In webinars and other discussions throughout the year, we’ve talked about the process Medicare uses to determine your need to report performance data for 2018, the dollar figures considered, etc. Ultimately, the “how” isn’t as important as the answer to “do I need to submit for 2018?”. And that question is best answered by the definitive resource: the NPI lookup tool on the Quality Payment Program website.
- Head to https://qpp.cms.gov/participation-lookup
- Enter your individual NPI in the lookup tool
- Click “Check All Years”
The system will then return your eligibility status at each Tax ID your NPI was associated with during the first eligibility determination period. Why is that significant? Because each NPI/Tax ID combination is viewed as a distinct entity for reporting purposes. That means if you saw patients at multiple businesses during the year you’ll need to consider each one from a MIPS standpoint. And along the same line of thinking, it is completely possible that you could have reporting requirements at one business, but not at another because CMS looks at each one independently. Thankfully, the NPI lookup tool will help.
For each Tax ID, you’ll see a picture like posted below where your status as an “individual” and as a “group” is listed:
Now if you’re a solo doc and the only one who sees patients in the practice, both individual and group columns will be the same like above. But if you happen to practice in a setting with more than one doctor, it’s possible that you’ll see a picture like below where you’re exempt from reporting requirements if you report as an “individual”, but included in MIPS if you report as a “group”:
This gives you a degree of flexibility as you can say “I don’t want to be involved and I don’t care about seeing my reimbursements change in 2020” or you could say “I want a shot at seeing my Medicare reimbursements increase in 2020”. If the latter is true, the data from all of the doctors who provided care during the performance period would need to be aggregated into one set of stats and reported that way.
That might sound like a lot of work, but RevolutionEHR will make it easy for you. You’ve seen the MIPS – PI scorecard and you’ve also seen the MIPS – Quality scorecard. Both scorecards will offer you the ability to return performance data for just one doctor (“Individual” reporting) or return a single set of data for all doctors in the group (“Group” reporting). And you’ll be able to do that for each Tax ID associated to the practice. We’ll focus on the scorecards in future posts.
All said, a good starting point is to explore that NPI lookup tool to help get a grasp on what your reporting requirements are for 2018. Don’t rely on others to tell you what to do. The Rev360 Quality Reporting team has already assisted a group practice who was told “You don’t have to do anything for MIPS this year” by a billing company. Here’s what the QPP website showed for the practice:
The problem with the billing company’s guidance is that it neglects the possibility that the practice could make more money in 2020 if they report successfully as a group. Individual eligibility is only one part of the consideration. So remember that it’s important that you understand your own eligibility and what the QPP NPI lookup tool is telling you.
