MIPS Scoring for Facility-based Pathologists: 3 Things to Know

August 20, 2019 By: Quadax

Pathologists must optimize their MIPS participation to minimize risk stemming from new and evolving CMS payment models.

There are two pathways under the Quality Payment Program (QPP): MIPs and Advanced APMs. Unless you qualify as a participating clinician in an Advanced Alternative Performing Model, MIPS will be your default. MIPS has four weighted performance categories, identified below. This post will focus on Quality and Cost.

◻️ Quality
◻️  Improvement Activities
◻️  Promoting Interoperability
◻️  Cost

As a facility administrator, navigating the requirements to be successfully compliant with MIPS can be confusing, especially for those CMS considers non-patient facing clinicians, like pathologists. Pathologists must optimize their participation in order to minimize the risk of losing out on bonus opportunities stemming from new and evolving CMS payment models. One of those models centers on the new policies of Facility-Based Measurements. As a facility administrator, what do you need to know?

1.  Definition of facility-based

Individual Facility-based clinician

Must have 75% or more of covered professional services in any of the following:

◽  Inpatient hospital (POS 21), or
◽  On-campus outpatient hospital (POS 22), or
◽  Emergency room (POS 23), and
Have at least one service billed with POS 21 or POS 23

Facility-based group

At least 75% of MIPS-eligible clinicians billing under the group’s TIN are identified as facility-based.

Attributed to a facility with a Hospital VBP score

2.  Your facility-based status

The easiest way to determine and confirm your 2019 Facility-based status is to start with CMS by utilizing their online MIPS eligibility and look-up tool, found at (You will need your HCQIS Access Roles and Profile System (HARP) credentials, Tax Identification Number (TIN) and National Provider Number (NPI).) This tool will also inform you if you are exempt from MIPS, in which case, you will not be responsible for MIPS reporting. If you are not exempt, the tool will provide you with any special status needed for reporting other than facility-based. The tool will also indicate your attributed facility if you have facility-based status.

If you are a facility-based pathologist or group, CMS will automatically assign you Quality and Cost scores for based on the attributed facility’s Hospital Value-Based Purchasing (HVP) program. CMS will assign these scores even if you are not a patient-facing clinician.

Facility-based pathologists should attest to Interoperability Activity scores separately to maximize their MIPS score. Facility-based pathology groups must attest to these scores separately from the facility in order to be assesses as a group and to maximize their MIPA score.

3.  Your potential 2019 MIPS performance

You can preview your Quality and Cost scores on the QPP website for estimated 2019 MIPS performance period, based on 2019 Hospital VBP Total Performance Scores (TPS) mapped to 2017 performance QPP data.

The 2019 MIPs scores will use 2020 Hospital VBP scores mapped to QPP data from the 2019 performance period. Note, scores between the preview and 2019 MIPS may change. How? There could be changes in the hospital to which the clinician or group is attributed. There could be updates to the HVBP TPS between 2019 and 2020 at the attributed hospital. Or, there could be updates to the distribution of MIPS quality and cost performance scores. The College of American Pathology suggests you may want to report on MIPS separately if you are not confident in your hospital’s VBP score as CMS will take the higher score from your reporting data.

The CMS recommends that eligible professionals check with the QPP Help Desk for more information on measures and the QPP.

QPP Help Desk Contact Information:

7:00 AM–7:00 PM CT Monday - Friday


Phone: 866-288-8292

*Adapted from Facility-Based Measurement: A Practical Overview, by Emily E. Volk, MD, MBA, FCAP (Aug 2019).

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