MACRA Reporting Requirements for Small & Mid‑Size Practices

MACRA directly affects how much Medicare pays small and mid-size medical practices. Under MACRA, the Centers for Medicare & Medicaid Services (CMS) adjusts Medicare Part B payments based on how health practices report quality, cost control, and care improvement through MIPS. Even small reporting mistakes can lead to payment cuts, while accurate reporting can earn bonuses. For practices already managing tight budgets and limited staff, understanding MACRA reporting requirements is essential to protecting revenue, staying compliant, and keeping the focus on patient care instead of paperwork.

MACRA and Its Impact on Small & Mid‑Size Practices

Understanding MACRA is especially important for small and midsize practices, as even minor reporting errors can affect Medicare reimbursements. By staying informed and compliant, practices can maximize incentives while avoiding penalties.

What Is MACRA and Why Does It Matter?

The Medicare Access and CHIP Reauthorization Act (MACRA) was enacted in 2015 to modernize how Medicare pays clinicians. It replaced the problematic Sustainable Growth Rate (SGR) with a new system that incentivizes quality and value over volume.

Under MACRA, Medicare created the Quality Payment Program (QPP). QPP gives clinicians two participation paths:

1. Advanced Alternative Payment Models (APMs): where clinicians take on more risk and can earn incentive payments.
2. Merit‑based Incentive Payment System (MIPS): the default reporting track for most clinicians and practices. 

Small and mid‑size practices that do not participate in an eligible APM typically fall under MIPS and must meet specific reporting requirements to avoid financial penalties and to qualify for bonus payments.

Who Must Comply With MACRA Reporting Requirements?

Before you begin reporting, you must first know whether your practice is eligible for MIPS. MACRA reporting requirements do not apply to every clinician.

Here’s what CMS says:

✔ Providers who bill Medicare Part B for professional services are generally MIPS eligible.
✘ However, exemptions apply if you:

• Are newly enrolled in Medicare during the performance year
• Have a low Medicare volume (below a specified threshold)
• Participate significantly in an Advanced APM and qualify for the APM incentive payment 

Low‑Volume Threshold Example:

• Total Medicare Part B allowed charges ≤ $30,000 OR
• ≤ 100 Medicare Part B beneficiaries (group basis)

CMS updates these thresholds annually, so always check the current year thresholds on the official QPP website.

MACRA Reporting Requirements (MIPS)

MACRA reporting requirements are centered around four performance categories within MIPS:

1. Quality
2. Cost (Resource Use)
3. Improvement Activities
4. Advancing Care Information / Promoting Interoperability

Each category has rules about what you must report and how you report it. The goal is to produce a composite score that determines whether your Medicare payments will increase, remain the same, or decrease.

Here’s a clear, side‑by‑side look:

Table: MACRA Reporting Requirements by Category

Performance Category	Primary Objective	Reporting Requirement	Small Practice Notes
Quality	Measures how well your care meets recommended clinical standards	Report at least 6 quality measures, including at least one outcome or high‑priority measure; submit for 70% of eligible patients	Small practices can receive bonus points and often get simplified reporting options to offset resource limits
Cost	Evaluates overall Medicare spending on your patients	No direct reporting; CMS calculates cost based on claims data	Practices shouldn’t worry about submitting cost data, but they should track efficient resource use internally
Improvement Activities	Encourages practice enhancements and patient engagement	Attest completion of either 1 high‑weighted or 2 medium‑weighted activities (small practice allowance)	Small and rural practices get weighting boosts and flexible options
Advancing Care Information (Promoting Interoperability)	Supports EHR use and secure health data exchange	Must report specified measures for a minimum 90‑day period	Small practices may have additional exclusions or simplified routes

 

Quality Reporting: The Core of MACRA Requirements

The Quality category is usually the most substantial portion of your MIPS score. For most years, it carries a significant weight (e.g., 30–45% or more of the total score), depending on the annual program rules. 

Key Points for Quality Measures

• Minimum requirement: Report at least 6 quality measures for the performance year.
• At least one outcome measure is required. If an outcome measure doesn’t apply, report another high‑priority measure (e.g., patient safety, efficiency).
• Data completeness: Your reported data must cover 70% of applicable patients for the measure to count. 

Small and Mid‑Size Practice Considerations:

• Small practices often qualify for a 6‑point bonus in quality when they submit at least one quality measure.
• CMS may offer simplified reporting options or scoring advantages for small groups to reduce administrative burden.

Cost Category: CMS Calculates for You

The Cost category under MIPS is different from the other MACRA reporting requirements because it does not require direct data submission from your practice. Instead, the Centers for Medicare & Medicaid Services (CMS) calculates cost performance automatically using Medicare claims data. This approach reduces reporting burden, especially for small and mid-size practices.

What this means for your practice:

• You do not submit any cost measures or separate reports.
• CMS evaluates the total cost of care for your Medicare patient population, including services, procedures, and hospital use.
• Your performance is benchmarked against national standards and best practices.

The Cost category focuses on whether care is delivered efficiently while maintaining quality. Practices that coordinate care well, avoid unnecessary tests, and reduce preventable hospitalizations tend to perform better in this category.

For small and midsize practices, this category highlights the importance of resource stewardship over documentation. Simple actions, such as timely follow-ups, improved care coordination, and appropriate referrals, can help control costs without adding administrative work.

Although there is no direct reporting, practices should still monitor internal spending patterns and review CMS feedback reports. These reports can reveal trends, identify opportunities for improvement, and support better decision-making in future performance years.

Improvement Activities: Boosting Patient Outcomes

The Improvement Activities category recognizes actions that improve clinical practice. Examples include care coordination, patient engagement strategies, and patient safety initiatives.

Reporting Criteria

• High‑weighted vs. medium‑weighted: Activities are classified as either high or medium.
• Small practices usually need either:
  • 1 high‑weighted activity OR
  • 2 medium‑weighted activities

These activities are attested, meaning you confirm completion rather than submit clinical data.

Examples of Improvement Activities:

• Use of telehealth to engage patients
• Implementation of patient safety protocols
• Enhanced care coordination for chronic disease patients

Advancing Care Information (Promoting Interoperability)

Advancing Care Information measures how well your practice uses certified electronic health records (CEHRT) to exchange clinical data securely. It evolved from the earlier “Meaningful Use” program. 

Key Points for Small & Mid‑Size Practices

• You must report on the required measures for a minimum of 90 days during the performance year.
• These may include:
  • e‑prescribing
  • Patient access
  • Health Information Exchange
  • Security risk analysis

Certified EHR technology (CEHRT) is necessary to report in this category.

Reporting Mechanisms: How to Submit Your Data

Submitting MIPS data correctly is critical to meeting MACRA reporting requirements. Practices have several reporting options, and choosing the proper mechanism depends on staff availability, technology, and reporting goals.

1. Claims-Based Reporting

Quality measures are attached directly to your Medicare Part B claims using specific codes.

• Pros:
  • Does not require an EHR or registry system.
  • Simple for small practices with few patients.
• Cons:
  • Limited to the quality measures supported by claims.
  • May not capture the full range of Improvement Activities or Promoting Interoperability data.

Use claims-based reporting if your practice is primarily paper-based or has limited EHR functionality.

2. Registry Reporting

Submit data through a Qualified Clinical Data Registry (QCDR) or a Qualified Registry approved by CMS.

 

• Pros:
  • Can report a wider variety of quality and improvement measures.
  • Often includes technical support and validation features to reduce errors.
  • Some registries automatically submit data to CMS.
• Cons:
  • May require a subscription fee.
  • Learning curve for staff unfamiliar with registry systems.

Choose a registry that aligns with your specialty for easier measure selection and reporting.

3. CMS Web Interface

Larger practices (25+ clinicians) can submit group-level MIPS data directly through the CMS Web Interface portal.

• Pros:
  • Ideal for multi-clinician practices.
  • Offers a structured format with built-in validation tools.
• Cons:
  • Not available to practices with fewer than 25 clinicians.
  • Data entry can be time-consuming for larger organizations.

If your practice qualifies, assign a dedicated staff member to manage CMS Web Interface submissions for accuracy.

4. CEHRT (Certified EHR Technology) Reporting

Data is automatically submitted from your certified electronic health record (EHR) system. Measures include quality, improvement activities, and promoting interoperability.

• Pros:
  • Streamlined, automated reporting reduces manual errors.
  • Can capture a broad set of measures across multiple categories.
• Cons:
  • Requires a CEHRT-compliant EHR, which may be costly or require staff training.
  • Technical issues can delay submission if the EHR isn’t correctly configured.

Ensure your EHR is up to date and certified for the reporting year, and run a test submission early to catch errors.

How To Choose the Right Reporting Mechanism?

For small and mid-size practices, the best reporting option often depends on:

• Staff availability: Smaller teams may prefer automated CEHRT reporting or registry support to reduce workload.
• Technology resources: Practices with a fully certified EHR can leverage CEHRT reporting. Those without may rely on claims or registry submissions.
• Measure flexibility: If you want to report specialized or high-priority measures not supported by claims, a registry or CEHRT option is better.

Some practices use a hybrid approach, for example, claims-based reporting for basic quality measures and a registry for more complex improvement activities. This can maximize your MIPS score while minimizing administrative burden.

Common Challenges and Practical Solutions

Meeting MACRA reporting requirements isn’t always easy, especially for smaller practices with limited staff and resources. Here are some typical hurdles and solutions:

Challenge 1: Choosing the Right Measures

The Issue: Selecting measures that accurately reflect your practice and patient population can be overwhelming. Reporting the wrong measures may lower your MIPS score.

Solution:

• Start with measures that align closely with your specialty and the patient population you serve.
• Use the CMS QPP Resource Library to filter and identify measures that are relevant, achievable, and high-priority.
• Focus on measures you can track consistently throughout the performance year to avoid incomplete data.

Challenge 2: EHR Data Gaps

The Issue: Incomplete or inaccurate electronic health record (EHR) data can cause errors in your submissions, especially in the Advancing Care Information / Promoting Interoperability category.

Solution:

• Work closely with your EHR vendor to ensure your system is fully CEHRT-compliant and configured adequately for MIPS reporting.
• If your EHR cannot capture all required measures, consider registry reporting as an alternative to fill gaps.
• Schedule regular data audits to catch errors before submission deadlines.

Challenge 3: Limited Resources in Small Practices

The Issue: Small practices may struggle with reporting due to limited staff, time, and administrative capacity.

Solution:

• Take advantage of small-practice bonuses, which provide extra points and simplified reporting options.
• Consider joining a virtual group or collaborative network to combine patient volumes, making it easier to meet reporting thresholds.
• Prioritize automation and workflow improvements to reduce manual reporting tasks.

Many small and mid-size practices benefit from a step-by-step reporting plan: choose measures first, map them to your EHR or registry, track progress throughout the year, and conduct a final review before submission. This structured approach reduces errors and stress.

Stop Stressing Over MACRA and MIPS Reporting – Get Professional Support!

MACRA and MIPS reporting can feel like a full-time job, especially for smaller practices. You don’t have to manage it alone. Kansas Medical Billing helps practices stay compliant, reduce reporting stress, and protect Medicare revenue. From MIPS guidance to full billing support, our team knows what works. 

Contact us today and get expert help.

Frequently Asked Questions

1. What counts as a performance year for MACRA reporting?

A performance year is the calendar year when you collect data for MIPS reporting. The data you submit in one year influences Medicare payment adjustments two years later (e.g., reporting for 2024 affects 2026 payments).

2. Can small practices report as a group?

Yes. Small practices can report collectively, which may reduce the administrative burden and help meet measure thresholds by pooling patient volumes.

3. Is there a way to avoid MIPS penalties entirely?

Yes: if your practice falls below the low‑volume threshold or if you qualify as an Advanced APM participant. Otherwise, strategic reporting is key to avoiding penalties. 

4. How does CMS define a high‑priority measure?

High‑priority measures include patient safety, care coordination, efficiency, patient experience, and appropriate use measures, used when an outcome measure isn’t available.

5. What are the benefits of accurate MACRA reporting?

Accurate reporting can earn positive payment adjustments, improve care quality, build stronger patient outcomes, and position your practice as a leader in value‑based care.