As the countdown continues toward the final 90 days for reporting MIPS there are some specific advantages for small practices worth noting. CMS defines a small practice as a practice with 15 or fewer clinicians. These advantages apply to both individual and group reporting for small practices, helping them as they move toward a fast approaching time, when all practices will be required to report MIPS with no exceptions.

The small practice status this year will be determined by September 30, 2023. If a new clinician joins the practice after September 30, the designation of small practice will still apply. Clinicians in small practices have some advantages that may help them reach the 75 point performance threshold for 2023, to avoid any negative payment adjustments in 2025. To check the status of a Provider, click here, or to check the status of all clinicians in a practice at once, click here.

The first noteworthy advantage is that CMS has extended the Quality category bonus of +6 points for clinicians who are in small practices and submit, at least, 1 Quality measure. The measure can be submitted as an individual, a group or a virtual group. Note: This bonus does not apply to clinicians or groups under facility based scoring or for practices over 15 providers.

Small practices that submit Quality measures that do not have a current benchmark will receive 3 points. They will also receive 3 points for quality measures submitted that do not meet the case minimum requirement (20 cases) or the data completeness requirement (70% of eligible cases).

Small practices will automatically have their Promoting Interoperability (PI) category re-weighted to 0%. No PI Hardship Exception application is necessary for this automatic re-weighting. Note: if the practice chooses to submit PI data, the data will be scored and the re-weighting option will be void. Keep in mind that the Quality category will increase from 30% to 40% if PI is re-weighted to 0% and the IA category will increase from 15% to 30%. Cost will remain at 30%.

For the Improvement Activities (IA) category, small practices also have a smaller reporting burden. They are only required to perform and attest to 1 high weighted activity OR 2 medium weighted activity.

Eligible clinicians or groups that do not meet the low volume threshold will continue to be excluded from the requirement to report MIPS data. The low volume threshold requirements are: less than 201 Medicare Part B patients or less than 201 covered professional services under Medicare or less than or equal to $90,000 in allowed charges for covered professional services under Medicare.

As a small practice, it is still possible to report data directly to CMS for 2023, however, a certified registry can provide an excellent source of expertise for all MIPS reporting.