Clarification is needed with the promoting interoperability and group submission for hospital based providers. If all of the claims the providers submit are POS 21 or 23, would they have the quality reweighted and be exempt from promoting interoperability?

If the group is 100% hospital-based, then the PI category will be re-weighted to quality.

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If small practices apply/receive a PI/ACI exemption, is that % reweighted to the quality category?

Yes.

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How will a clinician know if they are exempt?

First, determine if you're an eligible clinician type. Then, use the MIPS participation look up tool to determine if you exceed the low volume threshold: https://qpp.cms.gov/participation-lookup.

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If clinicians are exempt and decide to voluntarily participate in the MIPS program as a group, I understand they will not receive a negative adjustment. However, can they receive a positive adjustment if meeting or exceeding MIPS criteria?

Voluntary reporters do not receive a payment adjustment neither positive nor negative. However, beware that you could be considered eligible as a group, if your group exceeds the low volume threshold. If clinicians do not exceed the low volume threshold, individually, you can participate voluntarily that way.

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How can small practices apply for the exclusion for Promoting Interoperability?

They apply on the QPP site when the application portal opens later in the summer 2018.

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Are Behavioral Health clinicians included in the provider types?

Yes, if they are a physician or nurse practitioner. LCSW and therapists are not eligible clinician types at this time.

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For PI reporting, how should we handle reporting as a group if we use multiple EMRs within the same TIN? (The TIN is also a part of MSSP track 1).

You sum the data across the CEHRT to submit.

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What is the benefit of participating as a virtual group?

Virtual groups allow MIPS eligible clinicians to join forces without geographical boundaries to maximize their participation.

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For 2017 reporting, when do we receive information on where clinicians finished and their payment adjustments?

Preliminary feedback is available now.  However, final feedback and scores will be available summer 2018.  You are required to use your EIDM credentials for access.

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Is QPP full credit participation given for Improvement Activities, for MSSP Track 1 MIPS APM?

Yes, MIPS ECs in a MSSP Track 1 ACO will get full credit for the Improvement Activities (IA) category. More information on the 2018 IA points assigned to Shared Savings Program ACOs can be found in this guide: 

https://www.cms.gov/Medicare/Quality-Payment-Program/Resource-Library/Scores-for-Improvement-Activities-in-MIPS-APMs-in-the-2018-Performance-Period.pdf

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