Merit-based Incentive Payment System (MIPS)

The Medicare Physician Fee Schedule (PFS) regulation makes updates to the Quality Payment Program (QPP), the major quality reporting program for physicians under Medicare. Failure to successfully participate in the Merit-based Incentive Program (MIPS)—the main track within the QPP—could eventually result in a 9 percent reduction to your Medicare payments. We are doing all that we can to simplify the requirements and make it easier to avoid a penalty and even be eligible for a bonus.

Read below about MIPS and what ACEP is doing to help emergency physician successfully participate.

Latest MIPS Updates

Final 2022 Policies

On November 2, 2021, CMS released the CY 2022 PFS and QPP final rule. In this rule, CMS is significantly increasing the requirements with its removal of bonus points and scoring floors and its decision to increase the performance threshold to 75 points and the exceptional performance threshold to 89. CMS expects that many more clinicians will not meet the threshold and will receive a penalty. CMS did decided to finalize an emergency medicine-focused MIPS Value Pathway (MVP) that will start in 2023.

  • For ACEP’s summary of the final rule, please click here.
  • For CMS fact sheets highlighting final MIPS policies, please click here

ACEP Responds to Proposed 2022 Policies

On September 13, 2021, ACEP submitted a comprehensive response to the Centers for Medicare & Medicaid Services’ (CMS’) Calendar Year (CY) 2022 PFS and QPP proposed rule.

Final 2021 Policies

On December 1, 2020, CMS released the CY 2021 PFS and QPP final rule. In this rule, CMS finalizes numerous changes and updates to MIPS, including delaying the transition to MIPS Values Pathways (MVPs).

  • For ACEP’s summary of the final rule, please click here.
  • For CMS fact sheets highlighting final MIPS policies, please click here
  • For an ACEP presentation on the final rule, please click here.

COVID-19 Flexibilities

CMS has announced some needed relief to MIPS reporting requirements due to COVID-19. CMS has created an automatic COVID-19 hardship exemption policy in 2020 and 2021. CMS will create an application-based COVID-19 exemption policy in 2022, but the details of that policy are still pending.


In 2015, Congress enacted the Medicare Access and CHIP Reauthorization Act (MACRA), which created a new physician performance program in Medicare called the Quality Payment Program (QPP). The QPP includes two tracks: The Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs). The Centers for Medicare & Medicaid Services (CMS) within the U.S. Department of Health and Human Services is responsible for operating the program.

Most emergency physicians participate in the first track of the QPP: MIPS. MIPS includes four performance categories: Quality, Cost, Improvement Activities, and Promoting Interoperability (formerly Meaningful Use). Performance on these four categories (which are weighted) roll up into an overall score that translates to an upward, downward, or neutral payment adjustment that providers receive two years after the performance period (for example, performance in 2021 will impact Medicare payments in 2023).

MIPS Impact on Emergency Physicians

Most emergency physicians will need to participate in MIPS to avoid a penalty and perhaps get a bonus. You can report as an individual or as part of a group. For the 2021 performance year, the potential payment adjustments range between -9 and +9 percent. Potential bonuses and/or penalties grow over time, so they can have a major impact on your revenue.

MIPS Value Pathways (MVPs)

CMS has heard feedback, including from ACEP, that MIPS reporting should be streamlined and more meaningful to clinicians. Therefore, CMS will be implementing the MIPS Value Pathways (MVPs), an approach that would allow clinicians to report on a uniform set of measures on a particular episode or condition in order to get MIPS credit. ACEP developed and proposed an emergency medicine-focused MVP, the “

ACEP believes that the emergency medicine-focused MVP will help improve quality of care, reduce costs, and transition emergency physicians to alternative payment models (APMs)—as it aligns with ACEP’s proposed APM, the Acute Unscheduled Care Model (AUCM).

Find Out Whether You’re Eligible

If you see a minimum number of Medicare patients, have a small amount of Medicare charges, or provide a small number of services to Medicare beneficiaries, you may be excluded. You'll need your National Provider Identifier (NPI) number to determine your eligibility.

Find out whether you must report in MIPS

What is ACEP doing?

ACEP continually advocates on behalf of emergency physicians to reduce provider burden and help our members succeed in the program. Every year, CMS updates program requirements through federal regulatory rulemaking and ACEP actively comments on these regulations. A summary of our comments on the last rule that sets policies for 2021 is found below in the Resources section. Also found below is a summary of the final policies CMS has adopted for 2021.

ACEP also provides our members with helpful tools to report in MIPS. Thousands of emergency physicians are now using CEDR to meet the Quality Reporting requirements and participating in E-QUAL to meet the Improvement Activities requirements.

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