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Eligible Clinicians

Clinicians Included in MIPS

  • Physicians (including doctors of medicine, doctors of osteopathy, osteopathic practitioners, doctors of dental surgery, doctors of dental medicine, doctors of podiatric medicine, doctors of optometry, and chiropractors)
  • Physician assistants
  • Nurse practitioners
  • Clinical nurse specialists
  • Certified registered nurse anesthetists
  • Physical therapist
  • Occupational therapist
  • Clinical psychologist
  • Qualified speech-language pathologist
  • Qualified audiologist
  • Registered dietician or nutrition professionals
  • Groups or virtual groups that include one or more of the clinician types above


    • Have ≤ $90K in Part B allowed charges for covered professional services,
    • Provide care to ≤ 200 Part B enrolled beneficiaries, OR
    • ≤ 200 covered professional services under the Physician Fee Schedule (PFS)

Clinicians Exempt from MIPS

    • Clinicians who are not one of the clinician types above
    • Clinicians who enroll in Medicare for the first time in 2018
    • Clinicians who participate in an Advanced APM and are either a Qualifying APM Participant (QP) or Partial QP
    • Clinicians who are not in a MIPS eligible specialty
    • Clinicians or groups that have billed $90,000 or less in Physicial Fee Schedule (PFS) services furnished to Medicare Part B Fee-for-Service (FFS) beneficiaries (including Railroad Retirement Board and Medicare secondary Payer)
    • Clinicians or groups that have 200 or fewer Medicare Part B FFS beneficiaries

Determination Period

CMS creates a single MIPS determination period that would be used for purposes of the low-volume threshold and to identify MIPS eligible clinicians as non-patient facing, a small practice, hospital-based, and ASC-based, as applicable:

    • An initial 12-month segment beginning on October 1, 2017 to September 30, 2018; and
    • A second 12-month segment beginning on October 1, 2018 to September 30, 2019.
    • It is important to note that if a TIN or TIN/NPI did not exist in the first segment, but does exist in the second segment, these eligible clinicians could be eligible for MIPS. For example, the eligible clinician may not find their TIN or TIN/NPI in the Quality Payment Program lookup tool but may still be eligible if they exceed the low-volume threshold in the second segment.

MIPS Opt-in

  • Starting in 2019, clinicians or groups will be able to opt-in to MIPS if they meet or exceed at least 1, but not all three, of the low-volume threshold criterion. 
  • For individual eligible clinicians and groups to make an election to opt-in or voluntarily report to MIPS, they would make an election via the Quality Payment Program portal by logging into their account and simply selecting either the option to opt-in (positive, neutral, or negative MIPS adjustment) or to remain excluded and voluntarily report (no MIPS adjustment).
  • Once the clinician or group elects to opt-in to MIPS, the decision is irrevocable and cannot be changed for the applicable performance period.
  • Clinicians who do not decide to opt-in to MIPS would remain excluded and may choose to voluntarily report. Such clinicians would not receive a MIPS payment adjustment factor.
  • CMS has developed a website that provides design examples of the different approaches to MIPS participation in CY 2019. The website uses wireframe (schematic) drawings to illustrate the three different approaches to MIPS participation: voluntary reporting to MIPS, opt-in reporting to MIPS, and required to participate in MIPS.
  • Individual eligible clinicians and groups opting-in to participate in MIPS would be considered MIPS eligible clinicians, and therefore subject to the MIPS payment adjustment factor.  Individual eligible clinicians and groups voluntarily reporting measures and activities for the MIPS are not considered MIPS eligible clinicians, and therefore not subject to the MIPS payment adjustment factor.

Performance Period:

  • Quality: 12-month calendar year performance period.
  • Cost: 12-month calendar year performance period.
  • Promoting Interoperability: 90 days minimum performance period.
  • Improvement Activities: 90 days minimum performance period.

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