2024 MIPS Program: Small vs Large Practice

The Centers for Medicare & Medicaid Services (CMS) designates small practices as those that have 15 or fewer clinicians; and therefore, have special allowances under the Merit-based Incentive Payment System (MIPS) in order to reduce burden on small practices. This includes varying submission methods and special scoring considerations as illustrated here.

The CMS has reweighted Quality for small practices. Quality is 50% of their overall MIPS score. For large practices, weighting is still 85% of their overall MIPS score. Individuals or groups must meet the Quality category reporting requirements:

  • Report a minimum of 6 measures
  • One must be an outcome or high priority measure
  • 12-month reporting period
  • 70% data completeness (70% of all patients, regardless of payer, that meet the measure denominator)*
  • 20 case minimum per measure

*The only exception is for measures submitted via Medicare Part B claims, which can only be submitted by small practices. For Claims measures, pathologists must submit data on 70% of all Medicare Part B patients that meet the measure denominator during the performance period.

Small Practices
(≤15 pathologists)
Large Practices
(>15 pathologists)
Submission Methods
  • Medicare Part B Claims
  • Registry Submission
  • Registry Submission ONLY
Data Completeness (Quality Category)Failure to meet:
  • 70% data completeness
Will result in 3 points for the measure
Failure to meet:
  • 70% data completeness
Will result in zero points for the measure
Measures that Don’t Meet Case MinimumMeasures that don’t meet cases minimum (20 cases) will still earn 3 points.

Measures that don’t meet cases minimum (20 cases) will earn zero points.

Note: This change will not apply to new measures in the first two performance periods available for reporting.

  • 7 point floor for new measures in their first year in MIPS (QPP 491, CAP 39)
  • 5 point floor for new measures in their second year of MIPS (CAP 38)
Measures without a benchmark (historical or performance period)

Measures without a benchmark will earn 3 points. (CAP34)

Measures without a benchmark will earn zero points. (CAP34)

Note: This change will not apply to new measures in the first two performance periods available for reporting.

  • 7-point floor for new measures in their first year in MIPS (CAP 39, QPP 491)
  • 5-point floor for new measures in their second year of MIPS
Measures with historical benchmarkCMS removed 3-point floor. These measures will receive 1-10 points or 1-7 point if topped out. (QPP 249, 250, 395, 396, 397, 440, CAP 22, CAP 28, CAP 30)CMS removed 3-point floor. These measures will receive 1-10 points or 1-7 point if topped out. (QPP 249, 250, 395, 396, 397, 440, CAP 22, CAP 28, CAP 30)
Bonus Points6 bonus points automatically added to the Quality category if data for at least 1 quality measure is submittedNone

Pathologists Quality Registry

Optimize your performance in MIPS and enroll for the 2024 reporting period.

Learn more about the registry Right Arrow

We have a dedicated team to help you succeed in MIPS. Contact us to learn how we can optimize your MIPS performance.

Email: mips@cap.org

Phone: 800-323-4040, option 3