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


6. My practice has two locations. One location uses an EHR and the other location uses paper charts. How do I gather the required data for each MIPS category if I am reporting as an individual?

  1. First, you will need to determine whether each practice location bills under the same or two different tax identification numbers (TINs).
    If each location bills under a different TIN, the data you report for MIPS will be respective to each practice location. This is because each NPI/TIN combination is subject to MIPS participation unless one or both NPI/TIN combinations are exempt (e.g., due to the low-volume threshold). You may use the QPP lookup tool to determine whether any TIN you are associated with is exempt from MIPS due to the low-volume threshold.

    Continuing in 2023, CMS is permitting physicians to report measures and improvement activities using multiple reporting mechanisms and collection types. This provides some flexibility in reporting and submitting your MIPS data to CMS based on what is convenient at the different locations, particularly if both are under the same TIN. For more information on reporting options, please see PAI’s MIPS Reporting Mechanisms.

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