• MIPS 2018—Nuts and Bolts: Small or Large Practice?

    Written By: Rebecca Hancock, Flora Lum, MD, Chris McDonagh, Cherie McNett, Jessica Peterson, MD, MPH, and Sue Vicchrilli, COT, OCS

    This content was excerpted from EyeNet’s MIPS 2018; also see the Academy’s MIPS hub page


    The impact of some MIPS regulations depends on the size of your practice, and small practices sometimes get a break. For the 2017 performance year, you could attest to your practice size, but this year CMS will make that determination—and will do so based on historic data.

    How CMS determines practice size. CMS determines how many eligible clinicians are in a practice by reviewing claims data and looking at the number of NPIs associated with the practice’s TIN. This would include NPIs of eligible clinicians (NPIs) who were excluded from MIPS—see Who Does (and Doesn’t) Take Part in MIPS—and consequently weren’t taking part in the MIPS program.

    Next, it designates practice size as follows:

    • Small practices have 15 or fewer eligible clinicians.
    • Large practices have 16 or more eligible clinicians

    What data does CMS look at? In determining practice size for the 2018 performance year, CMS looks at 12 months of claims data, from Sept. 1, 2016, to Aug. 31, 2017, and will include a 30-day claims run out. Unfortunately, this means practices that have fewer than 16 eligible clinicians in 2018 could be designated as large based on historic data.

    Size determined by spring. If your practice is deemed small, CMS has said that it will notify you of that by spring 2018. You also will be able to look up the result of this size determination at https://qpp.cms.gov/participation-lookup.

    Review your roadmap. For a succinct MIPS guide that is tailored to your practice size, see the small practice roadmap or the large practice roadmap.

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