The Basic of MIPS: FAQs

MIPS Overview Basics
  • What is MIPS?
    • MIPS stands for the Merit-based Incentive Payment System. MIPS is a Centers for Medicare and Medicaid (CMS) sponsored healthcare reimbursement model to pay clinicians for the services they provide to patients billed under Medicare Part B.  MIPS is one of two types of reimbursement models offered under the CMS Quality Payment Program (QPP). Under MIPS clinicians receive a payment adjustment for Medicare Part B covered professional services based on CMS’s evaluation of their performance across four different performance categories.

·      Who participates in MIPS?

  • MIPS applies to providers who bill for professional services under Medicare Part B via the Physician Fee Schedule. CMS has identified a list of eligible clinician types who are subject to participating in the QPP.  The list of eligible clinician types can be found here in the QPP website.  Physical Therapists, Occupational Therapists, and Speech and Language Pathologists are all eligible clinician types under the MIPS program.
  • If you are a MIPS eligible clinician type, are you required to participate in MIPS?
    • If you are an eligible clinician type, then CMS will determine your eligibility status based on the volume of services you provide to Medicare B beneficiaries over a consecutive two-year period, also known as the MIPS determination period. Your eligibility is based on your National Provider Identifier (NPI) and associated Taxpayer Identification Numbers (TINS).  CMS evaluates each TIN / NPI combination for MIPS eligibility.  Click here to learn more about MIPS eligibility.

  • How is reimbursement determined under MIPS?
    • MIPS uses a scoring methodology to determine reimbursement based on the clinician’s performance in four categories over a 12-month period. The four categories that CMS reviews to calculate the clinician’s score are: Promoting Interoperability, Cost, Quality, and Improvement Activities.
    • The clinician’s performance in these categories will determine whether he / she receives a positive, neutral, or negative percentage payment adjustment applied to future Medicare Part B service payments.
    • Physical Therapists, Occupational Therapists, and Speech and Language Pathologists are only scored on two of the four performance categories, Quality and Improvement Activities. Click here to learn more about the 2022 Quality Performance Category MIPS requirements. Click here to learn more about the 2022 Improvement Activities MIPS requirements.
Eligibility and Low Volume Threshold
  • How do I know if I am a MIPS Eligible clinician? 
    • You should check your eligibility status in the Quality Payment Program website under Here you will enter in your 10-digit National Provider Identification (or NPI) number to find information related to your MIPS participation status for each associated practice. Clinicians are considered MIPS Eligible if they are an eligible clinician type and meet the MIPS low-volume threshold.

  • What is the MIPS low-volume threshold?
    • A clinician who meets the following three criteria, also known as the low-volume threshold, is required to participate if during both segments of the determination period the clinician has: 
      • billed more than $90,000 in Part B allowable charges; and
      • evaluated and/or treated more than 200 unique Medicare beneficiaries; and
      • provided more than 200 covered professional services under the Medicare Physician Fee Schedule.

    • Is the low-volume threshold based on Medicare B claims only, or does it include all claims?
      • The low-volume threshold pertains only to Medicare Part B claims.

    • Is the low-volume threshold the same for all providers?
      • Yes, the low-volume threshold is the same for all clinicians across all specialties.

    • If I do not meet the low-volume threshold criteria, can I still participate in MIPS?
    • Yes, clinicians may still participate in MIPS if they meet 1 or 2 (but not all 3) of the low-volume threshold criteria by opting-in or voluntarily reporting data to CMS for MIPS (please see the “Opting in and Voluntarily Reporting” section of this document for further details).
  • Are institutional providers such as hospital-based outpatient departments (CORFs), or Rehab Agencies (ORFs) able to participate in MIPS?
    • Currently, participation and performance in MIPS are identified and tracked via the therapist’s NPI number as it appears on the claim. Services billed to Medicare Part B by institutional providers (via the UB-04) do not contain the individual therapist’s NPI number as it does on professional claims (e.g., the CMS 1500 or 837p), therefore clinicians treating beneficiaries in these settings will not be able to participate in MIPS until CMS changes the method by which it judges the performance for clinicians or changes the claim format for institutional providers.

  • Are new providers eligible to participate in MIPS?
    • No, providers who are newly enrolled in Medicare during the performance year are not eligible to participate in MIPS.
  • What are the ways I can participate in MIPS?
    • There are three ways to participate in the MIPS program: Reporting as an individual, as part of a group, or as part of a virtual group.
Keet Outcomes Reporting
  • What is the Keet Outcomes QCDR data completeness standard and how it is measured?
  • The Keet Outcomes data completeness standard requires that a baseline PRO is collected on each patient that qualifies for MIPS submission. This reporting standard is part of our responsibility as stewards of the Quality Payment Program to ensure that each patient’s initial performance is captured from which quality performance can accurately be measured over time and ensures that clinicians are capturing assessment information on all patients that qualify for MIPS.  Keet data completeness requirements are met when at least one PRO has been collected, or if the patient is identified as other, is disqualified, or meets any other exclusion criteria.  Keet dashboard reports include information regarding adherence to the Keet data completeness standard to allow for actionable insights in near real time.
Individual Reporting
  • What does it mean to report as an individual?
    • An individual is defined as a single clinician, identified by their individual National Provider Identifier (NPI) tied to a single Taxpayer Identification Number. If you report only as an individual, you will report on the applicable MIPS performance categories for your clinician type, and your payment adjustment will be based on your final score based on your performance in these categories. 

  • What criteria do I need to meet to report as an individual?
In order to be MIPS eligible as an individual clinician, you must: be identified as a MIPS eligible clinician type on Medicare Part B claims, have enrolled as a Medicare provider before 2022, not be a qualifying alternative payment model participant (QP), and you must exceed the low volume threshold as an
Group Reporting
  • What does it mean to report as a group?
    • A group is defined as a single TIN with 2 or more clinicians (at least one clinician within the group must be MIPS eligible) as identified by their NPI, who have reassigned their Medicare billing rights to a single TIN.

  • How does CMS determine if a practice is eligible to participate in a group?
    • CMS reviews the practice’s Medicare B claims during the MIPS Determination Period to evaluate if the practice exceeds the low-volume threshold criteria. To be eligible for MIPS, the practice must exceed all 3 of the low volume threshold criteria during both 12-month segments of the MIPS determination period at the group level. If the practice exceeds some, but not all, of the low-volume threshold criteria the practice may be eligible to opt-in or voluntarily report as a group for MIPS. For more information on group participation options, please see the CMS MIPS Group Participation User Guide.

  • If we choose to report as a group, does every provider in the group TIN have to participate, even if they would not have to based on the individual criteria?
    • Per the CMS MIPS Group Participation User Guide (p. 20), if you choose to participate in MIPS as a group, you will need to collect and submit the available data from all of the clinicians in your group as appropriate to the quality measure and improvement activities that you select. This includes the data of clinician that are not eligible for MIPS or a MIPS payment adjustment.
  • Can I participate as both an individual and as a group?
    • Yes, clinicians can report data as an individual and as part of the group under the same TIN. In this instance, the clinician will be evaluated for his / her performance on the individual and group level and will receive a payment adjustment based on the higher of the two scores.
  • What does it mean to participate as a virtual group?
    • A virtual group is defined as a combination of 2 or more TINS assigned to 1 or more solo practitioners (who are also MIPS eligible clinicians) or to 1 or more groups consisting of 10 or fewer eligible clinicians (including at least 1 MIPS eligible clinician), or both, that elect to form a virtual group for the performance year. Additional information on virtual group participation is available in the CMS Virtual Groups Toolkit.

  • How is the group assessed on their performance?
    • If you participate in a group CMS will assess your performance across all applicable performance categories at the group level, and your payment adjustment will be based on your group’s final score based on the group’s performance in these categories.
Opt-In Voluntary Reporting
  • What is the difference between voluntary reporting and opting in?
    • Providers who opt in are choosing to participate in MIPS will be assessed in the same manner as providers who are required to report. If you choose to opt into MIPS, you will:
      • Be considered a MIPS eligible clinician and will be required to report data to MIPS
      • Receive feedback on your performance in the MIPS performance categories
      • Receive a MIPS positive, neutral, or negative payment adjustment
      • Be eligible to have your data published on the CMS Care Compare website, and
    • This CMS video explains how to report MIPS data as an opt-in eligible clinician, and can be found –with additional information about opt-ing into MIPS – in the QPP resource library website.
    • Providers who voluntarily report will receive feedback from CMS regarding their performance in the MIPS performance categories and will be eligible to have data published on the CMS Care Compare website, but they are not eligible to receive a payment adjustment and their data will not be included in the calculation of MIPS measure benchmarks. If you voluntarily report, you are essentially participating in a “practice” version of MIPS to prepare for future years.  

  • How and when do I submit my decision to Opt-in or voluntarily report in the MIPS program?
    • A clinician or group is required to complete their voluntary reporting election or Opt-in election during the submission period before submitting data to CMS. Once made, the election to voluntarily report or to Opt-in is final and cannot be reversed.  The submission period for each performance year can be found on the QPP website at
Performance Categories: Quality
  • What does the MIPS Quality Measure performance category assess?
    • The MIPS Quality performance category assesses the quality of care that clinicians deliver based on select performance metrics created by CMS and by other medical professional stakeholder groups. Quality measures are tools that are used to measure health care outcomes and patient experiences of their care.

  • What are the reporting requirements for the Quality performance category?
    • Clinicians must report a minimum of 6 quality measures – one of which must be an outcome measure or other high priority measure if an outcome measure is not available – on ≥ 70% of all eligible patients (those patients who qualify for the measure), regardless of payer.

  • What types of Quality measures are available to report on?
    • There are two types of Quality Measures: Outcome and Process. Outcome Measures measure the resulting clinical outcome of the services provided by the practitioner.  Process Measures inform on the processes or steps providers take during a patient encounter and / or during the patients’ course of treatment to manage their care. It is important to note that in 2019 CMS announced that they are “implementing an approach to incrementally remove process measures” as documented in this category fact sheet published by CMS (p. 6). 
    • Patient-reported outcome measures (PROs) are a specific type of outcome measure where the outcome is based on the patient’s perspective and how meaningful the outcome was relative to their specific interests and functional activities, and are considered high priority measures for MIPS. The Keet Outcomes QCDR supports the following patient-reported outcome measures (PROs) that are well known and widely used in the healthcare industry:
      • Lower Extremity Functional Scale (LEFS)
      • Knee Outcome Survey (KOS)
      • Disabilities of the ARM, Shoulder, and Hand (Quick Dash)
      • Neck Disability Index (NDI)
      • Modified Low Back Pain Disability Questionnaire (MDQ)
      • Numeric Pain Rating Scale (NPRS)
      • Dizziness Handicap Index (DHI) *New for 2022
    • For more information about the MIPS Quality performance category, please reference the 2022 Quality Requirements on the QPP website or the CMS published MIPS Quality Quick Start Guide.


Performance Categories: Improvement Activities
  • What does the MIPS Improvement Activities performance category assess?
    • The MIPS Improvement Activities category assesses how the clinician or group of clinicians improve clinical practice and care processes that enhance patient engagement and increase access to care.

  • What are the reporting requirements for the Improvement Activities performance category?
    • Reporting Improvement Activities involves attesting to CMS that the eligible clinician completes the same improvement activities for 90-continuous day during the performance year; for groups and virtual groups, at least 50% of eligible clinician with the TIN must perform the same Improvement Activity for 90-continuous days at some point during the performance period.

  • What types of Improvement Activities are available with Keet?
    • The Keet QCDR supports multiple improvement activities that inherently allow clinicians to receive a maximum score because they are demonstrated through the use of the Keet application. These include:
      • Collection and follow-up on patient experience and satisfaction data on beneficiary engagement
      • Participation in a QCDR, that promotes use of patient engagement tools.
      • Participation in a QCDR, that promotes collaborative learning network opportunities that are interactive.
      • Improved Practices that Engage Patients Pre-Visit.
    • For more information about the MIPS Improvement Activities performance category, please reference the 2022 Improvement Activities Requirements on the QPP website or the CMS published MIPS Improvement Activities Quick Start Guide.
MIPS Scoring and Payment Adjustments
  • How is the clinician’s performance scored in MIPS?
    • With MIPS, performance is scored via a point system. For Physical Therapists, Occupational Therapists, and Speech and Language Pathologists, points are awarded based on how the clinicians perform in the Quality and Improvement Activities Categories. Quality is weighted so that it contributes to 85% of the final score, while Improvement Activities make up 15% of the final score.  The final score is the sum of the weighted scores from each category and can range from 0 to 100 points.

  • What does the score mean?
    • The score will determine whether a clinician receives a positive, neutral, or negative percentage payment adjustment that will be applied to future Medicare Part B Physician Fee Schedule payments in the second calendar year after the performance year (i.e., the clinician’s performance in 2022 will determine the payment he / she receives in 2024).

  • What is the minimum score I need to avoid a negative payment adjustment?
    • For 2021, the performance threshold is set to 60 points. The performance threshold is the number of points required to achieve a neutral payment adjustment.  Scores below 60 points will result in negative payment adjustments, scores above 60 points will result in positive payment adjustments.

    • For 2022, the performance threshold is set to 75 points. The performance threshold is the number of points required to achieve a neutral payment adjustment.  Scores below 75 points will result in negative payment adjustments, scores above 75 points will result in positive payment adjustments.
  • How do I earn points under the Quality Performance Category?
    • A MIPS eligible clinician or group must submit at least 6 quality measures to be scored under the Quality Performance Category. CMS will award points based on performance and other factors, such as the type of outcome measures submitted; for example, the high priority measures offered through Keet receive more points.
    • Each quality measure can receive up to 10 points, therefore the maximum number of points that can be achieved is 60 points. More than 6 quality measures can be submitted for CMS review, however only 6 measures will count towards the final score. If more than 6 measures are submitted, CMS will count the six highest scoring submissions.
    • Beginning in the 2022 performance year, there are no bonus points available for additional outcome and high priority measures or measures that meet end-to-end electronic reporting criteria. Small practices (15 or fewer clinicians, reporting individually, as a group, virtual group, or APM Entity) that submit at least one quality measure will continue to earn 6 bonus points, which will be added to their quality performance category score.

  • How do I earn points under the Improvement Activities Category?
    • There are two types of Improvement Activities: High weighted and medium-weighted. High-weighted activates earn 20 points, medium-weighted activities earn 10 points. Clinicians can report on any combination of 1 to 4 improvement activities meaningful to their practice to achieve the maximum 40 points as follows:
      • two high-weighted activities, 
      • one high-weighted activity and two medium-weighted activities, or 
      • four medium-weighted activities. 
    • Small practices, however, only need to attest to 20 points’ worth of activities, and can achieve the maximum points as follows:
      • one high-weighted activity, or
      • two medium-weighted activities.
    • Improvement Activities are inherently demonstrated through the use of Keet, therefore clinicians using the Keet Health application will automatically achieve the maximum points available under the Improvement Activities performance category.

    • What is the Exceptional Performance Bonus?
      • The Exceptional Performance bonus allows for up to a 10% increase beyond the positive payment adjustments earned, via achieving a total score of 89 points or higher. Following the 2022 performance year, the additional bonus for exceptional performance will no longer be awarded.
For more information about MIPS scoring, please reference the CMS published MIPS Scoring Guide.
MIPS Reporting Requirments: Minimum Case Volume and Data Completeness
  • Since this is a Medicare program, do I only collect information on Medicare patients?
    • No, since MIPS focuses on improving the overall quality and value of care in the broader healthcare industry CMS mandates that data must be collected on all patients across all payers, not just Medicare beneficiaries. As such, you should assign and collect patient-reported outcomes for all patients in your practice that qualify for the measure.

  • What is Minimum Case Volume?
    • Minimum case volume is the minimum volume of eligible cases you must report on for each quality measure for CMS to have enough data for it to be reliably assessed. The current case minimum is set at 20 cases.
  • What is Data Completeness and how is it calculated?
Data completeness refers to a minimum reporting standard that CMS has established for reporting quality performance data. For the 2022 performance period (January 1-December 31, 2022), clinicians must report data on a minimum of 70% of the patients who qualify for each measure regardless of payer. Patients who do not qualify for the measure, because they are part of the exclusion or exception criteria, will not count towards the total patient population on which the 70% is calculated from.