UninTINded Consequences: How Your Tax Identification Number (TIN) May Impact The Bottom Line.

June 9, 2016 · Amy Maciejowski

As a recognized Patient-Centered Medical Home (PCMH), you may know that you will benefit under the new Medicare Access and CHIP Reauthorization Act (MACRA). This bipartisan legislation pushes health care forward by tying physician payments to the value of the care they provide, rather than the volume of patients they see. Importantly, it gives clinicians specific credit for being in NCQA PCMH or Patient-Centered Specialty Practices (PCSPs).

As you might imagine, this revolutionary legislation comes with lots of changes, adjustments and questions.

As experts in what it really means for a practice to be patient-centered, we want your assistance steering federal policymakers who’ll administer this new law down the right path.

As an NCQA-Recognized Patient-Centered Medical Home, you will receive full credit for the Clinical Practice Improvement Activities (CPIA) category. This means NCQA PCMH (and PCSP) practices receive an automatic 15% towards their fulfillment of the Merit-Based Incentive Payment System (MIPS).

Recently, the Department of Health and Human Services (HHS) outlined their proposals for how they will administer payments.

In order for PCMHs to receive payment and to allocate their credit correctly, HHS plans to use the organizations’ specific Tax Identification Number (TIN) as a way to identify them. The concern is that some PCMH sites under a specific TIN may be recognized PCMHs. Some may not. For example, there may be five practices under one TIN, but only three out of the five are recognized PCMHs.

So, how should HHS iron out this wrinkle?

We Need Your Insight.

Do you share a TIN with an unrecognized PCMH? Is this a common issue among your colleagues and contacts?

As an NCQA Recognized PCMH, how would you address this? What do you think is the best way to assign PCMH credit?

We ask because we want to make sure HHS assigns PCMH credit in the best way possible for our practices. We look forward to your responses and plan on sharing them here and with HHS.

Please share your experience, and possible solutions, with us at PublicPolicy@ncqa.org  or in the comments section below.

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