Although reporting under the Medicare Access and CHIP Reauthorization Act (MACRA) is supposedly optional, not adhering to this new rule gets you a guaranteed Medicare reimbursement cut. The only way to head it off is to report at least some data in 2017. The question is, how should you report it?

This is no small decision since it can have a significant impact on how much you are paid for your future Medicare claims. Why will it have such an impact? Because if you report data under the Merit-Based Incentive Payment System (MIPS) as part of a group, your payment increase or decrease will be based on the entire group’s performance. On the other hand, reporting as an individual means bearing the full responsibility for your reportable data.

The Centers for Medicare and Medicaid Services (CMS) is able to define what payment adjustment you will receive by using a combination of your National Provider Identifier (NPI) and Tax Identification Number (TIN):

• Individual Provider — single NPI tied to a single TIN
• Group Provider — single NPI tied to a common TIN

If you report your MIPS data as part of a group, everyone within your group will receive the same payment adjustment based on the combined group’s performance. This could be a negative for high performers. For example, if the data you submit justifies you to receive a Medicare reimbursement increase, but the remainder of your group actually qualifies for a decrease, you’ll be paid on the combined rate – which, in this case, probably wouldn’t be a positive payment adjustment.

So if you are thinking about joining a group practice, you should make a point to know their payment adjustment score before you sign on the dotted line.

With MACRA now in play and the impact it can have on your Medicare reimbursement, you MUST take a hard look at your data reporting options before you make a decision. Making the wrong choice has the potential to reduce the money you receive from Medicare substantially.

Take Aways

• CMS will base your Medicare payment adjustment on the combination of your NPI and TIN.
• If you report as part of a group practice, everyone in the group will receive the same payment adjustment based on the group’s reported MIPS data.
• If you are thinking of joining a group practice, you should inquire about its Medicare payment adjustment as part of the review process.