Merit-based Incentive Payment System (MIPS)

What is MIPS?

Passage of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) resulted in implementation of the Quality Payment Program, a Medicare payment system designed to reward physicians for delivering high-quality, cost-effective care. The program is comprised of the following two participation tracks:

  • Advanced Alternative Payment Models (APMs)
  • MIPS
  • MVPs

If you decide to participate in an Advanced APM through Medicare Part B, you may earn a 3.5% incentive payment for engaging in an innovative payment model and will not need to participate in MIPS. Since sleep clinicians can only participate in an Advanced APM if they are affiliated with a large academic institution or healthcare center, most will select the MIPS track. If you choose to participate in MIPS, you will earn a performance-based payment adjustment based on submission of evidence-based and specialty-specific quality data.

How does MIPS work?

Providers participating in MIPS will earn a performance-based adjustment by reporting patient care data, as well as reporting how their practice used technology during the year. An eligible provider can report as an individual, group, or virtual group. Your MIPS score is calculated using four weighted performance categories: Quality (30%), Improvement Activities (15%), Promoting Interoperability (25%) and Cost (30%). Each performance category has a maximum point value assigned to it, as well as a length of time over which data must be collected. Please note that Cost data does not have to be submitted, as Medicare Part A and B claims data are used to calculate cost measure performance.

Who qualifies for MIPS?

Providers are eligible for the MIPS track if all of the following criteria are met:

  1. You bill more than $90,000 per year in Medicare Part B allowed charges
  2. You provide care to more than 200 Part B enrolled Medicare patients per year
  3. You provide more than 200 Medicare professional services
  4. You are one of the following:
    • Certified registered nurse anesthetist
    • Clinical nurse specialist
    • Physical therapist
    • Clinical psychologist
    • Nurse practitioner
    • Occupational therapist
    • Physician
    • Physician assistant
    • Qualified speech-language pathologist
    • Qualified audiologist
    • Registered dietitian or nutrition professional
    • Osteopathic Practitioner
    • Chiropractors
    • Clinical Social workers
    • Certified nurse midwives

What are MVPs (MIPS Value Pathways)

The newest, voluntary reporting option that can be used to meet MIPs reporting requirements and are available for reporting beginning in the 2024 performance year.

MVPs offer:

  1. A more connected assessment of quality care;
  2. Streamlined, reduced set of measures and improvement activities;
  3. Enhanced performance feedback;
  4. An opportunity to become familiar with MVPs and the future of MIPs.

The 16 MVPs that have been finalized for the 2024 performance year can be found here.

Changes to the MIPS program due to COVID-19

For the 2024 performance year, CMS has, once again, implemented the Extreme and Uncontrollable Circumstances policy. This policy allows eligible clinicians, groups and virtual groups to submit an application, requesting reweighting of the Merit-based Incentive Payment System (MIPS) performance categories down to 0%, due to COVID-19.  The 2024 extreme and uncontrollable circumstances application will be available in Spring 2024.  Extreme and Uncontrollable Circumstances applications will be reviewed on a case-by-case basis, and if approved, the performance categories included in the application are weighted at 0% and will not contribute to the participant’s final score unless MIPS data are submitted for the 2024 performance period. In some instances the Extreme and Uncontrollable Circumstances exception will be automatically applied. Learn more about COVID-19 flexibilities.

For questions about MIPS and/or the Quality Payment Program, contact the QPP Help Desk at QPP@cms.hhs.gov

AASM Measures for the 2024 Performance Year

The AASM has several quality measures included in the Quality Payment Program for 2024.

MIPS Clinical Quality Measures (CQMs):

Members may submit questions about Sleep CDR to registry@aasm.org.