MIPS 2020: Proposed Rule

On July 29, 2019, the Centers for Medicare and Medicaid Services (CMS) released the proposed rule for services paid under the Medicare Physician Fee Schedule and Other Changes to Part B Payment Policies as well as Updates to the Quality Payment Program. The latter would include the Merit-Base Incentive Payment System (MIPS). Remember that only physical therapists (PTs), occupational therapists (OTs) and speech-language pathologists (SLPs) that practice in a private practice (submit claims on a 1500-claim form to the Medicare program) are eligible to participate in MIPS. This would include a therapist owned private practice or a physician owned private practice. PTs, OTs and SLPs in all other practice settings are not eligible to participate in MIPS.

For performance period (PP) 2020, CMS estimates that approximately 818,000 clinicians would be MIPS eligible clinicians. PP 2020 score will impact the MIPS eligible Medicare payment in payment year (PY) 2022. CMS is estimating that MIPS payment adjustments will be approximately equally distributed between negative MIPS payment adjustments ($584 million) and positive MIPS payment adjustments ($584 million) to MIPS eligible clinicians, as required by the statute to ensure budget neutrality.

Beginning with performance period 2021, CMS is proposing to apply a new MIPS Value Pathways (MVP) framework. The MVP framework would connect measures and activities across the 4 MIPS performance categories, incorporate a set of administrative claims-based quality measures that focus on population health, provide data and feedback to clinicians, and enhance information provided to patients. CMS believes the MVPs will reduce the complexity of the MIPS program and the burden to participate. To read about MVPs, click

Proposed Weights by MIPS Performance Category for the 2022 through 2024 MIPS Payment Years

Performance Category       2022 MIPS Payment Year      2023 MIPS Payment Year       2024 MIPS Payment Year