Medicare QPP

Physicians Advocacy Institute

Frequently Asked Questions Updated for 2023

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10. Can I report data for the different categories using different reporting mechanisms?

  1. Yes, multiple reporting options exist. However, physicians should be aware of reporting options as well as specific applicability by category and reporting type.

    Reporting mechanisms, which are available and/or approved, differ depending on whether reporting as an individual or group. Notably, available reporting mechanisms differ for individuals, groups, and Virtual Groups across each of the four MIPS performance categories. Furthermore, if you choose to report as an individual, you must report as an individual across all categories. If you choose to report as a group or Virtual Group, you must report as a group or Virtual Group across all categories.

    You can report different categories using different collection types and reporting mechanisms=. For example, you can report through claims for the quality category, report through your 2015 Edition CEHRT for the promoting interoperability (PI) category, and report through attestation for the improvement activities categories. Although you can use different reporting mechanisms for each category, you must use only one reporting mechanism per category. For example, under the quality category, you must report on at least 6 measures. You cannot report data for 3 measures through claims and data for 3 measures using a registry to meet the 6-measure requirement.

    The following chart outlines the different reporting mechanisms available by MIPS category and individual vs. group reporting.
    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; Log-In and Upload (only for those with 15 or fewer clinicians in group, virtual group, or APM entity)

    Log-In and Upload (only for those with 16-24 clinicians in group, virtual group, or APM entity)

    Log-In and Upload; Direct (25 or more clinicians in group, virtual group, or APM entity)
    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 Log-In and Upload; Direct
    Cost Individual No submission required. CMS will use administrative claims data.
    Group or Virtual Group

    For additional information, please see the PAI Practice Assessment Resource




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