This content is excerpted from EyeNet’s MIPS 2020; also see the Academy’s MIPS hub page.
Practice size is determined by CMS based on the number of eligible clinicians in a practice:
- Small practices have 15 or fewer eligible clinicians.
- Large practices have 16 or more eligible clinicians.
CMS uses claims data to assign practice size. CMS determines how many eligible clinicians are in a practice by reviewing claims data during two 12-month time periods (see “MIPS Determination Period”) and looking at the number of National Provider Identifiers (NPIs) associated with the practice’s Taxpayer Identification Number (TIN). This would include NPIs of eligible clinicians who are not MIPS eligible clinicians—see “Who Does (and Doesn’t) Take Part in MIPS”.
Why practice size matters. CMS provides small practices with accommodations that can help them to avoid the MIPS payment penalty. For example, CMS doubles their score for performing improvement activities, adds a 6-point bonus to their quality score, gives them a 3-point floor on quality measures, and has created an undue hardship exception for promoting interoperability that is specifically for small practices. Also, only small practices can report quality measures via Medicare Part B claims, as described in the Academy Claims Reporting Guide.
Is your practice small or large? CMS will post its practice size determinations online (see “What’s Your MIPS Participation Status”).
Use a Roadmap. The Academy has developed guidance that takes practice size into account:
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