MIPS Sub-group Option
The MIPS 2023 Subgroup Option allows multi-specialty groups to voluntarily participate in subgroup reporting and can help you earn higher MIPS scores. To be eligible for the subgroup option, your group must have two or more specialties that are eligible for MIPS, and all of those specialties must be included in the subgroup. By participating in this option, your group can benefit from increased MIPS scores, as well as gain insight into how each specialty is performing within the larger context of your practice's performance.
The MIPS 2023 Subgroup Option offers a number of advantages to practices. For example, CMS believes that allowing multi-specialty groups to form sub-groups will enable specialties to select MVPs that are most relevant to the care they deliver. Starting in 2025, subgroup reporting will be mandatory for multi-specialty groups that choose to participate in an MVP.
How does it work?
To allow flexibility for groups to explore the different ways they could utilize subgroups, CMS is not proposing any restrictions related to the composition of a subgroup. Instead, CMS is proposing that a group must submit a description of each subgroup at the time of registration. For 2023, CMS will only allow 1 subgroup per TIN.
Registration Deadlines
Clinicians who choose to participate in a subgroup to report an MVP must register as a subgroup between April 1 and November 30 of the performance year on the QPP website. In addition to the required MVP registration information, the subgroup registration must include:
A list of Taxpayer Identification Numbers (TINs)/National Provider Identifiers (NPIs) in the subgroup;
A plain language name for the subgroup (which will be used for public reporting);
A description of the composition of the subgroup, which may be selected from a list or described in a narrative.
Clinicians (identified by NPI) may register for one subgroup per TIN.
Eligibility
CMS will use the first segment of the MIPS determination period to determine the eligibility of clinicians intending to participate and register as a subgroup. As previously finalized, each subgroup must include at least one MIPS-eligible clinician.
Scoring
CMS will calculate and score administrative claims measures at the TIN level, not at the subgroup level:
Foundational Layer (MVP Agnostic) - For each selected population health measure in an MVP, subgroups would be assigned the affiliated group’s score, if available. In instances where a group score is not available, each such measure would be excluded from the subgroup’s final score.
Quality Performance Category - For each selected outcomes-based administrative claims measure in an MVP, subgroups would be assigned the affiliated group’s score, if available. In instances where a group score is not available, each such measure would be assigned a zero score.
Cost Performance Category - Subgroups would be assigned the affiliated group’s cost score, if available for the cost performance category in an MVP. In instances where a group score is not available, each such measure would be excluded from the subgroup’s final score.
For 2023 subgroups reporting final scores, CMS will not assign a score for a subgroup that registers but does not submit data as a subgroup.
Want To Know More?
If your practice wants help in registering or supporting a subgroup, or needs help with traditional MIPS, we can help. Give us a call at 888-647-7247 to get started today.
