Ophthalmology and Optometry Coding Alert

Take advantage of these tools to achieve success in the QPP.

Submitting Merit-Based Incentive Payment System (MIPS) measures can be taxing for any practice; however, smaller practices might have an especially tough time with MIPS reporting.

The reason: Budget constraints and staffing shortages tend to affect smaller practices the most, so compiling the necessary MIPS data may pose challenges. However, there are resources that can help small practices meet the requirements. The Centers for Medicare & Medicaid Services (CMS) realized the complexity associated with the MIPS program and the importance of incentive payments for quality care — especially for small practices. Due to the fact that traditional MIPS and MIPS Value Pathways (MVPs) are 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.

Check out these seven simple steps you can take to bolster your PY 2023 MIPS experience.

1. Bookmark the small practices portal on the Quality Payment Program (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 MIPS eligibility is fluid. Another important point to consider is changes in MIPS eligibility during the course of a performance year. For example, if a provider changes practices or reports under different specialty types between segment 1 and segment 2, that could alter their 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 changing from one snapshot to the next, not billing Part B claims under the practice Tax Identification Number (TIN) during segment 1, or not having 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 zero, 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.