Your MIPS Action Plan: Step 2 – Factors to Determine Reporting as a Group or as an Individual
August 29, 2017
Written by Sharon Phelps
An important step in your Merit-based Incentive Payment System (MIPS) action plan is determining whether you will report as a group or only report eligible clinicians (ECs) as individuals. There are multiple factors to consider when making this decision – some are obvious, while others are more nuanced and may require discussions with your entire team.
Let’s look at the definitions of each type of reporting first:
Reporting as an individual means you will submit data in the three reportable categories for each single National Provider Identifier (NPI) reporting under your Taxpayer Identification Number (TIN). The 2019 payment adjustments for this NPI will be based on the performance results of this NPI only.
If you are a solo practitioner, your only option for reporting will be as an individual.
If you have more than one eligible clinician in your group and you select individual reporting, you will likely choose to report on only those NPIs who exceed the low-volume exemption threshold. For more information on how to determine if your clinicians exceed the low-volume threshold, please see our previous blog.
Group reporting is defined as a set of two or more eligible clinicians sharing and submitting claims to Medicare under a common TIN. The resulting payment adjustments will be based on the group’s performance and will be applied to all the eligible clinicians in the group.
If you select to report as a group, you will include pertinent data for all the eligible clinicians submitting claims under your TIN whether or not they exceed the low-volume threshold.
Here are some factors to consider when determining to report as Group or Individual.
Each reporting method has its own cost and reporting as a group or individual can affect that cost. For example, most qualified registries charge per eligible clinician. If you have a large number of clinicians but only a few exceed the threshold, it may be cost prohibitive to report as a group. However, if you have a high score, your positive payment adjustment if you report as a group may offset those costs.
While the method of reporting will have the largest effect on administrative effort, reporting as a group or individual can also affect the time and resources needed to participate in MIPS. Choosing to report individually means you will need to track, trend, monitor and report quality measures, improvement activities and Advancing Care Information criteria individually for each practitioner. That can create an overwhelmingly complicated program to manage and may consume precious resources you could put towards improvement efforts.
Ease of ability to obtain results
If you are in a mixed environment with more than one Electronic Health Record (EHR) system in use or perhaps have some providers not using an EHR, you may wish to leverage the power of group reporting by using data only from those providers with the EHR that yields the data in the least difficult or complicated method to obtain. You may be able to cover some specialty practice providers where data and results would be very time consuming to obtain at the individual level. A mixed EHR environment can complicate decision making in a hurry, so please reach out to us with your questions if this describes your environment!
While the negative payment adjustments will only be applied to those eligible clinicians who exceed the exemption threshold volumes, the positive payment adjustments will be applied to all eligible clinicians in the group if you select group reporting. If you select individual reporting, there will be no adjustments (positive or negative) for those ECs falling below the exemption thresholds.
It’s time to sharpen the pencil and do some math! What is the Medicare Part B volume of those ECs in your group who fall below the exemption thresholds? Do you have star performers who could positively contribute to your group’s score?
Tip: Use a cost calculator to get a sense of your score as a group. If your MIPS Final Score exceeds 70 points, you will be positioned to get part of the high performance positive adjustment.
Each Certified Electronic Health Record Technology (CEHRT) vendor approaches MIPS a little differently. You will want to ensure your vendor is capable of reporting in the manner you wish to report. For example, some vendors prefer to report individually only and will not participate in group reporting. It will change your approach to MIPS if your vendor is unable or unwilling to do group reporting.
Public Reporting on Physician Compare
Your MIPS score is going to be publicly reported and each ECs MIPS score will follow them if they bill under a different TIN in the future. Are you aware if your community members use online rating systems or publicly reported data when selecting their health care providers? Are you in a highly competitive market space? If your high volume ECs have stellar scores and want to shine among their peers, reporting individually may allow you to showcase their performance in the future. Conversely, you may wish to select group reporting if your lower volume ECs are rock stars at addressing quality measures, engaging patients in using your CEHRT capabilities and contribute positively to the group score.
What is the approach of your clinic? Are you heavily focused on a team-based approach where everyone is seen as contributing to a common set of goals? Or, is your group configured so each eligible clinician is accountable for their improvement plans, results and outcomes? Groups can have clinicians with a wide variety of approaches and ideologies on what constitutes quality care and how to deliver that care. Using a group approach among a clinic of very independent practitioners with diverse documentation styles and workflows could be complicated or cause undue conflict.
While this list may not be exhaustive and you may find other factors of importance to your group, using these factors as a launching point will provide your group with questions for discussion and decision making.
Leave a reply, ask a question or share information using the “Leave a Reply” section below, or email Sharon Phelps directly with your questions or comments.