Understanding Your MIPS Eligibility Status

CMS has updated the Quality Payment Program (QPP) Participation Status Tool for the 2022 performance year. Clinicians can now check their final 2022 eligibility status for the Merit-based Incentive Payment Program (MIPS) by entering their individual National Provider Identifier (NPI) into the tool or checking their MDinteractive account dashboard. Clinicians can also check their eligibility in an Advanced Alternative Payment Model (APM) and their initial 2022 MIPS eligibility status. It's important to review the participation tool in case there have been any changes in a clinician’s MIPS eligibility.

Review Your 2022 MIPS Eligibility

The QPP Participation Status Tool now displays your final 2022 MIPS eligibility and specifies if you are eligible to report MIPS at the individual and group levels. MIPS eligibility is based on your individual NPI and associated Tax Identification Numbers (TINs). This means you could be required to report MIPS for more than one practice.

The CMS tool lists any practice(s) your NPI is associated with and if you have a special status designation, such as hospital-based, non-patient facing, or small practice. It also includes information about your ability to opt-in to MIPS.

Remember, you need to review your eligibility for each TIN/practice for which you submit Medicare claims. It is important to check both your MIPS participation status and your APM participation status.
 

How CMS Determines Your Eligibility

MIPS Eligible Clinician Types

There are several “types” of providers that are considered “MIPS eligible clinicians” in 2022 and are included in the program if they bill Medicare Part B claims:

• Physicians (including doctors of medicine, osteopathy, dental surgery, dental medicine, podiatric medicine, and optometry)
• Osteopathic practitioners
• Chiropractors
• Physician assistants
• Nurse practitioners
• Clinical nurse specialists
• Certified registered nurse anesthetists
• Physical therapists
• Occupational therapists
• Clinical psychologists
• Qualified speech-language pathologists
• Qualified audiologists
• Registered dietitians or nutrition professionals
• Clinical social workers
• Certified nurse midwives

MIPS Exclusions

You are excluded from MIPS in 2022 and are not eligible for a MIPS payment adjustment if you:

• Are not a MIPS eligible clinician type; or
• Enroll in Medicare for the first time in 2022; or
• Are a Qualifying APM Participant (QP) or Partial QP; or
• Don’t exceed the low-volume threshold criteria.

MIPS Determination Period

CMS reviews your Medicare Part B claims and PECOS data from two 12-month periods to determine the volume of care you provide to Medicare beneficiaries:

You must exceed all 3 of the low-volume threshold criteria during both parts of the MIPS determination period to be included in MIPS. Your eligibility could change during the second period for reasons such as joining or leaving a practice, so it is important to check your final status again. However, if you are not MIPS eligible for your existing practice during the first review period, you won’t become MIPS eligible for that same practice during the second review period.

Opt-In Option

The CMS tool provides information on your ability to opt-in to MIPS. Clinicians or groups would have the ability to “opt-in” to MIPS if they meet or exceed one or two, but not all, of the low-volume threshold criteria. If you “opt-in” to the MIPS program you will be subject to neutral, negative or positive payment adjustments based on your MIPS performance and final score. Once you elect to “opt-in”, the decision is irreversible for the current performance year.

Remember, if you are not required to report MIPS, you can choose to report MIPS voluntarily without choosing to “opt-in”. If you voluntarily report MIPS you will not be subject to any payment adjustments. The benefit of voluntarily reporting MIPS is you will receive performance feedback on your data.

MIPS Eligibility as an Individual and a Group

When you check your MIPS participation status, it will show your MIPS eligibility as an individual clinician and as a group.

• The participation tool will indicate if you are MIPS eligible as an individual and/or as a group if there are 2 or more clinicians in your TIN.

• If you are not MIPS eligible as an individual or as a group you may be eligible to opt-in to the program or voluntarily report MIPS.

• If you are not MIPS eligible as an individual but are MIPS eligible as a group, your data needs to be included if your TIN chooses to report as a group. 

APMs

The QPP Participation Status Tool will also indicate if you participate in an APM. An APM is a payment approach that gives added incentives to provide high quality and cost-efficient care. APMs can be designated as MIPS APMs or Advanced APMs.

• MIPS APMs participate in the APM under an agreement with CMS. Eligible clinicians in a MIPS APM will receive MIPS payment adjustments and MIPS-APM specific rewards.
• Advanced APMs must meet different requirements, including taking on some risk related to patient outcomes. Qualifying participants in an Advanced APM are exempt from MIPS payment adjustments and can qualify for a 5% lump-sum bonus.

Since January 1, 2021, MIPS APM participants can report MIPS via the APM Performance Pathway (APP). MIPS eligible clinicians participating in Advanced APMs will be required to participate in MIPS unless they earn QP or Partial QP status or are otherwise exempt.  

Note:  MIPS eligible clinicians currently participating in a MIPS APM (see MIPS APM List), please contact your APM entity for participation specifics.

APM Determination Period

CMS reviews APM participation throughout the performance year. During each review period, CMS will determine if you are a Medicare Qualifying APM Participant (QP) or Partial QP and exempt from MIPS reporting.

Below are examples of different scenarios that might appear on the QPP tool if you participate in an APM and how each could affect your MIPS eligibility.

• If you participate in an Advanced APM (for example Next Generation Accountable Care Organization (ACO) or Sharing Savings Program - Track 2) and are a Qualifying APM Participant (QP) or Partial QP you are not required to report MIPS:

• If you participate in certain types of MIPS APMs (for example Medicare Shared Savings Program ACO – Track 1), you may be required to submit Promoting Interoperability (PI) data at the group level (unless otherwise exempt) and the APM entity should submit Quality data. You should contact the APM to confirm your reporting requirements:

• If you participate in a MIPS APM, but are considered a “preferred provider”, you may be required to report MIPS unless otherwise exempt:

• If you bill with multiple TINs, your status will be noted for each practice. If you are not a QP, you may be required to report MIPS for one of your practice TINs and required to follow the APM rules for another practice TIN:

Next Steps

CMS updates the QPP Participation Status Tool throughout the performance year. Clinicians can check whether they are required to report MIPS or are part of an APM by entering their NPI into the tool or checking their MDinteractive account dashboard. It is important to check MIPS eligibility and APM status for each TIN/practice listed on the CMS website. 

MIPS Eligibility MIPS Eligible Clinicians QPP Participation Status Tool Low Volume Threshold APM