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

CMS Finalizes 2021 MIPS Policies

On December 1, 2020, the Centers for Medicare & Medicaid Services (CMS) released a Medicare annual payment rule for calendar year (CY) 2021 that impacts payments for physicians and other health care practitioners. In this rule, CMS finalizes numerous changes and updates to MIPS, including delaying the transition to MIPS Values Pathways (MVPs). The rule also makes some modifications to the four performance categories, the overall performance threshold, and to reporting requirements for qualified clinical data registries (QCDRs)—which directly affect ACEP’s QCDR the Clinical Emergency Data Registry (CEDR).

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

COVID-19 Flexibilities

CMS has announced some needed relief to MIPS reporting requirements due to COVID-19. 

2020 Performance Period

CMS announced on June 24 that you can submit an application to have your MIPS Quality, Cost, Improvement Activities, and/or Promoting Interoperability performance categories reweighted to 0% due to COVID-19. 

Specifically, if the COVID-19 pandemic prevents you or your group from collecting 2020 MIPS performance period data for an extended period of time, or could impact your performance on cost measures, you can submit an extreme and uncontrollable circumstances application through February 1, 2021 (CMS extended this deadline from December 31, 2020).

On July 13, ACEP had a call with CMS to find out more about the hardship exemption application process.

  • CMS stated on the call that the agency is being extremely flexible of granting hardship exemptions due to COVID-19. In the application, there is an open text box that allows you or your group to explain why you are requesting a hardship exemption. CMS told ACEP that as long as you include as part of your rationale that you are claiming the hardship exemption because of your inability to report due to “COVID-19” or the “coronavirus,” CMS will most likely grant your exemption request. CMS did note that the operative words to use in your application are “COVID-19” and “coronavirus.” CMS will not be requiring you to submit documentation and is trying to make the application process as easy as possible.
  • CMS stated that it will likely approve individual hardship exemptions within 24 to 48 hours after the request is submitted. As stated above, you can apply for the hardship exemption now until the end of the calendar year.
  • CMS did say that if you claim a hardship exemption and then still submit data, it will score the data submitted and override the hardship exemption. For example, if you submit a hardship exemption for all four MIPS performance categories (and it is approved), but then decide to submit data on two performance categories later on, CMS will use the data submitted to determine a MIPS performance score.

For more information on submitting a hardship exemption for the 2020 performance period, and to apply, please go to CMS’ website here.  

This MIPS relief was one of the major requests that ACEP included in our letter to the Secretary of the Department of Health and Human Services (HHS) on March 13th.

2021 Performance Period

CMS recently decided to extend the COVID-19 hardship exemption policy available in 2020 into 2021 as well.

Your 2019 MIPS Results are Available

CMS has released 2019 Merit-based Incentive Payment System (MIPS) performance feedback and final scores. Your performance in 2019 affects your Medicare payments in 2021. 

If you submitted data for the 2019 performance period, you can view your MIPS performance feedback and final score on the Quality Payment Program website

You can access your 2019 MIPS performance feedback and final score by:

  • Going to gov/login
  • Logging in using your HCQIS Access Roles and Profile (HARP) system credentials; these are the same credentials that allowed you to submit your 2019 MIPS data

The final scores you receive in 2019 affect your Medicare payments in 2021.  Since MIPS adjustments are made in a budget neutral way, and many clinicians were held harmless from negative adjustments in 2019 due to the COVID-19 pandemic, the amount available for bonuses is very small.  If you achieved a perfect score of 100 percent in 2019, you will only receive a 1.78 percent positive adjustment to your Medicare claims in 2021.

To learn more about performance feedback, review the 2019 MIPS Performance Feedback Resources.

A fact sheet explaining the MIPS adjustments can be found here.


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. CMS previously indicated that the first set of MVPs would be introduced in 2021. However, due to the COVID-19 pandemic, CMS is postponing MVPs to at least 2022. ACEP is working on developing an emergency-medicine focused MVP.

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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