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What Small Practices Should Know about MIPS

Some important changes were made to the Merit-based Incentive Payment System (MIPS) last year (2019). For one, Mental Health Practices and Physical Therapists became eligible to participate in MIPS in 2019. MIPS is one of the two ways the Center for Medicare and Medicaid Services (CMS) rewards specific providers on value and outcomes. Providers report their data and are measured in four areas - Quality, Improvement Activities, Promoting Interoperability, and Cost.


Further several adjustments were made to accommodate small practices and help them perform well in the Quality Payment Program. According to CMS, "For Performance Year 2019, we remain committed to identifying flexibilities and options to help clinicians in small practices meaningfully participate and succeed in MIPS."

Payment adjustment kicked in January of 2019 and whether you are receiving a positive or a negative payment adjustment, your goal should still be to strive to improve your MIPS score. CMS has added so much flexibility to MIPS, making it easier for clinicians-particularly small practices - to meet requirements.


Overall Flexibilities Accommodations

  1. Group Formation: Small practices with 10 or fewer clinicians can team up with other practices. This means you can form virtual groups and participate in MIPS together.

  2. Bonus Points: Six bonus points will now be added to your score in the Quality Performance category if you submit data for one measure (whether as a standalone practice or in a virtual group with others). In 2018, the bonus points awarded were 5 and it was added to the total score, instead of just the Quality category.

Quality Performance Category

  1. Mode of Submission: When reporting data for the Quality performance category, you can choose to continue to submit through Medicare Part B claims.You can also decide to submit by logging onto Qpp.cms.gov and uploading your files in the approved format. Finally, you can get a third-party intermediary to obtain data from your certified EHR Technologies (CEHRT) and submit it directly for you.

  2. Measure Points: If you submit data for a measure in the Quality category that does not meet completeness requirements, you will be awarded 3 points for it. This is compared to the 1 point other larger practices will receive if they submit incomplete data.

Performing Interoperability Category Accommodations

  1. Hardship Exception: As a small practice, you can apply for a hardship exception, which would get the performing interoperability category reweighed to 0% for you. If your application is approved, the category will have no bearing on your final score and the 25% it normally accounts for will be reallocated to the Quality category. Your hardship exception application will need to have been approved before the 31st of December 2019 for it to apply to your score in the performance year of 2019.

Improvement Activities Category Accommodations

  1. Activity Weight: Typically, high-weighted activities and medium-weighted activities in the Improvement category receive twenty and ten score points of the total Improvement Activity performance category score respectively. However, as a small practice, when you submit a high-weighted activity, you get 40 points while medium-weighted activities, get you 20 points.

  2. Activities Required: As a small practice, you're allowed to report only two activities in this category- either one high-weighted activity or two medium-weighted ones. This is unlike larger practices who must report data for two high-weighted activities or four medium-weighted activities. The CMS notes that this flexibility applies especially for small practices "in rural locations and in health professional shortage areas."

While many options have been provided to help you perform well in MIPS, you shouldn't become too relaxed. To avoid being penalized and getting a negative payment adjustment, you need to stay on top of MIPS reporting.


It's not just avoiding penalties, you shouldn't leave money on the table either. Improving your MIPS score and getting a positive payment adjustment is easier than you think.


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