This content is excerpted from EyeNet’s MIPS 2020; also see the Academy’s MIPS hub page.
While tackling MIPS is burdensome for all MIPS eligible clinicians, it is particularly challenging for solo practitioners and small group practices. With that in mind, CMS has provided small practices with several accommodations that can help them avoid the penalty and, perhaps, enable them to earn a small bonus.
What Is a Small Practice?
A practice is designated as small if it has 15 or fewer eligible clinicians. Simple, right? Not quite. As described in “Small or Large Practice?”, CMS reviews claims data from two 12-month time segments (see “MIPS Determination Period”) to determine how many eligible clinicians are associated with your practice.
Does CMS think your practice is small or large? You can check online (see “What’s Your MIPS Participation Status?”).
Accommodations for Small Practices
Avoid the Maximum –9% Penalty
Score more than 11.25 points to avoid the maximum –9% penalty. Even if you don’t get a MIPS final score of 45 points, which is what you need to avoid a future payment penalty, you can minimize the penalty by getting as close to 45 points as possible.
If you score less than 45 points but more than 11.25 points, your penalty will be based on a sliding scale (see “Table: Payment Penalty”).
If you score 11.25 points or less, that sliding scale becomes a precipice and your payments will be subject to the maximum –9% penalty.
MIPS and COVID-19
Will the pandemic prompt CMS to create new accommodations for practices? If it does, there may be a new route for avoiding the penalty, but nothing had been announced at time of press.
For the latest news, check your email for Washington Report Express (Thursdays) and—if you are an AAOE member—Practice Management Express (Sundays).
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