2019 MIPS Data Submission Process


2019 MIPS Submission Timeline Update

In light of the COVID-19 pandemic, Medicare has extended the submission timeline to April 30th, 2020. As a result of the impact that COVID-19 has had on the ability to conduct business as usual, Keet has also made the decision to extend our timeline for the 2019 MIPS Submission Process.


Below is an overview of the process we will use to confirm your intent to submit your 2019 MIPS data to the Centers for Medicare and Medicaid Services (CMS). 



1. Verify the individual(s) authorized to validate your organization's 2019 MIPS submission

To get started, identify the person(s) who are responsible to make the final decisions regarding your organization's MIPS submissions here. Please note, the person(s) identified will be our point of contact for the remainder of the process.

  • Submission deadline: Friday, October 18, 2019 *or ASAP if it has not yet happened


2. Designate if you will be reporting as individual providers, as a group, or both

The next step in this process is to identify if your organization will be reporting as individual providers, as a group, or both.

On Monday, October 21, 2019, Keet will provide the authorized individual(s) in your organization with a list of providers who have been utilizing Keet Outcomes. This list will be delivered by email in a Docusign form. An authorized individual will need to validate if your organization will be reporting as a group and if not, identify which individual providers data should be reported on. For more information on reporting as an individual or group, please visit the QPP website and read our summary below. 

  • Submission deadline: Friday, November 26, 2019


3. Review and edit your organization's 2019 MIPS data 

At the beginning of March 2020 you will be provided a draft report, which you should review and return with any revisions by mid-month. 



4. Review and approve your organization's 2019 MIPS data for reporting submissions 

By April 15, Keet will generate and provide final MIPS reports to your organization. An authorized individual is to approve the submission of your organization's final 2019 MIPS report no later than April 17. Keet will finalize all data integrity and compliance audits per Medicare regulations, submitting your 2019 MIPS data to CMS on your behalf no later than April 30.


These details are taken directly from the QPP website. Note that it is your responsibility to understand the potential impact of each option and make a decision based on the unique circumstances for your clinic. 

Report as an Individual  
An individual is defined as a single clinician, identified by their individual National Provider Identifier (NPI) tied to a single Taxpayer Identification Number (TIN).

If you report only as an individual, you'll report measures and activities for the practice(s)/TIN(s) under which you are MIPS-eligible and be assessed across all 4 performance categories at the individual level. Your payment adjustment will be based on your Final Score derived from the 4 MIPS performance categories.

Report as a Group
A group is defined as a single TIN with 2 or more clinicians (at least one clinician within the group must be MIPS eligible) as identified by their NPI, who have reassigned their Medicare billing rights to a single TIN.

If you report only as a group, you must meet the definition of a group at all times during the performance period and aggregate the group’s performance data across the 4 MIPS performance categories for a single TIN. Each MIPS-eligible clinician in the group will receive the same payment adjustment based on the group's performance across all 4 MIPS performance categories.

Report as Both an Individual and Group  
** Keet expects the majority of our clients to choose this option**
MIPS-eligible clinicians can report data as an individual and as part of a group under the same TIN. In this instance, the clinician will be evaluated across all 4 MIPS performance categories on their individual performance and on the group’s performance, with a final score calculated for each evaluation. The clinician will receive a payment adjustment based on the higher of the two scores.


Medicare requires us to perform random audits on the MIPS data being collected to ensure data integrity. If your clinic is chosen, we will review data extracted from Keet Outcomes to identify discrepancies between the MIPS reports and the data being prepared for submissions. If we find any discrepancies, we are required by Medicare to perform an expanded audit that would result in the detailed review of clinical source data to document corroborating evidence of the accuracy of the data to be transmitted to CMS.

If you have any questions, please don't hesitate to reach out to support@keethealth.com.