This content was excerpted from EyeNet’s MIPS 2018; also see the Academy’s MIPS hub page.
While the transition to MIPS is burdensome for all clinicians, it is particularly challenging for solo practices and small group practices. With that in mind, CMS has provided small practices with several concessions (see Table 5, below) that should help them to avoid the penalty and may enable them to earn a bonus.
What Is a Small Practice?
A practice is small if it has 15 or fewer eligible clinicians. Simple, right? Not quite. For the 2017 performance year, you could attest to your practice’s size based on real-time staffing levels. But for the 2018 performance year, CMS makes that determination—and does so based on historic claims data.
CMS determines practice size based on claims data from 2016 and 2017. CMS has said that, for operational reasons, it needs to know early in the performance year whether you are in a small practice, and this is why it now determines practice size based on historic claims data. To learn more, see Small or Large Practice?
CMS counts clinicians who aren’t participating in MIPS. When determining practice size, CMS counts eligible clinicians even if they aren’t taking part in MIPS because 1 of the 3 program exclusions applies. (You may be excluded from MIPS if you are new to Medicare, see a low volume of Medicare patients, or are an advanced APM participant.)
CMS is making its practice size–determinations available via the MIPS Participation Status lookup tool.
How to Avoid the MIPS Penalty
All small practices should be able to get a 2018 MIPS final score of 15 points, which would be enough to avoid a payment penalty in 2020. They can do this by:
- Performing and reporting 1 high-weight improvement activity; or
- doing minimal reporting (report on at least 1 patient at least 1 time) for 6 quality measures.
Although either option would earn a small practice a MIPS final score of 15 points, it would be safer to pursue both options, and to report quality more extensively. To review the activities and measures that are most relevant to ophthalmology, review an at-a-glance list of improvement activities (PDF) and an at-a-glance list of quality measures (PDF). (Note: Larger practices must do more to attain 15 points.)
Want help from CMS? CMS provides customized assistance to clinicians in small practices.
Review your roadmap. For a quick guide to MIPS that is geared toward the small practice, see the 2018 small practice roadmap.
Table 5: How CMS Accommodates Small Practices
|Small practice bonus for MIPS final score. If you report at least 1 MIPS performance category, you may be awarded a 5-point bonus if you are in a small practice (see Small practices get a 5-point bonus).
|Low volume exclusion. You may be exempt from MIPS if, over a specific 12-month period, you have Medicare Part B allowables of no more than $90,000 or care for no more than 200 Medicare Part B beneficiaries (see Exclusion 2—Eligible clinicians who are below the low-volume threshold). Given ophthalmology’s patient mix, this exclusion will apply to a limited number of ophthalmology practices.
|Virtual groups. CMS developed this option with small practices in mind, but few practices are likely to go this route in 2018 (see Virtual Groups).
|Small practices enjoy a 3-point floor for quality measures. Like last year, small practices can still earn 3 points for a measure with minimal reporting (see Meet the 2 Data Submission Thresholds).
|Promoting Interoperability (PI)
|Significant hardship exception. If you are in a small practice, you can apply to be excused from the promoting interoperability performance category, which was formerly known as advancing care information (ACI).
|Score double. If you’re in a small practice, your point score for an improvement activity is automatically doubled. (See How You'll Be Scored.)
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