MACRA QPP Center

Physicians Advocacy Institute

Frequently Asked Questions Updated for 2020

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1. What if I don’t have an electronic health record

  1. Physicians and practices can still participate in the program without certified electronic health record technology (CEHRT), except for the Promoting Interoperability (PI) performance measures which requires CEHRT reporting mechanisms. The reporting mechanisms that can be used to submit your MIPS data depend on (1) the reporting options designated for that category and (2) whether you participate as an individual, group, or Virtual Group. Moreover, you can report different categories using different reporting mechanisms; you are not required to submit MIPS data using one reporting mechanism across all the categories.

    The table below details the alternative reporting mechanisms available:
    Category Reporting Options   
    Quality Individual (themselves or working with a Qualified Registry, QCDR, or CEHRT Medicare Part B Claims; Direct; Log-In and Upload
    Group or Virtual Group (themselves or working with a Qualified Registry, QCDR, or CEHRT Medicare Part B Claims (only for those with small practice designation); Direct; Log-In and Upload;
    CMS Web Interface
    (for 25 or more ECs); 
    CAHPS for MIPS Survey; Administrative Claims
    Improvement Activities Individual, Groups, Virtual Groups, and Third-Party Intermediaries (e.g., Qualified Registry, QCDR, CEHRT, CMS-approved survey vendor) Direct; Log-In and Upload; 
    Log-In and Attest (via qpp.cms.gov)
    Promoting Interoperability Individual, Groups, Virtual Groups, and Third-Party Intermediaries (e.g., Qualified Registry, QCDR, CEHRT,) Log-In and Upload; 
    Log-In and Attest (via qpp.cms.gov)
    Third-Party Intermediaries Direct
    Cost Individual No submission required. CMS will use administrative claims data.
    Group or Virtual Group

    To learn more about the reporting mechanisms at the individual, group, or Virtual Group level for each category, please see the MIPS Reporting Mechanism resource.



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