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

If you decide to participate in an Advanced APM through Medicare Part B, you may earn a 9% 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 (45%), Improvement Activities (15%), Promoting Interoperability (25%) and Cost (15%). 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


Submit any 2020 MIPS performance category through the Quality Payment Program web portal. Eligible clinicians can register and manage existing accounts here.

Once 2020 data has been submitted, await performance feedback and review the changes to the MIPS program in 2021 to prepare for participation during the next performance year.

Changes to the MIPS program due to COVID-19

On June 24th, the Centers for Medicare & Medicaid Services (CMS) announced additional flexibilities for the Quality Payment Program (QPP), in response to the COVID-19 pandemic. For the 2020 performance year, CMS has 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 2020 extreme and uncontrollable circumstances application is open through December 31, 2020.  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 2020 performance period. Data submission will void approved applications on a category-by-category basis.

CMS had also previously introduced a new high-weighted COVID-19 clinical trials improvement activity which provides an opportunity for eligible clinicians to receive credit in MIPS.  This improvement activity will also be available for the 2020 performance year.

More information about the additional flexibilities and the Extreme and Uncontrollable Circumstances application can be accessed here.

For questions about MIPS and/or the Quality Payment Program, contact the QPP Help Desk at

AASM Measures for the 2021 Performance Year

The AASM has several quality measures included in the Quality Payment Program for 2021.

MIPS Clinical Quality Measures (CQMs):

Qualified Clinical Data Registry (QCDR) Quality Measures:

A QCDR is an entity CMS approves that collects clinicians’ clinical data for submission. QCDR data submission is not limited to MIPS measures and a QCDR may submit up to 30 QCDR measures (previously referred to as non-MIPS measures) for CMS review and approval. The AASM QCDR measures included in the MIPS program for 2021 include:

  • Pediatric OSA: Objective Assessment of Positive Airway Pressure Therapy Adherence
  • Pediatric OSA: Objective Assessment of OSA Signs and Symptoms in Children with Complex Medical Conditions
  • Adult OSA: Screening for Adult OSA by Primary Care Physicians

The specifications for the QCDR measures can be found here.

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