Part of the Understanding MACRA series provided you with a look at the advanced alternative payment models (APMs) and explained them in detail. This week we’re going to take a look at the differences between reporting as a group or as an individual and how to make sure you’re ready to get started.
Let’s look back at MIPS and the considerations you'll need to make in order to decide if you should participate at the group level or at the individual level.
An individual is defined as a single National Provider Identifier (NPI) tied to a single Tax Identification Number. If you send MIPS data in as an individual, your payment adjustment will be based on your performance along, even though there may be multiple eligible clinicians in your office. When reporting as an individual, you will send your individual data for each of the MIPS categories through an electronic health record, registry, or a qualified clinical data registry. You may also send in quality data through your routine Medicare claims process.
A group is defined as a set of clinicians (identified by their NPIs) sharing a common Tax Identification Number, no matter the specialty or practice. If you send your MIPS data with a group, the group will get one payment adjustment based on the group’s performance. When reporting as a group, your group will send in group-level data for each of the MIPS categories through the CMS web interface or an electronic health record, registry, or a qualified clinical data registry. To submit data through the CMS web interface, you must register as a group by June 30, 2017.
The main difference between the two is that sometimes utilizing the data across the entire practice will boost your level of performance for each of the measures. This is not always the case. You will need to determine if you believe the group option or individual option is a better one for your individual needs.
Although Virtual Groups will not be available for the 2017 Performance Year, it is the intention of CMS to implement them for future years. This will allow providers in different locations to associate as a group for reporting purposes, which helps providers that might otherwise have problems reporting on measures under MIPS. This is especially helpful for providers with limited direct patient interaction, in rural areas and those not able to report on full sets of measures for MIPS.
The Executive Director of Health IT Now, Robert James Horne, believes that virtual groups could potentially provide insight into how to encourage provider collaboration within alternative payment models and inform the development of new models and multi-provider episodes of care. He stated this in a letter to CMS along with the opinion that Virtual Groups will be essential to help providers cope with the changes.
Are You Prepared?
In order to ensure you are prepared to move forward with collecting data and successfully reporting for MIPS under the Quality Payment Program of MACRA here are three steps in you can take:
- Check that your Electronic Health Record (EHR) is certified by the Office of the National Coordinator for Health Information Technology. If it is, it should be ready to capture information for the MIPS advancing care information category and certain measures for the quality category. You will also need to note the year it was certified, either 2014 or 2015, as that will affect which measures you report for in the Advancing Care Information category. All you need to do is type in your vendor’s name and you will see if the certification is current and what year it is for. You can do that here: Check Certification Now.
- Choose which quality measures best fit your practice. CMS has created a terrific search engine for these purposes. You can search by specialty, keywords, high priority or data submission method using filters they created for this purpose. You will find that search engine here: Quality Measures for MIPS.
- Whether you need 2 or 4 improvement activities to achieve your score, you can choose them on a separate search engine that works much like the quality measure search engine you’ve already visited by now. The filters available are keywords, Subcategory Name and Activity Weighting. Remember, those that are weight high are worth 20 points and those that are weighted medium are worth 10. You can find all activities here: Improvement Activities.
- Finally, you can visit the search engine for the Advancing Care Information Category and download the measures that are available for the year in which your EHR was certified. You can find those measures here: Advancing Care Information.
Once you have taken these steps you’ll be ready to get started collecting the data. During the Performance Year, you’ll want to make sure you know how you’re going to organize your data for collection and be familiar with the submission method you will be using. Once that is done, you’ll be ready for the reporting period.
Now that you’re ready to take charge, come back next week where we’ll wrap it all up and explain some changes that you may see implemented during the 2017 performance year.