2023 MIPS Program: Small vs Large Practice

The Centers for Medicare & Medicaid Services (CMS) designates small practices as those that have 15 or fewer clinicians; and therefore, have special allowances under the Merit-based Incentive Payment System (MIPS) in order to reduce burden on small practices. This includes varying submission methods and special scoring considerations as illustrated here.

The CMS has reweighted Quality for small practices. Quality is 50% of their overall MIPS score. For large practices, weighting is still 85% of their overall MIPS score. Individuals or groups must meet the Quality category reporting requirements:

• Report a minimum of 6 measures
• One must be an outcome or high priority measure
• 12-month reporting period
• 70% data completeness (70% of all patients, regardless of payer, that meet the measure denominator)*
• 20 case minimum per measure

*The only exception is for measures submitted via Medicare Part B claims, which can only be submitted by small practices. For Claims measures, pathologists must submit data on 70% of all Medicare Part B patients that meet the measure denominator during the performance period.