Comprehensive Guide to MIPS 2021 Eligibility, Participation Requirements, and Special Status Insights

Medical Practitioners Eligible for MIPS 2021

Eligible Clinicians

The list of clinicians qualified to participate in MIPS 2021 includes those who meet the billing criteria for Medicare Part B or Critical Access Hospital Method II payments and satisfy the Low-Volume Threshold (LVT). Eligible practitioners are:

– Physicians (DDS, DPM, DDM, MD/DO), Chiropractors, and Optometrists
– Physician Assistants
– Audiologists
– Speech and Language Therapists
– Clinical Psychologists
– Nurse Practitioners
– Certified/Registered Nurse Anesthetists
– Nurse-Midwives
– Clinical Nurse Specialists
– Physical or Occupational Therapists
– Dieticians/Nutritional Professionals

MIPS Exclusion Criteria 2021

Reasons for Exclusion

There are three primary reasons healthcare providers may be exempt from participating in MIPS 2021:

1. APM Participation

Providers involved in an Advanced Payment Model (APM) are exempt from MIPS 2021 reporting.

2. Low-Volume Threshold (LVT)

Clinicians who care for 200 or fewer Medicare patients or earn $90,000 or less from Medicare beneficiaries in the performance year 2021 are eligible but cannot participate if they exceed these thresholds.

3. Newly Enrolled in Medicare

Clinicians who enroll in Medicare during the current performance year are exempt from participation until the following year.

MIPS Extreme and Uncontrollable Circumstance Policy 2021

This policy applies to clinicians affected by natural disasters or the COVID-19 pandemic. They can request a hardship exception for all four performance categories, with a deadline of December 31, 2021, for application submission.

Participants and Reporting Types

Types of Participants

MIPS participants can be categorized into three types:

– Individuals
– Groups
– Virtual Groups

All entities must fulfill their reporting requirements within the designated submission period. Participants can choose to report as individuals or as part of a group for all activities; reporting cannot be mixed.

Individual Reporting

Eligible individual clinicians can submit data across the four QPP MIPS categories, selecting the category for submission. CMS evaluates their MIPS scores and payment adjustments based on this data. Clinicians using multiple Tax Information Numbers (TINs) can report MIPS data for each number and receive scores and adjustments accordingly.

Group Reporting

Groups must be recognized for each of the four MIPS categories. Data is collected and reported at the group level, resulting in an overall MIPS score. Organizations submitting MIPS data for groups must include information from all clinicians, even those exempt from reporting due to low volume or other criteria. Certain clinician types, such as those who are hospital-based or non-patient-facing, may be exempt from group reporting for the Promoting Interoperability (PI) category.

Virtual Group Reporting

Virtual Groups consist of individuals and groups, typically comprising ten or fewer clinicians eligible for MIPS. An individual or group may only participate in one virtual group during a performance period, but there is no limit on the number of members in a virtual group. All eligible clinicians in a group must be included if the group chooses to join a virtual group. Clinicians in a virtual group report across all four performance categories, with similar scoring rules to non-virtual MIPS groups.

To form a virtual group, solo practitioners and groups must complete an election process before the performance period begins. For instance, the election period for the 2021 MIPS performance was from October 11 to December 31, 2020.

Special Status Designations

Special status designations provide flexibility for MIPS participants, allowing eligible clinicians to participate in the incentive payment program with fewer reporting requirements. Various designations exist for different participants, including:

– Ambulatory Surgery Center (ASC)-based
– Hospital-based
– Non-patient facing
– Small practice identification
– Health Professional Shortage Area (HPSA)
– Rural designations

Conclusion

The MIPS 2021 performance period marks a significant transition from the peak COVID-19 era to a post-COVID environment. This article summarizes the reporting exclusions, participation criteria, and special status designations related to QPP MIPS 2021, helping practitioners navigate the reporting process more effectively. By understanding these guidelines, clinicians can ensure a smoother MIPS 2021 reporting experience.