Merit-based Incentive

Payment System (MIPS)

2022 Eligibility and Participation Quick
Start Guide

1
Contents Already know what MIPS is?
Skip ahead by clicking the links in the Table of Contents.

How to Use This Guide 3

Overview 5
• What is the Merit-based Incentive Payment System? 6
• What are the MIPS Eligibility Criteria? 8
• What’s New with Participation and Eligibility in 2022? 10
Get Started with MIPS Eligibility and Participation in 5 Steps 12
• Overview 13
• Step 1. Check Your Current Eligibility 14
• Step 2. Review Your MIPS Participation Information for Each Associated Practice 15
• Step 3. Understand Your Reporting Options 19
• Step 4. Understand How Your Eligibility Could Change 21
• Step 5. Check Your Final Eligibility 22
Help, Resources, and Version History 23

Purpose: This resource focuses on Merit-based Incentive Payment System (MIPS) eligibility and
participation, providing high level information and actionable steps for interpreting your eligibility and
participation requirements for the 2022 MIPS performance period.

2
How to Use This Guide

3
How to Use This Guide

Table of Contents
The table of contents is interactive. Click on a
chapter in the table of contents to read that section.
You can also click on the icon on the
bottom left to go back to the table
of contents.

Please note: This guide was prepared for informational

purposes only and isn’t intended to grant rights or impose Hyperlinks
obligations. The information provided is only intended to Hyperlinks to the Quality Payment Program website
be a general summary. It isn’t intended to take the place of are included throughout the guide to direct the
the written law, including the regulations. We encourage reader to more information and resources.
readers to review the specific statutes, regulations, and
other interpretive materials for a full and accurate
statement of their contents.

4
Overview

5
Overview

What is the Merit-based Incentive Payment System?

The Merit-based Incentive Payment System (MIPS) is one way to participate in

the Quality Payment Program (QPP), a program authorized by the Medicare
Access and CHIP Reauthorization Act of 2015 (MACRA). The program describes To learn more about MIPS eligibility
how we reimburse MIPS eligible clinicians for Part B covered professional services and participation options:
and rewards them for improving the quality of patient care and outcomes.
• Visit the How MIPS Eligibility is
Determined and Participation
Under MIPS, we evaluate your performance across multiple categories that lead Options web pages on the Quality
to improved quality and value in our healthcare system. Payment Program website.
• View the 2022 MIPS Quick Start
If you’re eligible for MIPS in 2022: Guide.
• Check your current participation
• You generally have to submit data for the quality, improvement activities, status using the QPP Participation
and Promoting Interoperability performance categories. (We collect and Status Tool.
calculate data for the cost performance category for you.)
• Your performance across the MIPS performance categories, each with a
specific weight, will result in a MIPS final score of 0 to 100 points.
• Your MIPS final score will determine whether you receive a negative,
neutral, or positive MIPS payment adjustment.
• Your MIPS payment adjustment is based on your performance during
the 2022 performance year and applied to payments for covered
professional services beginning on January 1, 2024.

6
Overview

What is the Merit-based Incentive Payment System? (Continued)

Traditional MIPS, established in the first year of the QPP, is the original framework for collecting and reporting data to MIPS.
Under the traditional MIPS, participants select from 200 quality measures and over 100 improvement activities, in addition to
reporting the complete Promoting Interoperability measure set. We collect and calculate data for the cost performance category for
you.
In addition to traditional MIPS, 2 other MIPS reporting frameworks, designed to reduce reporting burden, will be available to MIPS
eligible clinicians.
• The APM Performance Pathway (APP), is a streamlined reporting framework available beginning with the 2021
performance year for MIPS eligible clinicians who participate in a MIPS APM. The APP is designed to reduce reporting
burden, create new scoring opportunities for participants in MIPS APMs, and encourage participation in APMs.

• MIPS Value Pathways (MVPs) are subsets of measures and activities, established through rulemaking, that can be used to
meet MIPS reporting requirements beginning with the 2023 performance year. The MVP framework aims to align and
connect measures and activities across the quality, cost, and improvement activities performance categories of MIPS for
different specialties or conditions. In addition, MVPs incorporate a foundational layer that leverages Promoting
Interoperability measures and a set of administrative claims-based quality measures that focus on population health/public
health priorities. There are 7 MVPs that will be available for reporting in the 2023 performance year:
1. Advancing Rheumatology Patient Care
2. Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes
3. Advancing Care for Heart Disease
4. Optimizing Chronic Disease Management
5. Adopting Best Practices and Promoting Patient Safety within Emergency Medicine
6. Improving Care for Lower Extremity Joint Repair
7. Support of Positive Experiences with Anesthesia

We encourage clinicians interested in reporting an applicable MVP to become familiar with the MVP’s requirements in advance of
the 2023 performance year. For more information on the finalized MVPs, please refer to the CY 2022 Physician Fee Schedule Final
Rule. We’ll also be adding more information to MIPS Value Pathways section of the QPP website.

7
Overview

What are the MIPS Eligibility Criteria?

Your individual MIPS eligibility is determined by:

• Your clinician type AND
• The date you enrolled in Medicare AND
• The degree to which you participate in an Advanced APM AND
• The volume of care you provide to Medicare patients

You’re excluded from MIPS for the 2022 performance year and aren’t eligible for a MIPS payment adjustment in the 2024 MIPS
payment year if:
• You’re not an eligible clinician type1 OR
• You enrolled as a Medicare provider for the first time on or after January 1, 2022 OR
• You’re determined to be a Qualifying APM Participant (QP) based on the degree of your participation in an Advanced APM

1The 2022 MIPS eligible clinician types are physicians (MD, DO, DDS, DMD, DPM, OD), osteopathic practitioners,
chiropractors, physician assistants, nurse practitioners, certified nurse anesthetists, physical therapists, occupational
therapists, clinical psychologists, qualified speech-language pathologists, qualified audiologists, registered dietitians
or nutrition professionals, clinical social workers, and certified nurse-midwives.

8
Overview

What are the MIPS Eligibility Criteria? (Continued)

Are you excluded from the 2022 performance year of MIPS but want to participate?

If you’re excluded from MIPS for one of the reasons listed on the previous page, you may participate in MIPS voluntarily. As a
voluntary reporter, you’ll receive performance feedback but not a MIPS payment adjustment.

If you’re not excluded from MIPS for one of the reasons on the previous page, you could be excluded based on the volume of care
you provided to Medicare patients, referred to as the low-volume threshold. The low-volume threshold looks at:
• The amount of your allowed charges billed to Medicare AND
• The number of Medicare patients you provided services to AND
• The number of covered professional services you furnished

9
Overview

What’s New with MIPS Eligibility and Participation in 2022?

We’ve added the following 2 new clinician types as eligible clinician types beginning in the 2022 performance year: clinical social
workers (CSWs) and certified nurse-midwives.

You’re considered a MIPS eligible clinician (i.e. required to report) and will receive a payment adjustment when:
• You’re an eligible clinician type AND
• You enrolled in Medicare before January 1, 2022 AND
• You’re not identified as a QP AND
• You exceed the low-volume threshold (exceeding all 3 low-volume elements as shown below)

Low-volume threshold criteria:

Billing Services
>90,000 AND AND >200
>200

To exceed the low-volume threshold for the 2022 performance year, you must:
• Bill more than $90,000 for Part B covered professional services under the Physician Fee Schedule (PFS), and
• Provide services to more than 200 Medicare Part B patients, and
• Furnish more than 200 covered professional services to Part B Medicare Patients.

10
Overview

What are the MIPS Eligibility Criteria? (Continued)

We evaluate both individuals and groups for eligibility against the low-volume threshold at each practice (identified by Taxpayer
Identification Number) through which you bill covered professional services during two 12-month segments, referred to as the MIPS
Determination Period. We also see if you qualify for any special statuses that might reduce your reporting requirements.

2022 MIPS Determination Period

October 1, 2020
October 1, 2021
- September 30,
– September 30,
2021
(preliminary
AND 2022
(available
eligibility results
November 2022)
available now)

If you or your group is not eligible to participate in MIPS because of the low-volume threshold, you can voluntarily report and
may be eligible to opt-in to MIPS participation.

To opt-in, you or your group must exceed 1 or 2 elements of the low-volume threshold elements.

11
Get Started with MIPS Eligibility
and Participation in 5 Steps

12
Get Started with MIPS Eligibility and Participation in 5 Steps

Overview

Step 1 Step 2 Step 3 Step 4 Step 5

Review Your MIPS

Understand How
Check Your Current Participation Understand Your Check Your Final
Your Eligibility
Eligibility Information for Reporting Options Eligibility
Each Associated Could Change
Practice

ANY TIME ANY TIME ANY TIME Until December 2022 December 2022

13
Get Started with MIPS Eligibility and Participation in 5 Steps

Step 1. Check Your Current Eligibility Status

If you work at multiple practices, you may be eligible (i.e., required to report) at one practice, but not at another.
• Check your preliminary eligibility status based on analysis of data from the first segment of the MIPS Determination Period by
entering your National Provider Identifier (NPI) in the QPP Participation Status Tool.
OR
• Sign in to QPP to check the eligibility status for all groups you’re associated with and the connected clinicians in your practice
based on analysis of data from the first segment of the MIPS Determination Period.

When checking your eligibility status, make sure you select Performance Year (PY) 2022.

PY Tabs in qpp.cms.gov

Note: This section includes screenshots from the QPP Participation Status Tool.

14
Get Started with MIPS Eligibility and Participation in 5 Steps

Step 2. Review Your MIPS Eligibility Information for Each Associated Practice
Beneath each practice association, you’ll see an indicator of your individual and group
eligibility statuses.
Click the + Expand option to the right of each associated practice name to view information
about your MIPS Participation (reporting requirements, reporting options, and payment
adjustment information) based on your eligibility status.

Helpful Hint

You’re MIPS eligible if you see a

checkmark and green font

You’re excluded from MIPS if you

see a no symbol and black
font

15
Get Started with MIPS Eligibility and Participation in 5 Steps

Step 2. Review Your MIPS Eligibility Information for Each Associated Practice (Continued)

Eligibility Information
• Keep scrolling to view more information about your eligibility, including whether you meet the low-volume threshold and
qualify for other reporting factors at the Clinician Level (for individual participation) and the Practice Level (for group
participation).

Helpful Hint

You will see “Yes” when you

exceed all 3 elements of the low-
volume threshold.

You will see “No” if you do not

exceed one (or more) of these
elements.

TIP: If you sign in to

qpp.cms.gov, you will see actual
patient counts, allowed charges,
and number of covered services
at the group level and for each
clinician in the practice.

16
Get Started with MIPS Eligibility and Participation in 5 Steps

Step 2. Review Your MIPS Eligibility Information for Each Associated Practice (Continued)

Other Reporting Factors

• Other Reporting Factors are designations, such as special statuses, that can affect
your MIPS participation options and reporting requirements. These factors are
determined at the clinician (unique TIN/NPI combination) level, practice (Tax
Identification Number (TIN)) level, and virtual group level.
• Other reporting factors, such as special status designations, only apply at the level
(i.e., clinician or practice) indicated and are not transferrable to other levels.
Special statuses at the
• Note: The QPP Participation Status Tool will only display other reporting factors at practice level ONLY apply
the clinician and practice level. You must sign in to QPP to view these factors for to group reporting.
your virtual group.

Special statuses at the

clinician level ONLY apply to
individual reporting.

17
Get Started with MIPS Eligibility and Participation in 5 Steps

Step 2. Review Your MIPS Eligibility Information for Each Associated Practice (Continued)

Don’t see your current practice listed on the status tool? Are you missing clinicians in your connected clinicians list when you
sign in to qpp.cms.gov?
This means we didn’t find Part B claims data for you at this practice in the first 12-month segment of the MIPS Determination Period.
We’ll update eligibility status information in December 2022 to show clinicians who started billing Part B services under a new
practice (identified by their Tax Identification Number, or TIN) between October 1, 2021 and September 30, 2022.

You may become MIPS eligible at a new

practice when we update eligibility status
information in December 2022.

Where can I learn more?

Visit the QPP website for more information about how

eligibility is determined and how other reporting
factors, including special status, can affect how much
data you need to report.

18
Get Started with MIPS Eligibility and Participation in 5 Steps

Step 3. Understand Your Participation Options

You may be eligible to participate in MIPS at different levels: as an individual, as a group, as an APM entity, or as a virtual group.
Because these participation options are tied to your eligibility, they are specific to each practice with which you’re associated.

You see… This means.

You, as an individual clinician, are required to report either individually or as part of a group.
• If you submit any data as an individual, you’ll be evaluated for all performance categories as an
individual.
• If your practice submits any data as a group, you’ll be evaluated for all performance categories as a
group.
• If data is submitted both as an individual and a group, you’ll be evaluated as an individual and as a
group for all performance categories, but your payment adjustment will be based on the higher score.

You’ll receive a payment adjustment.

You, as an individual clinician, are not required to report. Your practice exceeds the low-volume threshold and
has the option to participate as a group. There is no requirement to participate as a group.
• If your practice chooses not to participate as a group, the MIPS eligible clinicians in the practice who
exceed the low-volume threshold as individuals will need to participate as individuals.
• If your practice chooses to participate as a group, you’ll receive a payment adjustment

You, as an individual clinician, are not required to report and your practice doesn’t exceed the low-volume
threshold.

You will not receive a payment adjustment, even if you or your practice chooses to submit data voluntarily.
You’re eligible for MIPS and can only participate through your virtual group.

(We will add virtual group information once we

have finished processing virtual group
applications in February/March 2022.)

The QPP Participation Status tool will be updated throughout the year to identify which clinicians are MIPS APM participants. The first
update will be in July 2022. MIPS eligible individuals who are also MIPS APM participants may report to MIPS as an individual, a group, or
as an APM Entity either through the APP or via traditional MIPS.

19
Get Started with MIPS Eligibility and Participation in 5 Steps

Step 3. Understand Your Participation Options (Continued)

What does Opt-In Eligible mean?

This means that you aren’t required to participate in MIPS, but based on the volume of care you provide, you can elect (choose) to
receive a MIPS payment adjustment or to report voluntarily. These elections are made during the submission period (January – March
2023), prior to you submitting any data.
You may be opt-in eligible as an individual or a group (or both). If you’re opt-in eligible, you’ll see the following results in the QPP
Participation Status Tool.

• If you’re opt-in eligible because you’re an eligible clinician type, are not otherwise excluded, and exceed at least 1 but not all
3 elements of the low-volume threshold as an individual, you can elect to opt-in to MIPS as an individual, voluntarily-report,
or do nothing.
• If a practice is opt-in eligible as a group, the practice can elect to opt-in to MIPS as a group, voluntarily-report as a group, or
do nothing.
• If an individual or group doesn’t exceed any of the elements of the low-volume threshold, they can voluntarily-report or do
nothing.

20
 Get Started with MIPS Eligibility and Participation in 5 Steps

Step 4. Understand How Your Eligibility Could Change

As of January 1, 2022, we’re displaying your eligibility status based on analysis of data from the first 12-month segment of the MIPS
Determination Period.
Between now and December 2022, your eligibility status and associated participation options can change if you:
• Reassign billing rights to a new TIN OR
• Are identified as a Qualifying APM Participant (QP) or lose your status as a QP, OR
• Are identified as a MIPS APM participant and are eligible to report via the APP, OR
• See a decrease in the volume of care you provide to Medicare patients at a current practice
For example, you could become eligible (required to participate) at a new practice, identified by TIN if you start billing Part B claims
under that TIN between October 1, 2021 and September 30, 2022.
Your eligibility can also change, between now and December 2022, at practices you’re currently associated with:

Eligible Opt-In Eligible Exempt If you’re currently eligible, you

should start collecting your
If you’re currently eligible, you could If you’re currently opt-in eligible, If you’re currently excluded, you
quality data now so that
you could will remain excluded unless your
• Remain eligible, you’re prepared to submit this
QP status changes.
• Become opt-in eligible, or • Remain opt-in eligible, or information in January 2022.
• Become excluded. • Become excluded.
Why? The quality performance
If you’re identified as part of a virtual group, you’ll be eligible and required to participate through your virtual group category has a 12-month
which won’t change. If you’re identified as a MIPS APM participant, you may have the option to report to traditional performance period (January 1,
MIPS as an APM Entity or the APP (as an individual, group or APM Entity). 2022 – December 31, 2022).

21
Get Started with MIPS Eligibility and Participation in 5 Steps

Step 5. Check Your Final Eligibility Status

Check the QPP Participation Status Tool or sign in to qpp.cms.gov at the end of the year.

• Final MIPS eligibility status determinations, based on reconciled data from both 12-month segments of the MIPS
Determination Period and APM snapshots, will be available in late 2022.
• Estimated release dates for eligibility status updates and final determinations are available on qpp.cms.gov.
• Subscribe to the QPP Listserv at the bottom of the Quality Payment Program website to receive announcements on
important dates, deadlines, and releases.

22
Help, Resources, and Version
History

23
Help, Resources, and Version History

Where Can I Get Help?

Contact the Quality Payment

Program Service Center at 1-866-
288-8292 or by e-mail at:
[email protected] (Monday-Friday
8 a.m.- 8 p.m. ET). To receive Visit the Quality Payment Program
assistance more quickly, please website for other help and support
consider calling during non-peak information, to learn more about
hours—before 10 a.m. and after 2 MIPS, and to check out the
p.m. ET. resources available in the Quality
• Customers who are hearing Payment Program Resource Library.
impaired can dial 711 to be
connected to a TRS
Communications Assistant.

24
Help, Resources, and Version History

Additional Resources

The Quality Payment Program Resource Library houses fact sheets, specialty guides, technical guides, user guides, helpful videos,
and more. We will update this table as more resources become available.

Resource Description

2022 MIPS Eligibility and Participation Quick A high-level overview and actionable steps to understand your 2022
Start Guide MIPS eligibility and participation requirements.
A high-level overview and practical information about quality measure
2022 MIPS Quality Performance Category Quick
selection, data collection and submission for the 2022 MIPS quality
Start Guide
performance category.
A high-level overview and practical information about data collection
2022 MIPS Promoting Interoperability
and submission for the 2022 MIPS Promoting Interoperability
Performance Category Quick Start Guide
performance category.
A high-level overview and practical information about data collection
2022 Improvement Activities Quick Start Guide and submission for the 2022 MIPS improvement activities
performance category.
2022 MIPS Cost Performance Category Quick A high-level overview of cost measures, including calculation and
Start Guide attribution, for the 2022 MIPS cost performance category.
An overview of the reporting and scoring pathway for MIPS eligible
2022 APP Toolkit
clinicians who participate in MIPS APMs: the APP.

25
Help, Resources, and Version History

Version History
If we need to update this document, changes will be identified here.

Date Description

01/18/2022 Updated to reflect correct links on slide 25.

12/31/2021 Original Posting.

26