Who Qualifies for QPP MIPS 2022 Participation?

MIPS 2022 Eligibility

Eligibility status is based on the following:

• National Provider Identifier (NPI)
• Associated Taxpayer Identification Numbers (TIN)

A TIN can belong to

• You, if you are a self-employed
• A practice
• Or an organization such as Hospital

MIPS Eligible Clinicians 

A clinician who is eligible to participate in the Quality Payment Program through the Merit-Based Incentive Payment System MIPS and similar participants of the other program of CMS using the electronic clinical quality measures for the quality reporting as an Alternative Payment Model Participants.

The clinicians are eligible to participate in MIPS if they are MIPS-eligible clinician type and also meet all the other requirements. The clinician is excluded from Reporting and the MIPS payment adjustment if they are none of the mentioned below.

• Clinical Psychologists
• Physical Therapists
• Chiropractors
• Physicians (includes a doctor of medicine, dental surgeon, dental medicine, osteopathy, optometry, podiatric medicine)
• Nurse Practitioners
• Clinical Nurse Specialist
• Certified Registered Nurse Anesthetists
• Occupational Therapists
• Qualifies-Speech Language Pathologists
• Qualified Audiologists
• Registered Dietitians or Nutrition Professionals
• Clinical Social workers
• Certified Nurse Midwives

There are several ways to become a MIPS-eligible clinician, depending on whether you are reporting as an individual, as a part of the group, or as a part of the virtual group.

MIPS Participation Options Overview 

“Participation Option” refers to the level at which the data is collected and “submitted” or “reported” to CMS for MIPS. There are five options for MIPS 2022 participation:

• Individual
• Group
• Subgroup
• Virtual Group
• APM entity

The participation options available to you are also informed by your chosen MIPS reporting options. Below are the 5 participation options applicable for reporting.

1. Individual 

An individual is defined as a single clinician which can be identified by their National Provider Identifier (NPI) tied to a single Taxpayer Identification Number (TIN). You are qualified to take part in MIPS individually.

When you participate as an individual then you will collect be able to collect data and report measures and activities based on your performance. You’ll be able to access your performance across all performance categories as an individual. Your payment adjustment will be based on your final score from the MIPS performance categories.

To MIPS 2022 eligible as an Individual you must be:

• Identify as MIPS eligible clinician type on Medicare Part b claims
• Before the 2022 performance year enrolled as Medicare Provider
• Not a participant in Qualifying Alternative Payment Model
• As an individual exceed the low-volume threshold

2. Group 

A group refers to a single TIN with 2 or more clinicians (at least one clinician in the group must be eligible for MIPS) as they are identified by their NPI who have reassigned their Medical Billing rights to a single TIN. When you participate as a group then you’ll collect and report measures and activities based on the aggregated performance of the clinicians billing under TIN. If you participate as a group then your payment adjustment will be based on your group’s final score from the MIPS performance categories.

3. Virtual Group 

You can participate in traditional MIPS as a virtual group if you are part of a CMS-approved virtual group. A combination of two or more Taxpayer Identification Numbers (TINs) that decide to establish a virtual group for the performance year is referred to as a virtual group. There is no restriction on how many TINs can make up a virtual group.

4. Subgroup 

A subgroup is a subset of clinicians in a group (At least two clinicians) that contains at least one individually eligible MIPS clinician. Subgroup participation is only available for reporting an MVP and it requires advance registration. Subgroups can’t report to traditional MIPS and APP.

5. APM Entity

APM Entities are organizations that take part in alternative payment models or other payer arrangements either directly through agreements with CMS or other payers, or indirectly through federal or state laws or regulations. The doctors listed on one of the four APM snapshot dates’ APM Participant Lists (or Affiliated Practitioner Lists) are qualified to take part in MIPS as an APM Entity.

• If you participate as a virtual group you’ll receive a payment adjustment based on the virtual group’s final score no matter if you have the additional final score from the other participation option.
• You will get a payment adjustment depending on the top score if you participate as an individual, a group, or an APM Entity.

Opt-in Eligible Clinicians 

If you are not an opt-in eligible clinician then you are not required to participate in 2022 QPP MIPS Quality Measures but during the submission period you may elect to opt-in to MIPS 2022

End Note

Hope it will be helpful for you to understand who will be eligible for MIPS 2022 participation. Only the above-mentioned are able to participate in MIPSS reporting in 2022.