Will Your Practice Qualify for MIPS Exemption under BPCI Advanced?


Many orthopedic physician groups in BPCI Advanced will not reach Qualified Participant (QP) status for MIPS exemption since they will not meet required Advanced APM volume or payment thresholds in 2019 and beyond.  Because of this, it is vitally important that practices are positioned correctly when it comes to how they will be measured by CMS. 

In the recent application process for BPCI Advanced, CMS gave convener applicants three options:

  1. Submit hospitals and physician groups together attached to one application and physicians will be measured individually for QP threshold results
  2. Submit all physician group practices together attached to one application and have all groups measured together for QP threshold at an aggregate level
  3. Submit each physician group practice as a separate application to ensure that the PGP is measured at the group level

Pooling physician groups together under one application makes qualifying for MIPS exemption all the more difficult and riskier because either all of the groups will qualify (highly unlikely) or none will. Although it took a tremendous amount of work, Stryker submitted a separate application for each of over 300 physician groups that applied to join our convener. Practices in the Stryker Convener will be measured at the group level for QP thresholds and not measured by being pooled with other groups at the aggregate convener level. We want our groups to be positioned as advantageously as possible to qualify for the advantages of Advanced APM participation. 

If your group has applied to participate in BPCI Advanced through more than one convener, it is critical to find out if the other convener created a separate application for your group as Stryker did (which means your group gets measured individually) or if your group is part of an application that also includes other groups (which means you get measured together and either all qualify or all fail to qualify). This is a key question that you should ask as you decide which convener is the best BPCI Advanced partner for your practice in the coming years.