By: Tracy Sanders, RCC
Senior Billing & Coding Analyst at Alpha II, LLC
Think back to your days at school when you were assigned your first group project. While the outcome may have been successful, the beginning effort was probably strained. Learning to collaborate and rely on other’s strengths to promote your own success is a difficult concept to accept. Flash forward to adulthood and many people are still anxious about group participation. But just like that group project, combining efforts to reach a single goal may lead to a more favorable outcome than what you could achieve by approaching the task on your own.
Practices are no different when it comes to group collaboration. Yes, clinicians may come together to form a group and get paid under a single TIN, but each stakeholder in that group wants to ensure they’re maximizing their own reimbursement and can view collaboration as a risk. However, the most successful MIPS reporting practices have mastered the ability to rely on the strengths of their other group members. So how can you convince your practice to adopt group reporting?
Let’s start by resetting the view of what it means to be in a group practice. Payers and patients already see each individual clinician as a piece of the overall practice, so as a member of that group, try to do the same and realize everyone involved shares the same end goal as you. Understandably, it can be hard at first to trust that the everyone in the group adheres to the quality performance standards, especially if there is limited interaction with the other clinicians. However, since the goals of the Quality Payment Program (to improve care processes and health outcomes, increase the use of healthcare information, and reduce the cost of care) apply to the entire practice, why not collaborate and improve the overall image, level of care, and cash flow of your group?
Let’s look at some of the logistical and financial benefits of group reporting.
There is a common misconception that group reporting requires the practice to find six common measures, performed by all clinicians in the group, in order to receive a score in the quality performance category. The fact is, groups can select any six measures applicable to the services they perform, as long as they meet the 20-case minimum for each measure. The measure’s denominator population does not have to include patients seen by every clinician. Reporting through a third-party intermediary (like a qualified registry) where users can track their performance rate on more than six measures throughout the reporting year, allows for submission of the six highest scoring measures and will maximize your quality performance category score. If there are specialized clinicians in your group who have difficulty meeting case minimums or finding six applicable measures, aggregating data by TIN can easily bring them up to reporting minimums.
To receive a score under the Improvement Activities performance category, only one clinician in the group must perform the selected activity for the group to be able to attest. This allows the entire group to benefit from the work of a single clinician.
What is it costing you to continue to report MIPS as individuals? Besides the increased administrative time and effort of managing multiple data sets, there could be real dollars at stake for the practice by not reporting as a group. For example, let’s say your group has 10 clinicians – seven are exempt from individual reporting because they fall below the performance thresholds and three are required to report as individuals. If you only report on the three MIPS eligible clinicians, yes, you’re saving time by not coding and reporting on services performed by the exempt clinicians. But remember, any adjustment earned through group reporting is applied to all covered Medicare Part B services payable under the Physician Fee Schedule during the performance year, not just on services performed by the eligible clinicians. To get a general idea of the impact group reporting could have on your adjustment, take the percentage earned by your highest performing clinician and multiply that by the practice’s total Medicare Part B charges for the performance year. Compare that to the adjustments applied to each individual clinician in the same performance year. While it’s not an exact calculation, it still gives you an idea of the potential revenue.
As we move closer to the full MIPS implementation deadline in 2022, it becomes even more crucial for all clinicians to evaluate their reporting strategies. Upcoming program changes will affect the financial outlook of both individuals and groups. Those who use this extended MIPS roll-out to master their reporting will benefit overall, since they are implementing process improvements during the time when positive adjustments are relatively low. It’s not costing clinicians as much to figure out how to get the most from their reporting today, but CMS predicts bonuses for clinicians could top 27% in 2022. Now is the time to be proactive and ensure financial success for your practice in the value-based reimbursement future.