Merit-based Incentive Payment System (MIPS)
What are the eligibility requirements?
Eligible clinician types include: Physicians (includes doctors of medicine, osteopathy, dental surgery, dental medicine, podiatric medicine, and optometry; osteopathic practitioners; and chiropractors (with respect to certain specified treatment, a Doctor of Chiropractic legally authorized to practice by a State in which he/she performs this function)), Physician Assistants, Nurse Practitioners, Clinical Nurse Specialists, Certified Registered Nurse Anesthetists, Clinical Psychologists, Physical Therapists, Occupational Therapists, Qualified Speech-Language Pathologists, Qualified Audiologists, Registered Dietitians or Nutrition Professionals, and new for 2022, Clinical Social Workers and Certified Nurse Midwives.
Clinicians must exceed the low-volume threshold to be required to participate in MIPS. A clinician exceeds the low-volume threshold if he or she meets all the following criteria:
- Bill more than $90,000 a year in allowed charges for covered professional services; AND
- See more than 200 Medicare Part B beneficiaries; AND
- Provide more than 200 covered professional services to Part B patients.
Participation status can be checked on the CMS Quality Payment Program website.
What data is submitted?
MIPS is based on four performance categories: Quality, Cost, Improvement Activities, and Promoting Interoperability. Each category is weighted and has a set of measures, objectives, or improvement activities that must be completed/reported on to earn points. Data may be submitted by individual clinicians, groups, or virtual groups via the traditional MIPS or Alternative Payment Model (APM) MIPS pathways. The number of points received (out of 100 possible) establishes the performance threshold, which determines the type of payment adjustment – positive, negative, or neutral.
How are payment adjustment applied?
Clinicians receive either an upward or downward payment adjustment for Part B covered professional services based on the evaluation of performance across different performance categories.
What’s new for 2022?
- The performance threshold for a positive adjustment has been increased to 75.01 points. Negative payment adjustments will occur for any score below 75. If a clinician scores exactly 75 points, the payment adjustment is neutral (0%).
- For the Public Health and Clinical Data Exchange objective under the Promoting Interoperability category, Clinicians are required to report on the 1) Immunization Registry Reporting and 2) Electronic Case Reporting measures.
- MIPS Value Pathways (MVPs) are a subset of measures and activities, established through rulemaking, that can be used to meet MIPS reporting requirements beginning in the 2023 performance year.
Both MPIP and MIPS offer hardship exceptions on a case-by-case basis for providers who are unable to meet the requirements of the program, but the deadlines are fast approaching. Applications for MPIP hardship exceptions are due by September 1, 2022, and applications for MIPS hardship exceptions are due by December 31, 2022.
The team at Advis can help you or your organization navigate the intricacies of these programs and maximize your reimbursement amounts. For assistance with MPIP or MIPS, please contact Advis online, or by calling 708.478.7030.