Understanding MIPS 2023 Participation Status: Reporting Requirements Explained

MIPS 2023 Eligibility for Clinicians

Understanding MIPS Eligibility

Are you among the clinician types eligible for MIPS in 2023? It is crucial to understand the importance of maintaining MIPS eligibility. The Centers for Medicare & Medicaid Services (CMS) updates the MIPS participation status twice each performance year. Initially, clinicians receive their preliminary eligibility status, followed by a final eligibility status. Therefore, it is essential for MIPS 2023 clinicians to verify their final eligibility as CMS has recently made updates regarding MIPS 2023 reporting. With the submission window now open, it is an opportune time to check your participation status. This article provides valuable insights for all MIPS participants who have engaged this year, guiding them in comprehending MIPS eligibility and determining their reporting requirements.

MIPS 2023 Participation Status

According to the MIPS framework, only eligible clinicians can participate in MIPS. Wondering who qualifies as an eligible clinician? CMS has outlined a list of clinician types required to engage in MIPS reporting. However, it is not just about eligibility; these clinicians must also diligently meet reporting requirements to maintain their status. Failing to fulfill these requirements at any point could lead to immediate exemption. The initial eligibility status serves as a green flag for entering the performance period, while the final eligibility status allows entry into the reporting period.

Eligible Clinician Types for MIPS 2023

The following clinician types are recognized as eligible under the Physician Fee Schedule (PFS) final rule for Performance Year (PY) 2023:

– Medical professionals (including doctors of medicine, osteopathy, dentistry, dental medicine, podiatric medicine, and optometry)
– Osteopathic doctors
– Chiropractors
– Medical assistants
– Licensed practical nurses
– Clinical nurse specialists
– Registered nurse anesthetists (certified)
– Physical therapists
– Occupational therapists
– Licensed clinical psychologists
– Qualified audiologists
– Qualified speech-language pathologists
– Registered dietitians and nutritionists
– Social workers in clinical settings
– Nurse midwives (certified)

With an understanding of eligible clinician types, let’s explore the criteria CMS uses to determine your eligibility status for 2023.

MIPS Eligibility Determination Criteria

Your eligibility for MIPS 2023 is determined by several factors:

– Specific clinician type
– Enrollment date as a Medicare provider
– Volume of care provided to Medicare Part B-eligible patients
– Level of participation in an Advanced Alternative Payment Model (APM), specifically your Qualifying APM Participant (QP) status

The Importance of Checking Your MIPS Participation Status

Your MIPS participation status is essential for understanding how you can participate in MIPS 2023 reporting. It clarifies whether you are eligible to report as an individual or as part of a group. To check your status, you will need your correct National Provider Identifier (NPI) and Tax Identification Number (TIN).

In some cases, providers may associate their TIN with multiple practices, necessitating participation in MIPS for more than one practice. Fortunately, checking your participation status can provide you with timely eligibility updates. Additionally, if you hold any special status in MIPS, the CMS tool can provide detailed information in just a few seconds. Keep in mind that your eligibility and special status are linked to your claims’ review and Provider Enrollment, Chain, and Ownership System (PECOS) data. Specifically, data from October 1, 2022, to September 30, 2023, is pertinent. The Quality Payment Program (QPP) Status Tool also informs you about your opt-in capability for MIPS.

Key Considerations

It is imperative to conduct a MIPS eligibility check for every TIN or practice for which you submit Medicare claims. Additionally, review your APM participation status alongside your MIPS status.

Volume of Care Determination by CMS

As previously mentioned, your Medicare Part claims and PECOS data are crucial. CMS evaluates this data during two determination periods, each lasting 12 months, to assess the volume of care you provide to Medicare beneficiaries.

Review Period and Eligibility Status

– October 1, 2021, to September 30, 2022: Initial eligibility posted in December 2022
– October 1, 2022, to September 30, 2023: Final eligibility posted in November 2023

Retention of MIPS Eligibility

Your MIPS eligibility is contingent upon your performance. You must exceed the low-volume threshold criteria for MIPS 2023 to maintain your eligibility, which applies to both determination periods.

Various factors may influence your MIPS eligibility. For example, changes in practice affiliation can affect your status. Therefore, regular checks on your MIPS eligibility are recommended. If you do not meet eligibility requirements during the first determination period, you will not participate in MIPS moving forward, and your status will not change in the second determination period. However, there may be scenarios where you can opt to participate in MIPS 2023 as an opt-in participant.

Next Steps

Now is the time to verify your participation status for MIPS 2023. With the submission period underway, enter your NPI in the QPP participation tool to check your MIPS eligibility for the 2023 data submission and the MIPS 2024 performance year.