Leave a Message

Merit-based Incentive Payment System (MIPS) FAQs

The Medicare Access and CHIP Reauthorization Act (MACRA) permanently repealed the flawed sustainable growth rate (SGR) and set up the two-track Quality Payment Program (QPP) that emphasizes value-based payment models. This is your guide to the Merit-based Incentive Payment System (MIPS) track.

MIPS adjusts Medicare Part B payments based on performance in four performance categories: quality, cost, promoting interoperability, and improvement activities.

The other QPP participation option is the Advanced Alternative Payment Model (AAPM) track.  

Common questions and answers about MIPS

The Merit-based Incentive Payment System (MIPS) consolidates previous quality reporting programs. The system also added a new performance category, called improvement activities (IA). Scores from the four categories are combined to establish a final score (0-100) that will be compared against a threshold. The final score is then used to determine physician payment adjustments. The categories that make up the MIPS final score are:

  • Quality—based on PQRS;
  • Cost—based on VBPM;
  • Promoting Interoperability (PI)—based on MU; and
  • Improvement activities—new performance category.

Physicians can participate as either individuals or groups. When reporting as a group, all ECs reporting within the tax identification number (TIN) must be included in the group’s reporting. The MIPS final score will be applied to each national provider identifier (NPI) within the TIN.

Eligible clinicians excluded from MIPS include:

  • Eligible clinicians who provide care to less than or equal to 200 Medicare Part B patients OR have less than or equal to $90,000 in Medicare Part B allowed charges OR provide less than or equal to 200 Medicare Part B covered services.
  • Eligible clinicians in their first year of participation in Medicare.
  • Qualifying and partial qualifying Advanced Alternative Payment Model (AAPM) participants (QPs). Partial QPs may elect to report to MIPS.

ECs who meet or exceed one or two, but not all, of the low-volume threshold criteria can opt-in to participate in MIPS. ECs who opt in will be eligible for positive and negative payment adjustments. Opt-in elections must be made through the QPP Portal and are final (i.e., they cannot be rescinded). Additional information on opting in is available in the 2022 MIPS Opt-in and Voluntary Reporting Election Guide.

Physicians can check their eligibility status by entering their NPI into the QPP Participation Status Tool. Medicare uses claims data from two segments (referred to as determination periods) to determine eligibility. They update their Tool after analyzing claims for each determination period. Medicare makes determinations at both the individual and group level. A physician or group must exceed the low volume threshold in both segments to be considered eligible for MIPS. 

Additional information about how CMS determines eligibility and how to understand your status is available on the QPP Webpage and the 2023 MIPS Eligibility and Quick Start Guide.

Scores for each performance category will be weighted and rolled up into the MIPS final score. MIPS final scores will be published by the Centers for Medicare & Medicaid (CMS) on the Physician Compare website(www.medicare.gov)

PERFORMANCE CATEGORY

CATEGORY WEIGHT

Quality 30%
Cost 30%

Promoting Interoperability

25%
Improvement Activities 15%

All MIPS-eligible clinicians (ECs), regardless of specialty, will be compared to each other and against a performance threshold.

ECs in a large multispecialty group can report either as individuals or as a group. When reporting as a group, all ECs reporting under the group’s tax identification number (TIN) will be included. A group cannot have some ECs report as a group and others report as individuals. Under the group reporting option, all ECs must report on the same measures. If you choose to report as a group, you must report as a group across all four MIPS performance categories.

Beginning in 2026, multispecialty groups will be required to form subgroups to report MIPS Value Pathways (see below). 

Physicians who have opted out of Medicare and do not accept payments from Medicare will not be affected by payment adjustments in MIPS.

Yes. While most employed physicians will report as part of a group, MIPS payment adjustments are applied at the national provider identifier (NPI) level. If an employed physician changes practices between the performance period and the payment year, the physician’s MIPS score and accompanying payment adjustment will apply to payment at the new practice. When making hiring decisions, potential employers may take your MIPS final score into consideration.

Additionally, employers may begin basing your compensation on your MIPS final score. Employed physicians will want to make sure they are appropriately compensated for a high MIPS score.

Find additional information about employment contracting on the AAFP’s Physician Employment Contracting webpage.

Reporting methods for individuals include: claims, qualified clinical data registry (QCDR), qualified registry, and electronic health records (EHR). The promoting interoperability and improvement activities categories will include attestation options through the CMS Portal(qpp.cms.gov). There is no data submission for the cost performance category, as CMS will calculate this for ECs based on Medicare claims data.

Reporting methods for groups include: claims (15 or fewer ECs only), QCDR, qualified registry, EHR, and CMS-approved survey vendor for the Consumer Assessment of Health Providers and Surveys (CAHPS) for MIPS. Groups will also be able to attest for the promoting interoperability and improvement activities performance categories. 

Eligible clinicians can find approved qualified registry and QCDR vendors in the QPP resource library(www.cms.gov). ECs can find out if their EHR is certified by searching the Certified Health IT Product List (CHPL)(chpl.healthit.gov).

Solo and group practices (10 or fewer NPIs) can join together to participate in MIPS as a virtual group. A virtual group must consist of at least two TINs. Virtual groups are designed to help small practices successfully participate in MIPS.

Traditional MIPS and MIPS Value Pathways (MVPs)

Beginning with the 2023 performance year, individuals and groups can select their measures and activities through traditional MIPS or by electing to report an MVP. MVPs offer subset of related measures and improvement activities that are centered around a specialty, condition, or public health priority. CMS hopes MVPs will prepare more practices to transition out of fee-for-service and into alternative payment models. The MVPs for the 2023 performance period are:

  • Adopting Best Practices and Promoting Patient Safety within Emergency Medicine
  • Advancing Cancer Care
  • Advancing Care for Heart Disease
  • Advancing Rheumatology Patient Care
  • Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes
  • Improving Care for Lower Extremity Joint Repair
  • Optimal Care for Kidney Health
  • Optimal Care for Patients with Episodic Neurological Conditions
  • Optimizing Chronic Disease Management
  • Patient Safety and Support of Positive Experiences with Anesthesia
  • Promoting Wellness
  • Supportive Care for Neurodegenerative Conditions

CMS will continue to develop more MVPs. While MVPs are centered around a specialty or condition, there are no restrictions related to which specialties can report certain MVPs. Any MVP can be reported by any specialty.

When reporting an MVP, ECs choose from the predetermined list of measures and activities. In traditional MIPS, ECs select measures and activities from the broader CMS measure and activity inventories.

MVPs include the same four categories as traditional MIPS: quality, cost, improvement activities, and promoting interoperability. However, MVPs have fewer reporting requirements, which are outlined below.

Find additional information about MVPs on the CMS Quality Payment Program website.

Quality  (30%)

  • Physicians reporting via traditional MIPS must select six measures, one of which must be an outcome measure.
  • Physicians reporting via an MVP select four measures from the MVP, one of which must be an outcome measure.
  • The reporting period is an entire calendar year.
  • The Centers for Medicare & Medicaid Services (CMS) will use claims data to calculate additional administrative claims measures for groups with 16 or more ECs:
    • Hospital-wide, 30-Day, All-Cause Unplanned Readmissions (HWR) Rate for MIPS Groups
    • Risk standardized, All-Cause Unplanned Admissions for Multiple Chronic Conditions (MCCs) for MIPS (calculated for groups who meet the case minimum of 18 patients with MCCs)
  • Physicians must report on 70% of patients that qualify for each measure selected, regardless of payer. If you are reporting via claims or the CMS Web Interface, only Medicare Part B patients are included. The data completeness threshold will increase to 75% in the 2024 performance year.
  • Each measure is worth up to 10 points. Scores are based on performance compared to a benchmark.
    • Measures that can be reliably scored and have a benchmark will receive 1-10 points.
    • Measures without a benchmark, that don’t meet the case minimum or data completeness criteria will receive 0 points.
    • Small practices will receive 3 points for all measures, including those that don’t have a benchmark or don’t meet the case minimum or data completeness criteria.
  • Small practices that submit at least one quality measure will receive 6 bonus points.

Review quality measures on the CMS Quality Payment Program website.

Cost (30%)

  • No data submission is required.
  • CMS calculates cost measures using claims data. An EC must meet or exceed the case minimum for a measure to be scored.
  • Measures in traditional MIPS include Medicare Spending per Beneficiary (MSPB) per clinician, Total per Capita Cost, and  episode-based measures.
  • Cost measures in MVPs vary depending on the focus of the MVP.
  • An EC’s performance is compared against a benchmark and assigned 1 to 10 points. The cost category score is the aggregate of all scored cost measures.
  • CMS is developing additional episode-based cost measures for use in future program years.

Review cost measures on the CMS Quality Payment program website.

Promoting Interoperability (PI) (25%)

  • ECs must report on a set of required measures and are scored based on performance.
  • Reporting requirements are the same for traditional MIPS and MVPs.
  • Failure to report any of the required measures will result in a score of zero for the entire performance category.
  • ECs must use 2015 Edition certified electronic health record technology (CEHRT) for the 90 days they selected to report the promoting interoperability performance category. Look up your EHR’s certification information on the Certified Health IT Product List.
  • Conduct and attest to an annual security risk analysis. A security risk assessment is also a requirement of the Health Insurance Portability and Accountability Act (HIPAA) and should be performed by all covered entities annually, regardless of MIPS participation. Access security risk assessment tools on HealthIT.gov.
  • Complete and attest to an annual self-assessment using the High Priority Practices Guide (a part of the Safety Assurance Factors for EHR Resilience [SAFER] Guides) within the calendar year. Additional information is available on the SAFER webpage.
  • Attest “yes” to The Actions to Limit or Restrict Compatibility of Interoperability of CEHRT Attestation and the Office of the National Coordinator for Health Information Technology Direct Review Attestation.
  • ECs can apply for a hardship exception. If granted, the PI category weight will be reassigned to the quality category.
  • PI category is automatically reweighted for small practices (15 or fewer ECs)

Review promoting interoperability measures on the CMS Quality Payment Program website.

Improvement Activities (15%)

  • Physicians in traditional MIPS will report two high-weighted activities (20 points each) or four medium-weighted activities (10 points each), or a combination of both to achieve a total of 40 points.
  • Physicians reporting an MVP will report a combination of activities from the MVP for a total of 40 points. Activities are double weighted in MVPs.
  • Eligible clinicians in small practices (15 or fewer clinicians), rural practices, or health professional shortage areas (HPSA) can report one high-weighted activity or two medium-weighted activities (measures are double weighted).
  • Practices can attest to being a certified or recognized patient-centered medical homes (PCMH) and receive full credit.
  • Activities must be completed for at least 90 consecutive days. At least 50% of ECs within a group must perform the same activity during any continuous 90-day period in the same performance year.

Review improvement activities on the CMS Quality Payment Program website.

Clinicians without an EHR can still participate in MIPS but will not be eligible for any of the points under the PI performance category. Use of EHR technology that is not certified will result in a zero for the category.

While still possible to participate in MIPS without an EHR, the reporting requirements will be more burdensome without the use of an EHR. The reporting mechanisms available to a practice without an EHR would be claims or qualified registry. However, use of the qualified registry option would require a manual data collection process.  

MVPs are a reporting option that are meant to reduce the burden of MIPS reporting and prepare practices for participation in an alternative payment model (APM). MVPs are groups of measures and activities centered around a specific condition or specialty.

Individual ECs and groups can report using an MVP. Additionally, practices may form subgroups. A subgroup allows a larger practice to report multiple MVPs, depending on which MVP is relevant to the physicians in the subgroup. For example, a multispecialty group that includes cardiology and primary care may choose to form two subgroups - a subgroup with ECs that provide cardiology care and a subgroup with ECs that provide primary care. Subgroup reporting is currently optional. However, beginning with the 2026 performance year, multispecialty groups will be required to form subgroups to report MVPs.

Learn more about MPVs in FPM Journal.

MIPS are eligible for positive or negative Medicare Part B payment adjustments of up to 9%. Distribution of payment adjustments will be made on a sliding scale and will be budget neutral. Payment adjustments will be based on the following:

  • Physicians with a final score at the threshold will receive a neutral payment adjustment.
  • Physicians with a final score above the threshold will receive a positive payment adjustment on each Medicare Part B claim in the payment year.
  • Physicians with a final score below the threshold will receive a negative payment adjustment on each Medicare Part B claim in the payment year.
  • Physicians with a final score in the lowest quartile will automatically be adjusted to the maximum negative adjustment on each Medicare Part B claim in the payment year.

Performance in each category is weighted and used to calculate a final score (0-100). Each eligible clinician’s (EC’s) or group’s final score is compared to a performance threshold to determine payment adjustments.

ECs can receive up to 10 bonus points added to their final score through the Complex Patient Bonus. The Complex Patient Bonus is based on the medical complexity (average HCC score of EC’s Medicare patient population) and social risk (proportion of EC’s Medicare patient population that is dually eligible for Medicare and Medicaid) of an EC’s patients. The complex patient bonus is limited to ECs with at least one risk indicator (HCC score or dual-eligible ratio) at or above the median indicator calculated for all ECs. 

The performance threshold for the 2023 performance period is 75 points.

Payment adjustments are budget neutral and made on a sliding scale. To maintain budget neutrality, physicians with higher final scores may be eligible for a positive payment adjustment up to three times the baseline positive payment adjustment for a given year.

Payment adjustments are based on the final score from two years prior (e.g., performance in 2023 determines payment adjustments in 2025). Like the category weights, the payment adjustment increased in the first few years of the program.

Starting with the 2020 performance year, the payment adjustment is set at ±9%

  • Final scores above the threshold (75.01-100) will receive a positive payment adjustment.
  • Final scores below the threshold (18.76-74.99) will receive a negative payment adjustment.
  • ECs in the lowest quartile (0-18.75) will receive the maximum negative payment adjustment for a performance period.
  • Final scores equal to the threshold (75) will receive a neutral payment adjustment.

The Centers for Medicare & Medicaid Services will apply the MIPS payment adjustment at the TIN/NPI level. ECs who reported as a group will all receive the same final score, but the payment adjustment will be applied at the TIN/NPI level. Payment adjustments are made at the Medicare Part B claim level.

If an EC bills under more than one TIN during the performance period, CMS will use the highest final score associated with the clinician’s NPI during the performance period to adjust payment in the payment year.

If a clinician changes TINs between the performance period and payment year, CMS will apply the final score associated with the clinician’s NPI during the performance period to the new TIN/NPI combination. For example, if a clinician practiced at TIN A during the performance period, but is practicing at TIN B during the payment year, CMS will use the final score from TIN A to apply to the payment adjustment to the new TIN B.

Physicians can submit a request for a targeted review if they believe the information submitted to CMS has calculation errors, data quality issues, or if they clinician believes CMS has made errors in assigning score to MIPS-eligible clinicians (e.g., MIPS-eligible clinicians should have been subjected to the low-volume threshold).

Yes. Exclusions from MIPS include:

  • Clinicians in their first year of billing Medicare;
  • Clinicians with their volume of Medicare payments or patients falling below the low-volume threshold (200 Medicare Part B patients OR $90,000 or less in Medicare Part B charges) OR 200 Medicare Part B services); and
  • Clinicians who are qualifying participants (QP) in an AAPM.

Clinicians can check their MIPS-eligibility and QP status using the QPP Participation Status Tool(qpp.cms.gov).  

Clinicians that meet or exceed one or two, but not all, of the low-volume threshold criteria can opt-in to participate in MIPS. Clinicians who opt-in are eligible for positive and negative payment adjustments. Opt-in elections must be made through the QPP Portal and are in effect for the applicable performance year (i.e., they cannot be rescinded).

Resident physicians in their second year of Medicare billing and who are billing under their own NPI would be subject to MIPS adjustments. Resident physicians in their first year of billing would be considered new to Medicare and excluded from MIPS.

Payments for items and services made under a Federally Qualified Health Center (FQHC) or Rural Health Clinic (RHC) all-inclusive payment are exempt from MIPS. However, any Medicare Part B items and services provided and billed outside of the all-inclusive payment at FQHCs and RHCs will be subject to MIPS payment adjustments. FQHCs and RHCs are still subject to the low-volume threshold.

CMS calculates the low-volume threshold at both the group and individual level, but it is up to the clinician whether they participate at the individual or group level. For example, an EC may not be eligible at the individual level, but their group may be eligible. In that instance, if all ECs in the practice participate as individuals, the EC would not be required to report. However, if the practice decides to report as a group, the EC would be included and would receive a final score and payment adjustment based on the group’s performance.

Additional information on MIPS eligibility is available on the Quality Payment Program website.

The Centers for Medicare & Medicaid Services calculates an EC’s low-volume threshold status using two claims from two determination periods. CMS will not change the low-volume status of ECs who fall below the low-volume threshold during the first review period, but not the second. ECs can check their MIPS-eligibility status using the QPP Participation Status tool (qpp.cms.gov).

The Centers for Medicare & Medicaid Services defines a small practice as 15 or fewer ECs (small practice size for virtual groups is 10 or fewer ECs). This may include NPIs excluded from MIPS. CMS determines small practice status by analyzing claims, using the same dates as those used for determining low-volume threshold status. Small practice determinations will be available through the QPP Participation Status tool (qpp.cms.gov).

There are two hardship exceptions available to ECs. This includes a significant hardship exception for the promoting interoperability category and an extreme and uncontrollable circumstances (e.g., natural disaster) exception for the quality, cost, and improvement activities categories.

A MIPS APM includes APMs that did not qualify as AAPMs. MIPS APMs do not qualify as AAPMs because they either do not meet the nominal risk criteria or the AAPM participants do not meet the payment or patient thresholds. MIPS APM participants may report the APM Performance Pathway. MIPS APMs for the 2023 performance period include:

  • ACO Realizing Equity Access and Community Health (REACH)
  • Maryland Total Cost of Care Program – Care Redesign Program
  • Maryland Total Cost of Care Model - Primary Care Program Tracks 1, 2, and 3
  • Medicare Shared Savings Program (MSSP) All Tracks
  • Primary Care First
  • Vermont Medicare ACO Initiative (as part of the Vermont All-Payer ACO Model)
  • Additional models will be announced by CMS as they are approved

AAFP members can contact an AAFP subject matter expert or call (800) 274-2237.

Technical Assistance Programs for the Quality Payment Program (QPP)

The Centers for Medicare & Medicaid Services (CMS) offers several technical assistance programs to help you successfully participate in the Merit-based Incentive Payment System (MIPS). Use this guide to help understand which program fits your needs.

The QPP Help and Support offers free videos, webinars, and online, self-paced courses to help you better understand the QPP.

Quality Payment Program Service Center

The Centers for Medicare & Medicaid Services (CMS) encourages all eligible clinicians (ECs) to access the QPP Service Center at (866) 288-8292 or QPP@cms.hhs.gov. Practices can sign up for the QPP Listserv and monthly QPP Small Practices Newsletter on the CMS Quality Payment Program website.

Quality Innovation Network - Quality Improvement Organizations (QIN-QIOs)

Quality Innovation Network-Quality Improvement Organizations (QIN-QIOs) are designed to bring together Medicare beneficiaries, physicians, and communities in data-driven initiatives that improve patient safety, make communities healthier, provide better coordinated post-hospital care, and enhance clinical quality. QIN-QIOs offer technical assistance, as well as tailored education, best practices, and tools and resources. QIN-QIOs help provide skills for transforming practices, including employing lean methodologies, assisting Medicare physicians with the transition to the QPP, and developing innovative approaches to quality improvement.

Learn more about QIN-QIOs.

Alternative Payment Model Learning Systems

The goal of the Alternative Payment Model Learning System is to facilitate the sharing of information and promising practices. The learning system provides APM participants with specialized information needed to increase success in the Advanced APM track. For APMs that are not AAPMs, it helps practices to understand the special benefits of MIPS APMs. APM participants are provided information to access technical assistance by their APM.

Learn more about APM Learning Systems.

Related CME