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MIPS Updates for Independent Primary Care Practices


We’re starting a new series of blog posts on important health care policy issues that are important for independent primary care physicians. We’re calling it “The Primary,” because we believe primary care should be the center of all health care policy, and we hope it will serve as a partner blog to our collection of stories from Elation primary care physicians, “The Practice.” Health care policy at the federal level affects everything primary care physicians do, and at Elation we want to help you navigate this changing and complex landscape. Please let us know if this is helpful to you, and please send us your feedback and questions at

The Primary: The Centers for Medicare & Medicaid Services’ (CMS) Quality Payment Program (QPP) is an incentive system tied to clinical quality measures for physicians and clinicians who participate in the Medicare program. Within QPP, the Merit-based Incentive Payment System (MIPS) applies to all physicians and clinicians who have not opted in to an Alternative Payment Model (APM), a specific type of value-based care payment model, such as Comprehensive Primary Care Plus or Primary Care First. Recent updates to the MIPS program are of special importance to independent primary care physicians and clinicians.

Background: QPP and MIPS were created by law and began in 2017, and the program has evolved each year. Through MIPS, physicians and clinicians can receive a negative, neutral, or positive payment adjustment based on their performance in the program, which is designed to be budget neutral for Medicare. In 2018, Medicare had $500 million to distribute, and 98% of MIPS-eligible clinicians received a positive payment adjustment with scaling to achieve the necessary budget neutrality of the program). 

What Are the Issues?

  • The COVID-19 pandemic meant that every individual MIPS-eligible clinician was automatically granted the MIPS Extreme and Uncontrollable Circumstances (EUC) policy for the 2020 performance year:
    • Virtual Groups and APM entities had an extended period of time to apply for the EUC exception, until March 31, 2020. It is likely that most MIPS-eligible clinicians will fall into the EUC Exception category, and they will have all four MIPS performance categories re-weighted to 0% of their final score, unless they choose to submit data for two or more performance categories. 
    • This will result in a neutral payment adjustment (from guidance for the 2021 performance year), which means that each covered professional service furnished in 2020 will be reimbursed 100%, with no additional increase or decrease to the paid amount. 
  • The Future of MIPS and MIPS Value Pathways (MVPs):
    • Before the COVID-19 pandemic, CMS was working towards the next iteration of MIPS, through the MVPs Framework. MVPs are designed to align and connect measures and activities across the different MIPS categories: Quality, Cost, Improvement Activities, and Promoting Interoperability performance categories for different specialties and conditions. The evolution towards MVPs would have brought MIPS and APMs even closer together. Now, the MVPs rollout has been delayed, and will not be implemented as a reporting option for the 2021 performance period, but is still planned for the 2022 performance period.
    • This delay means that there is still time to submit MVPs candidates for consideration by CMS for the upcoming performance period, via the templates provided. CMS needs to hear from the independent primary care community about the alignment of care, quality, and value that matters in primary care. 

What’s Next?

Read More:

What’s the Quality Payment Program?

Participation Options Overview

MIPS Value Pathways (MVPs)