HBMA RCM Advisor Q4 2019 – President’s Message








Patient engagement is a concept that combines a patient’s knowledge, skills, ability, and willingness to manage their own health and care with interventions designed to increase activation and promote positive patient behavior.*1 Trading “patient” for “attendee,” this is exactly what we saw at this year’s HBMA Healthcare Revenue Cycle Conference at Planet Hollywood in Las Vegas from Sept. 12-14. With near record-breaking attendance, there were HBMA members, nonmembers, vendors, exhibitors, and staff all interacting together, creating a positive atmosphere for everyone involved.

At the heart of HBMA is our collaboration and networking with one another. This was ever-present at this year’s fall conference. There were sessions designed specifically to promote connecting with other attendees, learning about their companies, and sharing issues, ideas, and solutions. In between sessions, attendees were busy with conversations over lunch and in the halls. It was great to see the buzz that circulated through the entire event!

Within the educational sessions, the attendees were engaged in the presentations, led by enthusiastic speakers. The ongoing exchange during question-and-answer periods pushed our time limits. Expert panels presented great, real industry perspectives on hot topics. Our own HBMA members headed up breakouts to offer advice based on their own experiences and on-the-job learning, providing an opportunity to more formally learn from our peers as well as established industry experts.

The exhibit hall was full of opportunities and alive with activity at the booths, up and down the aisles and all around. Everyone was exploring new services, sharing experiences, offering referrals, and visiting with current clients/business partners.

What a huge success for HBMA and an incredible collaborative effort! It could not be possible without all those who contributed. I extend the sincerest appreciation for our board of directors, many of whom have committee or task force responsibilities beyond their board duties, for leading HBMA successfully throughout this year and through this fantastic event. We must recognize, too, that we would not be here today without the work of all the members who gave their time as committee chairs, committee members, and other volunteers to prepare the agenda, education, and organize this affair, as well as our partners at SmithBucklin who really pull it all together for HBMA. Thank you all!

Collectively, the entire event was an overwhelmingly positive experience and brought out the true spirit of HBMA. As we carry forward through the remainder of the year, we need to continue that spirit as well as take the notes, ideas, tasks/to dos, relationships, and contacts and put them into action. A key to engagement is staying engaged. Don’t let your engagement with HBMA end at the conclusion of the conference. It is important to apply what we have gained at the fall conference to our everyday business. Follow up on your notes from the sessions, work your to-do lists, and reach out to the colleagues you connected with at the event. The return on investment happens by building your business, gaining efficiencies, adding new services, etc.

To continue to make HBMA great for you, these committee volunteers give countless hours of their time to support HBMA’s efforts in education, advocacy, and networking for the membership. To keep this energy, we need you to keep pushing forward. Please get involved and get engaged!

As president, I am glad to see so much progress and to have been able to work with so many great people who are leading HBMA through this year to make it better. I know the true leaders are those in the trenches giving their time, expertise, and energy every day, week, and month to make these great accomplishments possible. I am confident we will see HBMA carry forward these positive trends into the future as President-Elect Cindy Pittmon takes the reins on January 1, 2020.

– Mick Polo, CHBME, HBMA President

*1 HealthcareITnews, “What Does ‘Patient Engagement’ Really Mean?”, by Michelle Ronan, May 01, 2015


How to Simply Avoid the 2018 MIPS Penalty

How to Simply Avoid the 2018 MIPS Penalty

Blog Contributor:  Mingle Analytics


Eligible Clinicians may have difficulty finding the time and resources to fully participate in the 2018 MIPS reporting year – especially if you are part of a small practice. CMS has made 2018 another “Transition Year” for the new Quality Payment Program, meaning, they are still allowing different participation options to satisfy reporting requirements to avoid the 5% penalty.



MIPS: Individual vs. Group Reporting

Blog Contributor:  Mingle Analytics

MIPS: Individual vs Group Reporting Explained

The Quality Payment Program (QPP) allows physicians to choose whether they will participate in the MIPS program as an individual or a group. This is one of the first decisions a practice will need to make when planning their MIPS reporting strategy.

The impact of this decision affects the performance of each Eligible Clinician (EC) reporting under a Tax Identification Number (TIN), and ultimately, the potential to earn an incentive.

When selecting a reporting option, individual or group, the choice is made for all three categories.

Here’s a brief overview of each option.

Individual Reporting

According to CMS, an individual is defined as a single clinician, identified by a single National Provider Identifier (NPI) number tied to a single TIN. If you are an Eligible Clinician (read Mingle’s blog post about MIPS Eligibility if you aren’t sure) who chooses to report MIPS individually, your Final Score is based on your performance alone.

Reporting the three performance categories as individual means that you will need to find Quality measures and improvement activities for each provider in the practice. For “Promoting Interoperability” (the new name for Advancing Care Information) each provider must pass the base score measures on their own to qualify for points in this category.

While reporting as an individual allows complete control over the performance and payment adjustment, collecting the data individually for your ECs could also mean a large administrative workload.

If choosing to report as an individual, CMS allows you to choose one of the following methods to submit quality data:

  • Qualified Clinical Data Registry (QCDR)
  • Qualified registry
  • Electronic Health Record (EHR)
  • Claims

For quality, the eligible instances are determined by the patients seen by that provider in the practice. However, the quality action could be met by another provider they see.

For example: Measure 226, requires that you ask patients about smoking at least once within the two years prior to the eligible visit date in the performance year. If a patient sees provider A in the performance year, the patient is in the denominator for Provider A. If the patient was asked about smoking by Provider B in a visit during the previous year, Provider A gets “credit” for the quality action. However, if Provider B, does not see the patient in the performance year, the patient is not in the denominator for Provider B.

If provider B also saw the patient during the performance year, then both Provider A and Provider B would report (and receive credit for the quality action) for that patient and essentially, you would report on that patient twice within the practice.

Keep this example in mind as we think about how group reporting determines the denominator.

Group Reporting

CMS states that a group consists of a single TIN with two or more eligible clinicians (including at least one MIPS eligible clinician), as identified by their NPI, who have reassigned their Medicare billing rights to the TIN.

The process for group reporting allows a group of providers to submit their data and be scored collectively—meaning each physician in the group will earn the same MIPS Final Score—and receive the same payment adjustment (including EC’s that weren’t in the group during the performance year).

Fundamentally, group scoring treats all EC’s in the group as if they were one individual.

In most cases, group reporting significantly reduces the level of effort. And for very large groups, it might be the only method that is technically feasible.

Here is how group reporting affects each category.


Instead of choosing measures for each provider in the group, you select measures based on the patients seen by the whole practice. The measures do not have to apply to everyone in the group.

In a multi-specialty group, this means that you can choose measures that the group performs well on, even if some providers do not perform as well, or do not have eligibility for the measures chosen. This makes a big difference when you have many specialists in the practice.

The eligible instances for the measures are determined based on the patients in the practice, regardless of which NPI or how many NPIs saw that patient.

For example: Measure 226, requires that you ask patients about smoking at least once within the two years prior to the eligible visit date in the performance year. If a patient sees provider A in the performance year, the patient is in the denominator for the whole group. If the patient was asked about smoking by Provider B in a visit during the previous year, the group gets “credit” for the quality action.

If provider B also saw the patient during the performance year, the patient is reported on just ONCE for the group and the group receives credit for the quality action for that patient.

And any group of 16 or more providers and greater than 200 eligible instances, CMS will automatically calculate the All Cause Hospital Readmission Measure and it will count toward their Quality score. Individual providers are not eligible for this measure.

Promoting Interoperability (formerly Advancing Care Information)

For this category, just one provider needs to pass the base score measures for the whole group to earn performance points. However, the exclusions for HIE and eRx, apply at the group level, so that if the whole group has a Promoting Interoperability denominator of less than 100 for these two objectives, the group is excluded. If data for Promoting Interoperability is not available at the group level, the group score is a sum of the numerator and denominator for each of the measures.

Improvement Activities

For Improvement Activities, if just one provider is participating in an activity, the entire group gets credit.

Claims reporting is not an option as a reporting mechanism, but these other options are available:

  • Qualified Clinical Data Registry (QCDR)
  • Qualified Registry
  • Electronic Health Record (EHR)
  • CMS Web Interface (groups of 25 or more NPIs)

That summarizes how group reporting affects each of the MIPS performance categories, however, there are more rules and requirements that you need to be aware of when deciding your reporting option.

Additional Rules and Requirements

Groups of 25 or more also have the option to use Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS as a measure.

Note: Groups must register to participate in the CMS Web Interface or CAHPS for MIPS between April 1st and June 30th, these are the only two options that require registration with CMS.

If you have a group with both MIPS eligible-clinicians and non-MIPS eligible clinicians, there are different rules for whether or not to include their data:

  • If the clinician is not MIPS eligible according to their credentials, you have the option to include their data when reporting as a group.
  • If the clinician is MIPS eligible by virtue of their credentials but are excluded for some other reason (low volume, first year Medicare etc.) then their data must be included when reporting as a group.

To qualify to report as a group, collectively, the group must exceed the low-volume threshold, even if you were reporting individually, all individuals would be exempt. Likewise, if the group collectively meets the requirements to be exempt from reporting Promoting Interoperability, all of the group’s Promoting Interoperability points will be reweighted to Quality.

The advantage of reporting as a group, when all are low volume, is that the practice, as a whole, can earn an incentive, where they couldn’t if reporting individually.

If by chance, a practice reports as a group, and an individual also reports as an individual, since the actual adjustment is applied at the individual level, CMS will take the higher of the two scores, and hence the more positive adjustment, to apply to the individual.

One of the best resources for deciding on whether to report as an individual or a group is someone who is knowledgeable and experienced in the reporting process.  Contact our Partner, Mingle Analytics at 1-866-359-4458. Remember to mention you’re affiliated with Medical Billing Resources when speaking with a Mingle Team Member.


TELEMEDICINE: The “new normal” in medical billing
HBMA RCM Advisor Q4 2019 – President’s Message
How to Simply Avoid the 2018 MIPS Penalty
MIPS: Individual vs. Group Reporting
MIPS: Transition Year vs. Full Reporting
MIPS: Choosing the Right Quality Measures for Your Practice