Medicare Freezes Thresholds for MIPS Exemption
By Joey Berlin


If you’re in a Qualifying Alternative Payment Model (APM) in Medicare’s Quality Payment Program (QPP), or you’re considering making the jump, take note: The thresholds for participating this year are now the same as in 2020 thanks to recent federal law.

The Centers for Medicare & Medicaid Services (CMS) announced that it has frozen the qualifying APM participant thresholds for the 2021 and 2022 performance years, negating previously planned increases to those benchmarks.

To be a fully qualified APM participant, either this year or in 2022, you have the same requirements as in 2020, meaning you must meet one of two criteria:

  • Payment amount: 50% of Medicare Part B payments, or
  • Patient count: 35% of Medicare patients through an advanced APM entity.

To earn partial participation status (meaning you don’t qualify for a 5% APM incentive payment), the thresholds for 2021 and 2022 once again are:

  • Payment amount: 40% of Medicare Part B payments, or
  • Patient count: 25% of Medicare patients through an advanced APM entity.

Those who don’t qualify for full or partial APM participation must join QPP’s Merit-Based Incentive Payment System (MIPS). Physicians required to participate in QPP must do so either through MIPS or an advanced APM. Partial participants can choose to participate through MIPS or through an advanced APM but, as noted, are not eligible for the APM incentive payment. Medicare will use three “snapshot dates” in 2021 to evaluate your data for possible QP status; the first one comes on March 31.

CMS is holding the line on these thresholds thanks to the Consolidated Appropriations Act, the wide-ranging, late-2020 omnibus legislation that also introduced new restrictions on surprise medical billing, supplied COVID-19 relief funding for physicians and others, and reduced the impact of Medicare physician payment cuts.

Medicare assesses QPP payment adjustments two years after the performance year, so payments or penalties for 2021 and 2022 will be assessed in 2023 and 2024, respectively.

Last Updated On

January 22, 2021

Originally Published On

January 22, 2021

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