Medicare QPP

Physicians Advocacy Institute

These resources have not been updated since 2023 but the general details remain relevant. For a summary of the key changes for CY 2024, please click here.

Frequently Asked Questions Updated for 2023

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2. How do I report my data as part of a Virtual Group?

  1. The reporting mechanisms that can be used to submit your MIPS data depend on the performance category. You can report different categories using different collection types and reporting mechanisms. You may submit MIPS data using multiple collection types and reporting mechanisms across all the categories and for individual measures and improvement activities as well.
    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



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