All About MIPS 2021 Eligibility, Participation, and Special Status

Medical Practitioners Eligible for MIPS 2021

There is a list of clinicians who can participate in the MIPS 2021. However, the clinicians, who qualify for participation based on the billing for Medicare part B or Critical Access Hospital Method II payments assigned to CAH and meet the Low-Volume Threshold (LVT) 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

There are three reasons for which a healthcare provider cannot take part in MIPS 2021.

APM Participation

Providers who are participating in an APM are exempt from MIPS 2021 reporting.

Low-Volume Threshold (LVT)

The eligibility criterion is that the clinicians who provide care for 200 or fewer Medicare patients can participate in this program. Moreover, this also stands for the clinicians who make $90,000 or less in Medicare beneficiaries in the performance year 2021.

Having said that, below are the thresholds that you cannot miss. In an otherwise case, you cannot participate in the quality payment program.

Newly Enrolled in Medicare

Clinicians who enroll in the current performance year are exempt from performing until the following year.

MIPS Extreme and Uncontrollable Circumstance Policy 2021

This policy is only for clinicians who have gone through natural disasters or are COVID-19 victims. Also, they can claim the hardship exception for all 4 of the performance categories. The deadline for which is 31st December 2021. And, you can do it by filling out an application.

Participants and Reporting Types

The participants in MIPS are of three types.

Individuals
Groups
Virtual Groups

All of the above-mentioned entities have to perform the activities. However, they have an allotted period to submit their reports.

Having said that, a participant can either take part as an individual or as part of a group for all activities in MIPS 2021. And, they cannot choose to report some as an individual and others as part of a group.

Individuals Reporting

Individual clinicians who are eligible for participation can submit data for each of the four QPP MIPS categories. However, they can only report for the category they choose to submit. After that, CMS measures their MIPS scores and payment adjustments accordingly.
Individual clinicians using more than one Tax Information Number (TIN) can report MIPS data 2021 through each number. And they will receive MIPS scores and payment adjustments for each TIN/NPI combination.

Group Reporting

A group will be marked as a group for each of the four MIPS categories. Moreover, they will also be recognized as a group for the categories they choose to attest to.
Their data is collected at the group level for each category and then reported, which will give them an overall MIPS score.
An organization (MIPS Qualified Registry), submitting their group’s MIPS data must include information from all clinicians in the group, including the ones who are otherwise individually excluded from MIPS due to either low volume, newly-enrolled Medicare status, or QPP status from an Advanced APM.
Some clinician types, such as hospital-based or non-patient-facing ones are exempted to report as a group for the PI category. Although, they can report data for other categories.

Virtual Group Reporting

Virtual Groups are composed of individuals and groups. Generally, they consist of ten or fewer clinicians, who are eligible to participate in MIPS.
An individual or group can only participate in one virtual group in any performance period. However, there are no limits on how many members a Virtual Group can have for MIPS 2021 reporting.
If a group chooses to join a virtual group, all of the eligible clinicians in that group have to be included as well.
Clinicians in a virtual group will report as part of it across all four performance categories. Moreover, they have the option to report for the categories they choose to report.
Most MIPS group scoring rules apply to virtual groups. So they have to fulfill the same categorical requirements as non-virtual MIPS groups.
Solo practitioners and groups who want to form a virtual group must go through an election process. And, it must happen before the start of the performance period MIPS 2021. Also, it cannot change once the performance period has started.

For example, the election period was from 11th October to 31st December 2020 for the 2021 MIPS performance period.

To participate in MIPS as a virtual group for the 2021 performance period, you can submit an election application to CMS by e-mail until 31st December 2020.

Special Status Designations

Special status designations make things a little easier for MIPS participants who qualify for them. It allows eligible clinicians to flexibly participate in the incentive payment program. Also, they can accomplish the same goals and meet their targets.

There are different designations for different participants. And those who fit the bill can submit a fewer number of activities per category.

Clinicians who are usually eligible for these designations are,

Ambulatory Surgery Center (ASC)-based
Hospital-based
Non-patient facing
Identify as a small practice
Health Professional Shortage Area (HPSA)
Rural

Conclusion

MIPS 2021 performance period is a special year, considering the transition from peak-COVID to post-COVID period. So, this article briefs a little about the QPP MIPS 2021 reporting exclusions, participations criteria, and special status designations. Here you can learn more about them and start with the reporting process. As a result, you can enjoy a seamless MIPS 2021 reporting process.