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 result in a 9 percent reduction to your Medicare payments. 

ACEP is 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 physicians 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

Proposed 2023 Policies

On September 6, 2022, ACEP responded to the CY 2023 PFS and QPP proposed rule. The 2023 performance year is the first year of a new reporting option in MIPS called the MIPS Value Pathways (MVPs). MVPs represent an approach that will allow clinicians to report on a uniform set of measures on a particular episode or condition in order to get MIPS credit. ACEP developed an emergency medicine-focused MVP that CMS will be including in the first batch of MVPs starting in 2023. 

Due to the COVID-19 public health emergency, hardship exemptions have been in place for the 2019, 2020, 2021, and 2022 MIPS performance periods. Therefore, for some clinicians, 2023 may be the first time they participate in MIPS in four years. 

  • For ACEP’s summary of proposed rule, please click here.
  • For CMS fact sheets highlighting proposed MIPS policies, please click here
  • For a summary of ACEP’s response to the proposed rule, please click here.
  • For ACEP’s complete response to the proposed rule, please click here

COVID-19 Flexibilities

CMS has announced some relief to MIPS reporting requirements due to COVID-19. CMS has created an automatic COVID-19 hardship exemption policy in 2019, 2020, and 2021. CMS has also created an application-based COVID-19 exemption policy in 2022. 


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 2023 will impact Medicare payments in 2025).

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 2023 performance year, the potential payment adjustments range between -9 and +9 percent. 

MIPS Value Pathways (MVPs)

CMS has heard feedback, including from ACEP, that MIPS reporting should be streamlined and more meaningful to clinicians. Starting in 2023 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 “Adopting Best Practices and Promoting Patient Safety within Emergency Medicine 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. 

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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