The law required CMS to implement incentive programs that reward value and outcomes for clinicians and other healthcare service providers. One of the incentive programs currently enforced is MIPS— Merit-Based Incentive Payment System.

Who are eligible for this incentive program?

Eligible clinician types that meet the low volume threshold under the Medicare Physician Fee Schedule are included in this incentive program. Their quality, improvement activities, promotion interoperability, and cost are all measured in order to get the whole picture when it comes to their performance as a health service provider. Here are the clinician types that fall under this system:

• Physicians
• 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 Dieticians & Nutrition Professionals

MIPS Eligibility Exemptions

There are some exemptions to the Merit-Based Incentive Payment System. You are not eligible to be in this incentive system if you:
• are newly-enrolled in Medicare,
• belong to the low-volume threshold (LVT)*,
• have an advanced APM participation.

*Less than $90,000 in Medicare Part B Charges, less than 200 Medicare Part B patients or less than 200 covered professional services

Opt-in Reporting Option

Clinicians and groups are allowed to opt-in or voluntarily sign-up to MIPS if they meet one or two (but not all) of the LVT criteria. If you are part of an opt-in group, there’s an increased potential for return on investment and a reduced administrative burden for clinicians. That means that clinicians will get the same score based on your performance as a group.

What happens if you fail to report for the 2020 performance period?

If you are a provider that’s eligible for this system, you should make sure to report data for the 2020 performance period. Otherwise, you will be charged 9% of your Medicare payments in 2022.

When will the performance feedback be released?

Once you’ve submitted your data, please expect the feedback in 60 days or less. If you do not receive your feedback in the given timeframe, try to approach CMS to follow-up on your performance feedback.

What are the Pacing Options available to clinicians this 2020?

Since this is a merit-based system, your performance feedback affects the amount of incentive you will get. If you receive less than 45 points, you have a 9% annual income penalty. If you hit exactly 45 points, you’ll avoid paying the penalty, but you won’t have an incentive either. Getting 45-79 points will give you some incentive, while 80-100 points will award you with the max incentives up to 9% of positive payment adjustment.

What are the weights for the performance categories?

As mentioned, four main performance categories will determine your score as a clinician or as a group. For the 2020 performance period, here are the weights for each category: Cost (20%), Quality (40%), Improvement Activities (15%), and Promoting Interoperability (25%).

Basics in Quality Reporting Requirements

  • You will typically need to submit collected data for at least 6 measures (including 1 outcome measure or high-priority measure in the absence of an applicable outcome measure), or a complete specialty measure set.
  • You will need to report performance data for 70% of the patients who qualify for each measure (data completeness).
The Quality performance category has a 12-month performance period (January 1 – December 31, 2020) which means you must collect data for each measure for the full calendar year.

Promoting Interoperability (PI) Reporting Requirement Basics

There’s a 90-day minimum reporting period for this, and 2015 certified EHR technology is needed for the performance-based scoring.
Interoperability Exemptions

If you belong to these specialties, then you are exempt from promoting interoperability performance category:
• Physician Assistants
• Nurse Practitioners
• Clinical Nurse Specialists
• Certified Registered Nurse Anesthetists
• Physical Therapists
• Occupational Therapists
• Clinical Psychologists
• Qualified Speech-Language Pathologists
• Qualified Audiologists
• Registered Dieticians, Nutrition Professionals
• Non-patient facing clinicians
• ASC-based clinicians

Improvement Activities Reporting Requirements

When it comes to reporting about your improvement activities, there are a few basics that you should be aware of. First, there’s a 90-day minimum reporting period applicable to this. More than 100 improvement activities are available. You’ll need 40 points for high and medium-weighed activities and 20 points for rural, HPSA, and non-patient facing clinicians, including small practices.

Cost Reporting Requirements

Your cost reporting will automatically be calculated from your administrative claims data. The performance period for this is the whole calendar year.

Get started on MIPS with WCH!

There’s a lot to learn about MIPS and how you should react to this as a healthcare provider. Follow this link if you want to know if you are eligible for MIPS.
Here at WCH, we have existing MIPS support services to help our clients handle the whole reporting process. For questions, do not hesitate to reach out to us at Start collecting data now!