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Center for Medicare and Medicaid Services (CMS) completed a “Group Reporting” webinar last week that covers the requirements of the group reporting option for the Quality Payment Program. The webinar covered topics such as how to assess your status as a group, your reporting options, and more information about the handy CMS Web Interface option.
Some of the biggest draws to the CMS Web Interface reporting option are designation of patients and measures for reporting. This effectively removes the guess work and streamlines your workflow. You must be a member of a group of 25 providers who’s NPIs are reassigned to a billing TIN (Tax ID#). If you are part of a group of this size and plan to report through the Web Interface, time is running out to elect your group for this status. Registration closes on June 6th, 2017, so don’t delay! Check out more details on Web Interface registration here.
Even if you are not a member of a group of 25 or more individuals, and not able to report under the Web Interface, the option for reporting as a group does offer certain advantages. You may report less measures in any category because you can share these reporting measures with your group. You may also gain positive incentive by reporting as a group if you were previously told, as an individual, that you were excluded from the program in 2017.
Where would you start?
To begin reporting as a group, you would assess the combined annual reimbursement from Medicare to verify that your group is meeting the $30,000 requirement. You and the other members of your group would then reassign your NPI to a TIN and begin reporting to the required categories and measures. This still excludes reporters who were first licensed in 2017, where no reimbursements are available.
Incentives are paid out at the TIN level and will reflect the outcome of the unified reporting. All category information must be reported as a group and in the same manner of attestation. For example, you would not report to the Quality and Improvement categories with your group and attest to your individual Advancing Care measures using a different submission method.
All three categories must be attested to using an aggregate of the data collected by all group members during reporting. This means groups cannot report the Quality category using G-Coded claims, as these billings are not seen as combined. The Quality category, for groups, would consist of reporting up to 6 collective Clinical Quality Measures (CQMs).
There are pitfalls to reporting as a group such as being dependent on each member of the group to “pull their weight.” You could also inherit a poor Quality score when joining a new group. Knowing all of the facts about the group you plan to work with could lead to a positive decision or create more work in the long run.