This content is excerpted from EyeNet’s MIPS 2023: A Primer and Reference; also see the Academy’s MIPS hub page.
You can take part in MIPS as an individual or as part of a group.
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 Taxpayer Identification Number (TIN) (see "Use of TINs and NPIs as Identifiers"). At least one of them must be a MIPS eligible clinician.
What is group-level reporting? In group-level reporting, clinicians pool their MIPS data and are scored at the TIN level; they’ll all get the same 2023 MIPS final score and will receive the same payment adjustment in 2025. There are some advantages to reporting as a group: For example, if at least 50% of clinicians 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 performance category when reporting as an individual, but you wouldn't be excused from promoting interoperability when reporting as part of a group unless all the MIPS eligible clinicians in that group were also excused from promoting interoperability.
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 2025.
How do you know if your practice can participate as a group? First, go to the QPP Participation Status Tool. Next, enter the NPI for any clinician in the group. When the clinician’s information appears, make sure that it is for performance year 2023. If the clinician is associated with more than one practice, look at the listing for your practice and check the “Group” indicator of MIPS eligibility. If there is a green checkmark next to “Group” or if there is text saying that the practice is eligible to opt in as a group, then your practice can participate in MIPS as a group.
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. There was a Dec. 31, 2022, deadline for forming a virtual group for the 2023 performance year.
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