• MIPS 2019—Fundamentals: Report as an Individual or as Part of a Group?

    This content was excerpted from EyeNet’s MIPS 2019; also see the Academy’s MIPS hub page


    You can choose to take part in MIPS as an individual or as part of a group. There is a third option, virtual groups, but few practices were able to meet the Dec. 31, 2018, deadline for forming a virtual group for the 2019 performance year.

    What is a group? For MIPS, a group consists of two or more eligible clinicians, each with their own National Provider Identifier (NPI), who have each reassigned their billing rights to the same Tax Identifier Number (TIN). At least one of them must be a MIPS eligible clinician.

    What is group-level reporting? In group reporting, clinicians pool their MIPS data and are scored at the TIN level; they’ll all get the same 2019 MIPS final score and will receive the same payment adjustment in 2021. There are some advantages to reporting as a group: For example, if one clinician in a group satisfies the requirements for a particular improvement activity, then the group as a whole scores points for that activity. But there are also some caveats to group-level reporting. For example there are limited circumstances in which you may be excused from the promoting interoperability (PI) performance category when reporitng as an individual, but you wouldn't be excused from PI when reporting as part of a group unless all the MIPS eligible clincians in that group were also excused from PI. A practice that opts to report as a group will be scored as a group for all four performance categories.

    What if you report as an individual and as part of a group? CMS will calculate two MIPS final scores for you. For the first final score, CMS will evaluate across all performance categories based on your individual-level reporting; the second final score will be based on group-level reporting. CMS will use the higher of those two MIPS final scores to determine your payment adjustments in 2021.

    Virtual groups. This year, you can participate in MIPS as part of a virtual group; however, you must have formed that group by Dec. 31, 2018.

    What is a virtual group? Solo practitioners and/or groups of 10 or fewer eligible clinicians can agree to form virtual groups for the purpose of MIPS reporting, scoring, and payment adjustment. In order to join a virtual group, a solo practitioner must be a MIPS eligible clinician and a group must have no more than 10 eligible clinicians (at least one of whom must be a MIPS eligible clinician). The virtual group must include two or more TINs, with each TIN belonging to a solo practitioner or a group of 10 or fewer eligible clinicians.

    Why form a virtual group? Small practices that combine together as a virtual group could potentially enjoy some of the economies of scale and expanded options that larger practices have.

    Few virtual groups in 2019. Clinicians have found it challenging to think through the complexities of MIPS within their own practice, never mind the repercussions of combining with other practices for MIPS reporting. Consequently, few—if any—ophthalmology practices met the deadline for forming virtual groups for this performance year. However, any practices that did form a virtual group cannot leave the virtual group during the 2019 performance year.

    Previous: Fundamentals: Use of TINs and NPIs as Identifiers

    Next: Fundamentals: Small or Large Practice?

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