Physicians Advocacy Institute

Frequently Asked Questions Updated for 2020


5. Am I required to participate in the Quality Payment Program (QPP) at all?

  • If you are a physician who provides services to patients that you bill for under the Medicare Physician Fee Schedule (i.e., if you see “traditional” Medicare patients), you are likely subject to the QPP.
    The following are considered “eligible clinicians” subject to the QPP (MIPS or Advanced APM):
    • Physicians, including doctors of: medicine, osteopathy, osteopathic practitioners, dental surgery, dental medicine, podiatric medicine, optometry, and chiropractors
    • Physician Assistants
    • Nurse Practitioners
    • Clinical Nurse Specialists
    • Certified Registered Nurse Anesthetists
    • Physical Therapists
    • Occupational Therapists
    • Qualified Speech-Language Pathologists
    • Qualified Audiologists
    • Clinical Psychologists
    • Registered dietitian or nutrition professionals

    The following eligible clinicians are exempt from participation in MIPS:
    • Newly-enrolled Medicare eligible clinicians who enroll in Medicare for the first time during the performance year
    • Eligible clinicians and groups that are below the low-volume threshold :
      • Who have Medicare Part B allowed charges ≤ $90,000
      • Who provide care to 200 or fewer Medicare Part B patients; AND,
      • Provide 200 or fewer covered professional services to Part B patients

      Your practice should receive a notification letter from CMS about whether you individually and your group are exempt due to the low-volume threshold. Additionally, use the CMS NPI lookup tool to help you determine your eligibility. To use the tool, you will need to know your 10-digit national provider identification (NPI) number.
    • Eligible clinicians who are participating in Advanced APMs

    If you are not exempt, you must participate in the QPP to avoid a -9% payment adjustment of your 2022 Medicare reimbursements. To learn more about the 2020 participation options, see the resources available on PAI’s QPP Resource Center.

    Continuing to 2020, you do have the option to elect to opt-in if you exceed one or two of the three low-volume thresholds for MIPS. If you elect to opt-in, you will receive a payment adjustment (which can be both positive, neutral, or negative) in 2022, like other providers who are mandated to participate. You also have the option to voluntarily report MIPS performance measures in 2020 if you meet at least one of the low-volume thresholds. Voluntarily reporting will not trigger a payment adjustment in 2022. Furthermore, those who voluntarily report will still receive performance feedback from CMS, which may help prepare you for future years.  

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