• MIPS 2019—Fundamentals: Use of TINs and NPIs as Identifiers

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


    TIN. The Internal Revenue Service assigns a Tax Identifier Number (TIN) to each practice for tax purposes.

    NPI. CMS assigns a unique 10-digit National Provider Identifier (NPI) to each individual health care providers.

    Individuals (TIN/NPI). CMS uses both your TIN and your individual NPI to distinguish you as a unique MIPS eligible clinician. If you have more than one TIN/NPI combination—because, for instance, you practice in more than one location or you move to a new practice—you will be assessed separately for each TIN/NPI combination. 

    MIPS groups (TIN alone). If you and your colleagues choose to participate jointly as a group, the group’s TIN alone will—for reporting purposes—be your identifier for all four performance categories. CMS defines a group as “a single TIN with two or more eligible clinicians (including at least one MIPS eligible clinician), as identified by their individual NPI, who have reassigned their billing rights to the TIN.” Typically, no registration is required to participate in MIPS as a group; the exception is if you are using the CMS web interface (which is unlikely to be an option for ophthalmology practices).

    Bonuses and penalties applied at the TIN/NPI level. Payment adjustments will be applied at the TIN/NPI level, regardless of whether you participate in MIPS as an individual or as part of a MIPS group.

    Your payment adjustment will follow you to your next practice. Your MIPS final score for the 2019 performance year will impact your payment adjustment during the 2021 payment year, and this is the case even if you move to a new practice after the 2019 performance year finishes. In that scenario, when CMS determines your 2021 payment adjustment, it will look at the 2019 final score that was associated with the NPI/TIN combination that you were using in 2019, not the 2019 final score that is associated with your new practice’s TIN.

    Special scoring for clinicians who join a practice late in the year. If you join a practice in the last three months of 2019, CMS will assume that you won’t have enough measures available to you to participate as an individual in MIPS at that practice. What does this mean for your score at that practice? If you join a newly formed practice (established after Oct. 1, 2019) or if you join an established practice where the clinicians are reporting as individuals, CMS will award you a MIPS final score of 30 points, which is this year's performance threshold, meannig that you would get a neutral payment adjustment in 2021 (no bonus and no penalty). However, if you join an established practice that is reporting as a group, you would get the practice’s group score.

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