Here are two things you should know about the MACRA reporting requirements before adding new physicians to your group:
1. Clinicians have a two-year tail on their MIPS payment adjustments
In a world of MIPS scores, history matters—and clinicians can't simply shed their baggage by switching to a new practice.
All clinicians are associated with a combination of a specific Tax Identification Number (TIN) and National Provider Identifier (NPI), which defines their MIPS performance score. MIPS scores in any given year impact payment adjustments two years later.
If you report group data through your TIN, every current clinician in your practice will receive the same payment adjustment in 2019.
If you acquire new physicians, however, they likely will have a different 2019 payment adjustment because they carry their MIPS score for the past two years from their previous practice.
For example, imagine Dr. X received a low MIPS score in 2017 and 2018. You acquire Dr. X at the beginning of 2019—even though he is now part of your group, he, individually, will receive a negative payment adjustment in 2019 and 2020 based on his poor performance in 2017 and 2018. The 2019 MIPS score you report for him won't impact his payment adjustment until 2021.
This two-year tail will impact physician groups differently based on compensation structure. If physicians in your practice are paid under an "eat what you kill" productivity-based payment model, then their poor MIPS score will only influence their individual Medicare income.
However, if your medical group pays physicians a set salary, your net income could be impacted. For example, imagine you promised Dr. X a specific salary when you acquired him. You will still have to pay him that salary even though he will generate less Medicare income for those first two years as a result of those negative payment adjustments from his poor MIPS performance.
But that performance tail won't last forever. Now that you are reporting for Dr. X as part of your group, his performance will be incorporated into your group's performance. In two years, he will receive the same score as the other clinicians in your group.