• MIPS 2020—Small or Large Practice?

    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:

    Previous: Low-Volume Clinicians Can Opt In to MIPS

    Next: Small Practices Get a Break

    DISCLAIMER AND LIMITATION OF LIABILITY: Meeting regulatory requirements is a complicated process involving continually changing rules and the application of judgment to factual situations. The Academy does not guarantee or warrant that regulators and public or private payers will agree with the Academy’s information or recommendations. The Academy shall not be liable to you or any other party to any extent whatsoever for errors in, or omissions from, any such information provided by the Academy, its employees, agents, or representatives.

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