Clinicians and groups are excluded from the Merit-based Incentive Payment System (MIPS) for 2020 if they:

  1. Billed $90,000 or less in Medicare Part B allowed charges for covered professional services during either of the 2 determination periods (October 1, 2018 – September 30, 2019 or October 1, 2019 – September 30, 2020); OR
  2. Provided care to 200 or fewer Part B-enrolled patients during either of the 2 determination periods; OR
  3. Provided 200 or fewer covered professional services professional services to Part B patients during either of the 2 determination periods.

In order to be eligible for MIPS, a clinician or group must exceed all 3 criteria listed above. You can check the Quality Payment Program (QPP) Participation Status Tool to view your final 2020 eligibility status for MIPS.

Participation Options for Clinicians and Groups Not Eligible for MIPS

Clinicians and groups who are not eligible for MIPS can still choose to report data to MIPS:

  • Make an Election to Opt-in or Voluntarily Report: Clinicians and groups who are identified as “opt-in eligible” on the QPP Participation Status Tool have exceeded 1 or 2 of the low-volume threshold criteria noted above and have at least 1 clinician who:
    • Is identified as a MIPS eligible clinician type on Medicare Part B claims;
    • Enrolled in Medicare before 2020;
    • Is not a QP; and
    • Is not a participant in one or more MIPS APM entities, all of which are below the low-volume threshold.

These clinicians and groups can make an election to:

  • Opt-in to MIPS. You will receive a MIPS payment adjustment (positive, negative or neutral).
    • Voluntarily Report. You will not receive a MIPS payment adjustment.
    • Note: Once made, your election is binding and irreversible. (No election is required if you don’t want to report data to MIPS.)
  • Voluntarily Report (no election required): Clinicians and groups who are excluded from MIPS and are not “opt-in eligible” because they fall below all 3 of the low-volume threshold criteria may choose to voluntarily report data to MIPS and will not receive a MIPS payment adjustment.

Next Steps

Before reporting data, opt-in eligible clinicians and groups will need to complete an election to opt-in or voluntarily report in MIPS by signing in to qpp.cms.gov. Qualified Registries and Qualified Clinician Data Registries (QCDRs) can also submit elections on behalf of clinicians and groups. Elections can be made once the 2020 MIPS submission period opens on January 4, 2021.

For More Information

Questions?

Contact the Quality Payment Program at QPP@cms.hhs.gov or 1-866-288-8292. To receive assistance more quickly, consider calling during non-peak hours—before 10 a.m. and after 2 p.m. ET.

  • Customers who are hearing impaired can dial 711 to be connected to a TRS Communications Assistant.

About Author

Healthcentric Advisors
As the New England Quality Payment Program Support Center, Healthcentric Advisors assists New England-based physician and other eligible clinical practices to prepare for and participate in the new Quality Payment Program (QPP), established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).