QPP FAQ

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Eligibility Questions

If you treat more than 200 Medicare patients per year and you are billing more than $90,000 in allowable charges per year, participation is mandatory.

The Quality Payment Program (QPP) is split into two options. Under the QPP, you can choose to report for the Merritt-based Incentive Payment System (MIPS) or Alternative Payment Models (APMs). Typically only the MIPS program would apply to the Chiropractic specialty.

You can use the "Insurance Billing report" through ChiroTouch Reports for this information. However, it would be best to defer to the letter being sent by CMS or the NPI look up tool for more information.

You will not be notified of your participation. status. You are required to use the NPI lookup tool available online.

No. The inclusion and exclusion criteria accounts for the whole reporting year.

As long as you are excluded, you will not be required to report on any category, including Quality (formerly PQRS), Promoting Interoperability, and Clinical Practice Improvement.

No, you are only required to participate if you are treating 201 or more Medicare patients and billing more than $90,000 in allowable charges.

If you are under the threshold, you are not required to report in QPP. However, be sure to check back for your potential inclusion in future years.

If excluded as an individual but included as a group you can choose to participate for incentive as a group, though it would be optional due to the individual exclusion. You can participate for program experience regardless of your status. However, you will not receive incentive for participation as an individual unless you treat more than 200 Medicare patients and you are billing more than $90,000 in allowable charges. If you qualify as a group and would like to receive incentive, you must be assigned a TIN by CMS.

If you check your participation status and you note that you are eligible for Opt-In you can report for an Incentive.

Only Part B claims qualify. If not paid out by Medicare, it will not count toward your total.

If you fall out of inclusion, you will not be affected by the penalty. You can report for experience, but you will not receive incentive or penalty. You do have the option to continue reporting g-codes or Clinical Quality Measures (CQMs) using your CT system, for positive scoring in the Quality category. Scores for submission are posted to the Physicians Compare site.

This number refers to unique patients.

Yes, Physical Therapists are eligible to report to the Quality Payment Program if they meet the requirements.

Reporting Questions

This information can be found on the Quality Payment Program site.

Sign up for emails directly from CMS through their website: www.qpp.cms.gov.

ChiroTouch has a dedicated Compliance support team and all support agents can answer basic questions about QPP requirements.

You will follow the same reporting instructions that you have followed for past reporting. The only thing changing with MIPS is that the incentives/penalties will now be combined.

Our Dashboard, Quality reporting, 2015 certified version and list of Improvement Activities are available for your reporting.

No. You are already included or excluded depending on your billing and patient volume.

APM stands for Alternative Payment Model. You can only report to this program if you are currently included in an Accountable Care Organization (ACO).

Through Quality reporting using Clinical Quality Measures (CQMs) found on your ChiroTouch dashboard. These regulations could always change in the future, however.

You want to achieve the highest percentage in each category. If you achieve 100% for all measures, you will earn the maximum percentage available under the category. The Merritt-Base incentive is relative to the percentages reported.

These are currently found on the Quality Payment Program site.

Complete the task and save all proof or document procedures therein. These will be attested to by check-marking those measures completed by your clinic. Click here for more information.

There are many practice improvement measures. One example is the integration with direct messaging.

You have the option to use G-coded claims or report to Clinical Quality Measures (CQM) using your software if included in the program. You do have the option to continue reporting G-codes or CQMs using your CT system, for positive scoring in the Quality category. Scores for submission are posted to the site Physicians Compare site.

Currently you must access the G-codes through our QPP page on www.mychirotouch.com.

You will use the CQM that your software is certified for. These can be found on the CQM tab of your QPP Dashboard. You are only responsible for the measures that accumulate denominators.

Chiropractors are held to a different reporting standard than other reporters. You can continue to submit just one G-code in conjunction with Clinical Quality Measures (CQMs) you will only report to those that accumulate patients in the denominator.

You can choose to report CQMs through your software system by gathering data on patients in certain age groups and/or those with a common diagnosis or charges. You can find descriptions of these measures on www.qpp.cms.gov.

If you cannot achieve 20 cases in the Quality category, CMS will assess the applicability of each measure and score accordingly.

Yes. You must submit data Promoting Interoperability ( a minimum of 2-5 required measures), Improvement Activities (a minimum of 1-4 measures) and Quality (ChiroTouch suggests using your 182 claims measure and CQMs).

No. They are considered orders, not referrals.

Quality scores will be available on the CMS website after submission.

The Affordable Care Act is not included in the MACRA legislation.

If you are required to report to a registry you must contact the registry and verify how they require you to register and transmit information.

No. Quality measures have many submission methods, including EHR Qualified Reporting Document Architecture (QRDA III) and claims.

You will report on Practice Improvement through attestation.

No. you must report to the Quality category for the full year currently. ACI and IA can be reported for only 90 days.

No. Any consecutive 90-day period is acceptable.

You can choose to report on either a 90-day period or on the full year for ACI and IA. It is completely up to you. If you find it too difficult to complete all of the requirements within 90 days, you might decide that a year time-frame suits your office better, or you can choose a time-frame longer than 90 days. The Quality category must be reported for the full year currently.

Group-Reporting Questions

You do not need to advise Medicare that you are billing as a group. However, you should have 2 or more NPIs re-assigned to a TIN prior to attestation.

No, you are already being assessed as a group.

It is optional to report as a group. Report as a group if you want to receive the incentive as a group. However, if you are part of a billing group who chooses to report together, you are required to report under that group.

Regardless of specialty, you can report as a group if you join your NPIs together and reassign as a TIN.

In order to submit as a group, you will submit all categories as a group. You can use multiple submission types for the Quality category.

Billing as a group and reporting as a group are different. If you plan to report as a group AND you meet thresholds for inclusion, then you would be required to complete the measures. If other members in your billing group are reporting to QPP you are required to report with them, or they might lose group reporting status.

Only reporters who qualify for incentives will receive them for reporting. If you reassign your NPI as a group TIN including providers who qualify, you could report as a group and receive incentive for compliance.

Yes, you are required to review each measure to verify if it applies to you or your group.

If you fall under the inclusion threshold, you are not able to receive incentive on your own unless you enjoy Opt-In status. You do not have to report as a group if you have been excluded as an individual; this is optional.

Incentive Questions

The incentive and penalty would be based on compliance. If you happen to have a small compliance score, you could receive an adjustment below 9%.

You are required to report compliance. If you fail to report compliance, you will not receive an incentive, or you may receive a smaller incentive. Also, based on the budget neutrality legislation you are only entitled to the incentive available for the reporting year.

MIPS reporting is scored based on the actions and activities of each provider and their staff. Though the measurement of a patient’s clinical progress is part of a provider’s required activities, the results of those measurements are largely irrelevant to most MIPS categories.

Attestation Questions

After the reporting year has ended you can begin attesting (Jan 2 to Mar 31, 2025) using the QPP submission site. This process is similar to past attestations. Each category will be submitted individually and the adjustments will be combined.

After the reporting year has ended you can begin attesting (Jan 2 to Mar 31, 2025) using the QPP submission site. This process is similar to past attestations. You will enter all numerators and denominators from your dashboard for the ACI category, select the IA measures that you chose to report and upload your CQM file unless G-codes were used.

Meaningful Use is included under the MIPS plan. It now referred to as the Promoting Interoperability category. You do not need to report to more than one program, just the categories that exist under QPP.

You will attest to them by check-marking those completed by you or your group.

You can bill all Part B claims throughout the reporting year with a G-code attached. You can also choose to report CQMs to achieve higher scoring under this category.

You would attest once to the Promoting Interoperability category, Quality reporting and Improvement Activities after the reporting period ends, Dec 31, 2024. Claims reporting is submitted throughout the year and no other attestation is necessary if solely submitting claims data.

 

Promoting Interoperability Questions

No, you will be completely insulated from all penalties and ineligible for all incentives if you fall into the category of excluded providers. As an excluded provider (either 200 or fewer Medicare Part B patients a year or billing less than $90,000 to Medicare Part B per year), you can cease all MIPS activities by discontinuing reporting dashboard objectives (Promoting Interoperability), G-codes on claims or CQMs (Quality), and Improvement Activities (IA). You will not be penalized for doing so. While it is possible that the requirements for excluded providers may change in future program years choosing to report or not to report will bring no monetary adjustment if you fall under the current exclusion.

If you choose to participate or you are required to do so, select a 2024 reporting period of a full year or 90 days, depending on your preference and begin reporting on Quality immediately. This reporting should be done using your 2015 certified ChiroTouch solution (version 7).

You can no longer use the 2014 certified version. 2015 certification phase is required to be active within your system when reporting.

The new 2015 ChiroTouch dashboard for 2024 reporting can be used to receive the maximum incentive. This new dashboard includes new measures and functions attributed to Promoting Interoperability (PI) and Clinical Quality Measures (CQM).

Yes. Though most reporting requirements will remain the same from 2023 to 2024 reporting. Quality reporting should be completed through Clinical Quality Measures (CQMs) for optimum scoring.

 

Improvement Activities Questions

No. Most improvement activities cannot be completed electronically. Example: Engagement of community for health status improvement: Take steps to improve health status of communities, such as collaborating with key partners and stakeholders to implement evidenced-based practices to improve a specific chronic condition.

Yes. For your convenience, ChiroTouch has listed the top 50 (out of 118) Improvement Activities that may fit within the Chiropractic profession. Find more Improvement Activities listed here.

The weighting of each activity, from Mid to High, has been assigned by CMS. These weights are not determined by your software vendor.

You will attest by check-marking the measures you have chosen to complete. There is no numerical value (numerator or denominator) required for these measures.

You will save all supporting documentation and or activity requirements/steps and supply these if required. Example: Participation in domestic or international humanitarian volunteer work. MIPS eligible clinicians attest to domestic or international humanitarian volunteer work for a period of a continuous 60 days or greater. For this IA, you may wish to save certificates of completion, letters from the organization regarding your time and work, travel receipts and any other documentation obtained during the 60+ days.

If completing measures through your software, screenshots are acceptable.