Making sense of MACRA: Group reporting under Merit-based Incentive Payment System

This is the third in a series of articles on how psychologists fit into Medicare’s new payment models.

If psychologists are added to Medicare’s new Merit-based Incentive Payment System (MIPS) in 2019, many will have the option to participate in MIPS reporting as part of a group practice and potentially earn bonuses for quality performance. Currently, psychologists are not included in the Centers for Medicare and Medicaid Services' definition of an eligible clinician under MIPS, and therefore are not required to report this year or next regardless of the size of their practice.

What happens in 2019?

If psychologists are required to report MIPS starting in 2019, some will have the option of reporting under MIPS as individual providers under their National Provider Identification number or as a group using the same Taxpayer Identification Number (TIN). With group reporting, the data submitted by all members of the group is combined and the group is assigned a composite score. Strong or weak performance by any members of the group will impact the score and consequently the group’s future payment adjustments.

Understanding the patient threshold set by CMS

MIPS contains a Low-Volume Threshold exclusion that for 2017 applies to providers who treat 100 or fewer Medicare beneficiaries or bill Medicare for $30,000 or less in allowed charges. CMS is now proposing that the Low Volume Threshold (LVT) for 2018 will be expanded to exclude providers treating 200 or fewer Medicare beneficiaries or billing for $90,000 or less in allowed charges. If this change is adopted for 2018 and beyond the majority of psychologists in Medicare would be exempt from MIPS reporting under the LVT. Even if the proposal is not adopted and CMS retains the 2017 LVT, many psychologists will still be exempt due to the small number of Medicare patients that they treat.

How groups are defined

In MIPS, a group is defined as two or more MIPS eligible clinicians who have reassigned their Medicare billing rights to the group’s TIN. MIPS applies the LVT at both the individual and group levels so while five psychologists in a group practice might each be excluded as individuals, when combining their services under one TIN the group may exceed the LVT, thus triggering the MIPS reporting requirement.

How groups report

Unlike Medicare’s previous reporting program, the Physician Quality Reporting System (PQRS), no special registration is required to report as a group in MIPS. Registration is only needed if the group:

  • Has 25 or more MIPS eligible clinicians.
  • Chooses to report using the CMS Web Interface and administer a survey called the Common Assessment of Healthcare Providers and Systems. 

Groups have the following data submission methods to choose from: claims (quality measures only), qualified registries, qualified clinical data registries, electronic health records (EHRs), and the CMS Web Interface.

Group reporting in MIPS involves the same four categories as it does for individual reporting. Three of the four stem from previous stand-alone programs in Medicare: 

  • Quality (formerly PQRS).
  • Advancing Care Information (formerly EHR meaningful use).
  • Cost (formerly the Value-Based Payment Modifier).
  • Clinical Practice Improvement Activities (a new category).

Group reporting involves combining the data submitted by every provider in the group and then assessing the group’s performance across all four categories. A single payment adjustment then applies to everyone in the group.

What psychologists need to know for 2017 and 2018

Right now, psychologists can voluntarily report MIPS without the possibility of penalties or bonus payments. If a psychologist is part of a group practice that involves MIPS eligible clinicians, such as physicians, and chooses to voluntarily report under MIPS, then the psychologist’s performance data would be combined with other practice members. In this situation, the psychologist’s score would impact the group’s composite score. The psychologist, however, would not be penalized or receive bonuses based on the group’s score because psychologists are not yet MIPS eligible clinicians.

Read more about how MACRA will affect practicing psychologists: