Reporting Options Overview

Now that you’ve determined that you are a MIPS eligible clinician, let’s look at some next steps.  We’ll break it down into three categories: MIPS Eligible Clinician, Opt-in Eligible Clinician, and MIPS Exempt Clinician.

MIPS Eligible Clinician

If you’re a MIPS eligible clinician, identified by a unique Taxpayer Identification Number (TIN)/National Provider Identifier (NPI) combination, then you’re required to submit MIPS data. You can report MIPS data at one of the following levels: individual and/or group, virtual group, or; MIPS APM entity.

If you’re a MIPS eligible clinician, here are your next steps.  Determine if you’re participating as an individual and/or group, virtual group, or MIPS APM entity.  Also determine if you qualify for any reporting factors that may impact your reporting requirements.  Then review the current performance year’s Quality measures and determine which collection types (eCQMs, claims measures, etc) make the most sense for your reporting requirements.  Start collecting your Quality data now and plan to collect at least 90 days of data for the other performance categories. And be sure to check updates to your eligibility to help plan your participation requirements, as these factors can cause eligibility to change.

If you’re required to participate in MIPS, you’ll receive a MIPS payment adjustment based on the data you submit or do not submit.

Opt-in Eligible Clinician

If you’re an opt-in eligible clinician, identified by a unique TIN/NPI combination, then you’re not required to report as an individual but can opt-in to report as an individual for MIPS.  Alternatively, you can elect to not opt-in and instead voluntarily report or not report at all. However, you can elect to opt-in to MIPS. If you elect to opt-in, you will be considered a MIPS eligible clinician and be required to report; receive performance feedback; receive a MIPS payment adjustment (positive, negative, or neutral); be eligible to have your data published on Physician Compare; and be assessed in the same way as MIPS eligible clinicians who are required to participate in MIPS and are therefore automatically included.

There’s also the possibility that you are associated with a practice that is eligible to report as a group, or opts-in to report as a group.  If this is the case, you’ll be treated as a MIPS eligible clinician and will receive the group’s score and MIPS payment adjustment. In this case, you don’t need to opt-in to receive the group score and payment adjustment. If you elect to opt-in as an individual and report MIPS data as an individual, you’ll receive the higher score between the two submissions.  If you are associated with a MIPS APM that is eligible or opts-in, the opt-in policy is applied at the APM entity level for clinicians and practices participating in MIPS APMs. If the MIPS APM entity is MIPS eligible and reports, or is opt-in eligible and elects to opt-in to report, they’ll be scored under the APM scoring standard. After the entity opts-in, individuals will be treated as MIPS eligible clinicians.

If you voluntarily report data to MIPS, you will receive performance feedback, allowing you to prepare for future years; and be eligible to have your data published on Physician Compare.  If you elect to voluntarily report to MIPS, you will NOT receive a payment adjustment based on the data submitted; or be included in the calculation of MIPS measure benchmarks.

These are your next steps.  First, determine whether you want to elect to opt-in to MIPS, report voluntarily, or not report at all; and determine if you qualify for any reporting factors that may impact your reporting requirements.  Next, review the current performance year’s Quality Measures and determine which collection types (eCQMs, claims measures, etc) make the most sense for your reporting requirements.  Start collecting your Quality data now and plan to collect at least 90 days of data for the other performance categories, and check updates to your eligibility to help plan your participation requirements. 

You’re a MIPS Exempt Clinician

If you’re exempt from MIPS as an individual clinician, identified by a unique TIN/NPI combination, you’re not required to participate in MIPS. However, if your practice is MIPS eligible or opts-in, and reports to MIPS as a group, you’ll receive a payment adjustment based on that group’s score. You’re also able to voluntarily report if you choose to do so.

If you elect to voluntarily report measures and activities for MIPS, you will receive performance feedback, allowing you to prepare for future years; and you will be eligible to have your data published on Physician Compare.  If you elect to voluntarily report to MIPS, you will NOT receive a payment adjustment based on the data submitted, or be included in the calculation of MIPS measure benchmarks. Your next step will be to determine whether your practice is eligible and will report, or if you want to voluntarily report.