MIPS: Participation in the Quality Payment Program

Who Can Participate in the Merit-based Incentive Payment System (MIPS)?

The Quality Payment Program (QPP) has expanded the groups for Eligible Clinicians in 2019.  Already eligible to participate are physicians, physician assistants, nurse practitioners, clinical nurse specialists and certified registered nurse anesthetists. For 2019, the Centers for Medicare & Medicaid Services (CMS) has added physical therapists, occupational therapists, qualified speech-language pathologists, qualified audiologists, clinical psychologists, registered dietitians or nutrition professionals and groups of such clinicians.

How Do We Find Out Who is Required to Participate?

Even if you are not required to participate as an individual, you may be required to report as a group or approved virtual group, or under a MIPS Alternative Payment Model (APM). Look at the QPP Participation Status Tool using your 10-digit National Provider Identifier (NPI) to see if you are required to report by status year.

Providers or practices who do not exceed the Low-Volume Threshold set by CMS for performance years, from the beginning of October in one year, until the last day of September in the following year, can choose not to participate as noted on the QPP Participation Status Tool.  

Typically excluded from MIPS Participation (and not receiving a MIPS payment adjustment) are:
  • Qualifying APM participants in an Advanced APM
  • Eligible Clinicians who did not meet the Low-Volume Threshold (less than $90,000 in Part B charges and less than 200 beneficiaries)
  • And new in 2019, Clinicians and Groups with less than 200 covered professional services under the Physician Fee Schedule

Can I Report Even if the QPP Participation Status Tool Shows It’s Not Required?

Practices and Individuals can participate and be eligible for MIPS payment adjustments if they meet or exceed certain criteria (see table below).  In the QPP Participation Status Tool, you will see a line noting Opt-In Option: Opt-in eligible as individual or group.


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