In the new year, it’s easy to feel overwhelmed with all the new standards and expectations for your practice. That’s why we’ve broken down the nitty-gritty basics you’ll need to thrive in this new year — both for your patients, and your practice.
First, let’s get our vernacular handled so we’re on the same page.
“Must Report” versus “Can Report”
Simply put, “Must report” means that you’re eligible to report according to CMS. On the other hand, “Can report but doesn’t have to” allows you to “opt-in” according to CMS. Now that you’re clearer on these, hopefully you know where your particular practice falls on this spectrum so you can make an educated decision.
You can also look up individual provider status if you’re unsure about where to begin.
Next, you’ll look up one of your NPIs in the system. Make sure you choose 2023 performance year to ensure you’re looking at the relevant data points that you need. The associated practice will show the provider with a line for “MIPS Eligibility”. A black circle with a line through it means you don’t have to submit MIPS data.
Options for MIPS reporting for Individuals
If you are submitting at the individual level or you are a sole proprietor, you can also opt-in for MIPS reporting for the chance of achieving a bonus/positive payment adjustment. The process is simple, all you must do is see if your screen looks like this:
TIN Help at the Group Level
This same opportunity is valid for groups of people looking to report MIPS as well. However, please note that this is never mandatory — you can (and should) decide how you want to report data for your practice. This is merely offered as a convenience if the majority of providers are MIPS eligible because it allows the entire group to share in the benefit of a potential bonus and further avoids the risk of negative payment adjustments.
Get your TIN and list of doctors from QPP:
- Log into qpp.cms.gov
- Choose Eligibility and Reporting on the left side navigation bar
- Select 2023 performance period from the performance year pull-down under the Eligibility and Reporting heading
- Navigate to your practice by scrolling down
- Choose “View practice details & clinician eligibility” link under your TIN
- Choose Download link under Connected Clinicians
- Open the file “Clinicians – Eligibility.csv” using Excel or Google Sheets
You should see rows with providers listed on each one. Pay special attention to column F, where you should see “MIPS ELIGIBLE”.
No – Individual, No – Group
This means the provider is not MIPS Eligible (and therefore, not required to report MIPS data neither as an individual or a group, as established above).
Yes – Individual, Yes – Group
The provider does have to report MIPS at the individual level in order to avoid a negative payment adjustment, and they “can” report as a group as well, but remember — group reporting is never mandatory.
If you’re still on the fence about understanding that group reporting really is always optional, take it from CMS themselves:
Are we required to report on MIPS as a group?
QPP response: For MIPS, groups are never required to report. Eligibility is looked at on the individual level. So for example, if you have a practice with five clinicians, and all five are exempt from reporting due to not meeting the Low-Volume Threshold (200 or more Medicare Part B Patients, 200 or more covered services, and $90,000 or more in allowed charges), but if the group is above this threshold, then they could put their data together and report as a group. However, it would not be compulsory to do so.
To determine individual eligibility, this can be done by either visiting the QPP Participation Lookup tool at https://qpp.cms.gov/ and putting in the Individual NPIs of of the clinicians at your group in the “Check Your Participation Status” near the top of the page.
If you have a lot of clinicians at your Tax ID, you can check the eligibility of all associated NPIs to your Tax ID by signing in to the QPP Portal using the same link above, provided you have access to your facility within the QPP Portal.
Need more help? Never fear — Patient360 is here.
For all your MIPS reporting needs, Patient360 is ready and willing to guide you through the process to ensure that your practice is properly compensated. You also might benefit from reviewing helpful PDFs. We’ve got the 2023 MIPS Eligibility and Participation User Guide and the 2023 MIPS Group Participation Guide – Traditional MIPS at your fingertips. For any other concerns or help with MIPS CMS reporting, don’t hesitate to contact Patient360 anytime.
