This content is excerpted from EyeNet’s MIPS 2023: A Primer and Reference; also see the Academy’s MIPS hub page.
While MIPS is burdensome for all MIPS eligible clinicians, it is particularly challenging for solo practitioners and small group practices. With that in mind, the MIPS rules provide small practices with some accommodations.
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 determines how many eligible clinicians are associated with your practice by reviewing claims data from two 12-month time segments (see “MIPS Determination Period”).
Does CMS think your practice is small or large? You can check online using the QPP Participation Status Lookup Tool (see “What’s Your MIPS Participation Status?”).
Accommodations for Small Practices
Low-volume exclusion. You may be exempt from MIPS if you provided limited Medicare Part B services—in terms of allowed charges, patients seen, or actual covered services provided—over either of two 12-month segments of the MIPS determination period (see “Exclusion 2—eligible clinicians who are below the low-volume threshold”). This exclusion is most likely to benefit clinicians in small practices.
Quality—a 3-point floor for reporting a measure. If you are in a small practice, you can score 3 points for a quality measure by reporting just one patient for it via claims. (To get the 3 points reporting via the IRIS Registry, you would also need to report the data-completeness totals.)
Quality—a 6-point small practice bonus. When CMS determines your quality score, it will add 6 points to your numerator if you are in a small practice provided that you submit data on at least one quality measure. (For more on your quality score’s numerator and denominator, see “How CMS Calculates Your Quality Score.” )
Quality—can report via Medicare Part B claims. Clinicians in small practices have the option of reporting quality measures via claims, and they can do so whether participating in MIPS at the individual or at the group level. (Note: If you report via Medicare Part B claims, CMS will calculate a quality score for you at the individual level. However, it will only calculate a group-level quality score if you report another performance category at the group level.)
One downside of claims-based reporting is that it is done in real time. This means that you may need to start early in the year in order to satisfy the 70%–data completeness criteria that is needed to score more than 3 achievement points for a measure.
Furthermore, many of the benchmarks for claims-based reporting have significant scoring limitations, which can make it hard to get a high achievement points total.
An upside of reporting via claims is that you don’t have to track the data-completeness totals. This means that you can score 3 achievement points for a measure with minimal reporting. Doing that for six quality measures, along with the 6-point bonus for small practices that report quality, would give you a quality score of 40%. What would a quality score of 40% contribute to your MIPS final score?
This depends on how the performance categories are weighted: It would contribute 12 points if the default weights apply; 16 points if promoting interoperability (PI) alone is reweighted to zero; and 20 points if both PI and cost are reweighted to zero. In conjunction with a high score for improvement activities, such quality scores could help to lower your penalty. However, you would need to report on quality more substantively in order to avoid a penalty altogether.
To learn more about claims-based reporting, visit aao.org/medicare/claims-reporting-guide.
Improvement activities—score double. Clinicians with a special status, such as being in a small practice, only have to perform one high- or two medium-weighted activities to get a 100% score for the improvement activities performance category (see “How You Will Be Scored”). What would this contribute to your MIPS final score? It would contribute 15 points if the default weights apply; 15 points if cost alone is reweighted to zero; 30 points if PI alone is reweighted to zero; and 50 points if both PI and cost are reweighted to zero.
Promoting interoperability (PI) small practice exception. If you are in a small practice, you will be eligible for an automatic exception from the PI performance category unless you report PI data to CMS. (Note: This exception won’t apply if you are reporting as part of a group and one of your colleagues reports PI data.)
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