Medicare Compliance & Reimbursement

Tip: Utilize the plethora of tools and flexibilities CMS offers.

Whether you’ve been all-in since 2017 or are just submitting measures for the current performance year, the Merit-Based Incentive Payment System (MIPS) can be daunting for small practices. From staff shortages to budget constraints, compiling the necessary data poses challenges, but there are resources and guidance to help small practices meet the requirements.

Context: The Centers for Medicare & Medicaid Services (CMS) realizes the complexity associated with the MIPS program and the importance of incentive payments for quality care — especially for small practices. With Traditional MIPS and MIPS Value Pathways (MVPs) running concurrently for performance year 2023/payment year 2025, CMS has beefed up its small practice assistance with safeguards and flexibilities to better ensure providers’ success.

Here are seven items you may not be aware of that can bolster your PY 2023 MIPS experience:

1. Bookmark the small practices portal on the QPP website. If you haven’t scoped out this QPP feature, now is a good time to skim through the offerings. CMS provides links to downloadable guidance, general MIPS information, and small practice specifics. Because the QPP online resources are vast and clunky, having this option to go directly to small practice details without sifting through myriad data is critical.

2. Register for the QPP Small Practices Newsletter. This handy resource is chock full of information from measures changes, program updates, and deadlines. However, there’s a caveat — the resource isn’t readily available on the QPP website. In order to get the update, you must sign up for the monthly newsletter.

One nifty feature CMS offers in the newsletter is its “at-a-glance” calendar. “Each month, we share required and recommended activities for small practices to support their successful participation in QPP,” the newsletter says. “The activities follow a rolling quarter approach, letting you see activities for the previous month, the current month, and the following month.

3. Use the tools to figure out if you are required to participate. Before you dive in and start amassing measures and data to submit, determine if you’re eligible via the QPP portal with your National Provider Identifier (NPI). If you’re part of a small practice, you have four criteria to meet in order to participate, which include the following:

• Practice as one of the 13 possible clinician-types;
• Be enrolled before Jan. 1, 2023;
• Not be identified and/or participating as a Quality APM Participant (QP) under the Advanced Alternative Payment Models (APM) side of the QPP;
• Surpass the low-volume threshold requirements as an individual.

4. Understand that your MIPS eligibility is fluid. Another important point to consider is your MIPS eligibility changing during the course of a performance year. For example, if you change practices or report under different specialty-types between segment 1 and segment 2, that could alter your eligibility. Also, “you won’t be eligible to participate if you fall below all 3 elements of the low-volume threshold in segment 2 of the MIPS Determination Period,” QPP guidance reminds.

According to CMS, other reasons your status might change include: opting out of an APM entity during PY 2023; QP changes from one snapshot to the next; stop billing Part B claims under the practice Tax Identification Number (TIN) during segment 1; or not have Part B claims in segment 2.

5. Familiarize yourself with the MIPS flexibilities for small practices for PY 2023. CMS wants to see more small practice participation in the QPP — and continues to minimize the requirements, making it easier to be a part of MIPS. For PY 2023, small practices can count on these policies:

• Option to participate without an electronic health record (EHR)
• Scoring flexibility and reduced requirements in the Quality performance category
• Automatic reweighting of the Promoting Interoperability category to 0, but still have the option to submit measures
• Reduced reporting requirements and flexible data requirements for the Improvement Activities category
• Option to reweight and redistribute across all performance categories

6. Remember there are three reporting paths and five participation options for PY 2023. MIPS-eligible clinicians have three distinct ways to report their measures and five possible participation paths. Here’s where it gets tricky — your participation option will dictate the reporting path. Here’s a breakdown of the various reporting and participation options:

Traditional MIPS: There are four ways to participate in Traditional MIPS: individual practitioner, group, virtual group, and APM entity. Virtual groups had to be organized and elect this route by Dec. 31, 2022.

APPs: The APM Performance Pathway (APP) is open to solo MIPS-eligible clinicians, groups, and APM entities. “The APP is designed to reduce reporting burden, create new scoring opportunities for participants in MIPS APMs, and encourage participation in APMs,” CMS reminds in QPP guidance. “This reporting option is available to MIPS-eligible clinicians identified on an APM Partici­pation List or Affiliated Practitioner List of an APM Entity participating in any MIPS APM on any of the 4 snapshot dates (March 31, June 30, August 31, and December 31) during a performance year.”

MVPs: Providers can submit measures as an individual MIPS-eligible clinician, a single specialty group or a multispecialty group, a subgroup, and an APM entity. “Single specialty group is defined as a group that consists of one specialty type as determined by Medicare Part B claims” while a “multispecialty group is defined as a group that consists of two or more specialty types determined by Medicare Part B claims,” according to the 2023 MVPs Implementation Guide. “A subgroup is a subset of clinicians within a group (identified by a single Taxpayer Identification Number, or TIN) which contains at least 2 clinicians, 1 of whom is an individually eligible MIPS eligible clinician,” the guidance notes.

7. Stay on top of the deadlines. With all the resources available to small practices, you should be able to plan out your various MIPS filing and review deadlines. Bookmark this QPP timeline link for PY 2023 for reference at https://qpp.cms.gov/resources/deadlines.

Resource: Check out the small practice page with links to sign up for the newsletter, auxiliary FAQs, resource and implementation guides, and more at https://qpp.cms.gov/resources/small-practices.