Medicare QPP

Physicians Advocacy Institute

These resources have not been updated since 2023 but the general details remain relevant. For a summary of the key changes for CY 2024, please click here.

Frequently Asked Questions Updated for 2023


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, dental surgery, dental medicine, podiatric medicine, and optometry)
    • Osteopathic Practitioners
    • Chiropractors
    • Physician Assistants
    • Nurse Practitioners
    • Clinical Nurse Specialists
    • Certified Registered Nurse Anesthetists
    • Physical Therapists
    • Occupational Therapists
    • Clinical Psychologists
    • Qualified Speech-Language Pathologists
    • Qualified Audiologists
    • Registered Dietitian or Nutrition Professionals
    • Clinical Social Workers
    • Certified Nurse Midwives

    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 OR
      • Who provide care to 200 or fewer Medicare Part B patients; OR
      • Provide fewer than 200 covered professional services to Part B patients.

      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 2025 Medicare reimbursements. To learn more about the 2023 participation options, see the resources available on PAI’s QPP Resource Center.

    Continuing in 2023, 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 2025, like other physicians who are mandated to participate. You also have the option to voluntarily report MIPS performance measures in 2023 if you meet at least one of the low-volume thresholds. Voluntarily reporting will not trigger a payment adjustment in 2025. Furthermore, those who voluntarily report will still receive performance feedback from CMS, which may help prepare you for future years.  

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