Medicare Compliance & Reimbursement

Question: In the last issue, you mentioned “special status” and how it impacts Merit-Based Incentive Payment System (MIPS) scoring. How does a provider get that assignment for the 2023 performance year and how exactly is scoring affected?

California Subscriber

Answer: A number of things factor into whether you’ll fall into the special status grouping for PY 2023. First, the Centers for Medicare & Medicaid Services (CMS) collects and analyzes your Part B claims data — and that goes for the various provider types, including solo clinicians, practices, virtual groups, and alternative payment model (APM) entities.

Next, if “you meet the criteria in 1 of the 2 segments of the MIPS Determination Period,” you’ll be assigned a special status, QPP guidance explains. For PY 2023, there are seven separate special status groups your assignment could fall under: ambulatory surgery center (ASC) based; hospital-based; facility-based; non-patient facing; small practice; rural; and areas with health professional shortage.

Scoring changes are determined by your special status assignment within one of the seven groups, but that’s just the tip of the special status iceberg. Different performance categories (Improvement Activities, Promoting Interoperability, or Quality in the case of special status assignment) are reweighted depending on the group. Additionally, the reporting pathway — Traditional MIPS, MIPS Value Pathways (MVPs), or APM Performance Pathway (APP) — also factors into some of the special status scoring.

For example: Providers given a non-patient facing special status will earn 2x the points for each improvement activity reported via either Traditional MIPS or MVPs for the 2023 performance year. Clinicians reporting under the APP pathway will get full credit for the improvement activities for PY 2023. Those with non-patient facing special status will “also qualify for automatic reweighting of the Promoting Interoperability performance category to 0 percent,” QPP guidance says. “The performance category weight will be redistributed to another performance category or categories unless you choose to submit Promoting Interoperability data. This automatic reweighting applies to all 3 MIPS reporting options: traditional MIPS, the APP, and MVPs.”

Review other special status impacts and sign into the QPP Participation Status Tool at https://qpp.cms.gov/mips/special-statuses?py=2023#ambulatory-surgery-center-asc-based.