Navigating MIPS Eligibility and Participation for 2023 and 2024

The healthcare landscape is continually evolving, and clinicians must stay informed about their eligibility and participation options in programs such as the Merit-based Incentive Payment System (MIPS). This article aims to provide a comprehensive overview of the key concepts presented in notifications related to MIPS eligibility and participation for the years 2023 and 2024.

2023 MIPS Eligibility Status Update

The Quality Payment Program (QPP) Participation Status Tool is a valuable resource for clinicians to review their final 2023 MIPS eligibility status. This status is determined based on a meticulous review of Medicare Part B claims and Medicare Provider Enrollment, Chain, and Ownership System (PECOS) data during the MIPS Eligibility Determination Period (October 1, 2022 – September 30, 2023).

The eligibility status is considered final unless a clinician participates in an Advanced Alternative Payment Model (APM), and their Qualifying APM Participant (QP) status changes based on the third APM Snapshot for the 2023 performance year. The results of this snapshot will be communicated through the QPP listserv.

Clinicians are encouraged to use the QPP Participation Status Tool to confirm their final 2023 MIPS eligibility status, especially if changes have occurred in their practice or billing association during the eligibility determination period.

2023 MIPS Low-Volume Threshold Criteria

For the 2023 performance year, clinicians and groups are excluded from MIPS if they meet specific criteria during either of the two segments of the MIPS Eligibility Determination Period (October 1, 2021 – September 30, 2022, or October 1, 2022 – September 30, 2023). Exclusion criteria include billing $90,000 or less in Medicare Part B allowed charges, providing care to 200 or fewer Part B-enrolled patients, or offering 200 or fewer covered professional services to Part B patients.

Clinicians who fall below all three criteria have options to either voluntarily report data for traditional MIPS or, if identified as "opt-in eligible," can elect to opt-in or voluntarily report.

2024 MIPS Eligibility Status Check

Moving into 2024, clinicians are advised to use the QPP Participation Status Tool to check their initial eligibility status for MIPS. This involves entering their 10-digit National Provider Identifier (NPI) to determine whether they need to participate in MIPS during the 2024 performance year.

To be eligible for MIPS in 2024, clinicians must exceed all three low-volume threshold criteria, including billing more than $90,000 for Medicare Part B covered professional services, providing services to more than 200 Medicare Part B beneficiaries, and offering more than 200 covered professional services under the Medicare Physician Fee Schedule (PFS).

Participation Options and Next Steps

Clinicians who fall short of meeting all three criteria for the 2024 performance year are excluded from MIPS. However, they have the opportunity to opt-in or voluntarily report to MIPS, with elections being binding and irreversible once made.

If you’re opt-in eligible, then you aren't required to participate in and report to MIPS, but during the submission period, you may elect to opt in to MIPS and receive performance feedback and a MIPS payment adjustment (positive, negative, or neutral).

For those excluded from MIPS, there is still a chance to participate in traditional MIPS reporting voluntarily, although this won't result in a MIPS payment adjustment.

Future Updates and Considerations

The QPP Participation Status Tool will be updated in December 2024 with final eligibility for the 2024 MIPS performance year. Additionally, updates to reflect clinicians' QP status are anticipated three times during the performance year, expected in July, October, and December 2024.

In conclusion, staying abreast of MIPS eligibility requirements and participating wisely in these programs can significantly impact clinicians' reimbursement and the quality of healthcare provided. Regularly checking eligibility status and making informed decisions about participation options will help clinicians navigate the complex landscape of value-based care.