Forum,
In this scenario a particular TIN shows clinical eligibility for 11 physicians in the QPP portal's new section Group Participation while two of these 11 physicians are listed as exempt in MIPS individually. This group is reporting to MIPS as a group through the American College of Radiology National Radiology Data Registry (NRDR). As the NRDR charges an annual fee per physician, it can get rather expensive to roster and submit data for all providers in the group esp. if they are not ACR members. As a result, my question is are there any 2018 MIPS rules aside of meeting the data completeness threshold of 60% that would inhibit "carving out" certain providers credentialed under a group TIN that would otherwise report minimal quality volume and would collectively not come close to falling under the 60% threshold by quality measure?
Further, if hypothetically a group credentials a third party radiology groups with 20-30 radiologists under their TIN but again report minimal volume collectively and/or only read non-Medicare studies under this TIN, can these providers be "carved out" from a group TIN roster? Would this effect the group's payment adjustment if certain providers were not included in the group TIN or would the payment adjustment be tied to all providers of the TIN regardless if certain providers would not have individually submitted data for their NPI #'s and wouldn't be otherwise eligible for a payment adjustment even if they opted as to submit their data?
Thanks in advance for those that made it through this painful inquiry.
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Gregory D. Wertz, MS
Director of Industry Research and Relations
MBMS, LLC
State College, PA
gwertz@mbms.net(814) 203-0088
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