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MIPS Reporting & Quality Payment Program Compliance

MIPS Reporting Services That Protect Your Medicare Reimbursements.

The Merit-based Incentive Payment System (MIPS) ties a direct percentage of your Medicare reimbursements to annual performance reporting. A missed measure, documentation gap, or late submission does not just affect your score — it reduces every Medicare payment your practice receives for an entire calendar year.

MedVersify manages the full MIPS reporting lifecycle — eligibility assessment, measure strategy, year-round performance tracking, and CMS submission — so your practice earns positive adjustments rather than absorbing preventable penalties.

What a Compliance Review Covers

Before any reporting begins, we assess your current MIPS exposure and identify the specific gaps and opportunities in your performance position.

  • MIPS eligibility status at TIN/NPI level
  • Current performance year payment adjustment risk
  • Quality measure selection benchmarked against CMS performance data
  • PI category EHR certification and compliance review
  • Improvement Activities aligned with your existing clinical workflows
  • Specialty measure set identification and scoring optimization
Schedule My Free Compliance Review

No obligation · CMS-aligned · Response within 24 hours

Up to 9%

Medicare Penalty Risk

Maximum negative payment adjustment

75 pts

Performance Threshold

Through 2028 performance year

2-Year

Payment Lag

Performance year to payment adjustment

11.92%

Receive Penalties

Of all eligible clinicians (CMS estimate)

Understanding MIPS

What Is MIPS and Why Does It Affect Your Revenue?

MIPS — the Merit-based Incentive Payment System — is a CMS program under the Quality Payment Program (QPP) created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). It determines whether eligible Medicare clinicians receive a positive, neutral, or negative adjustment to their Medicare Part B reimbursements based on annual performance reporting.

Unlike a voluntary quality program, MIPS directly ties a percentage of your Medicare income to compliance. The adjustment — currently up to ±9% — applies across all Medicare Part B payments for an entire calendar year. For a practice with meaningful Medicare volume, that is not a marginal impact.

The performance year and the payment year are offset by approximately two years. Data collected in 2026 is submitted by March 31, 2027, and the resulting adjustments are applied to 2028 payments. This lag means the financial consequences of poor performance are often invisible until they arrive.

Who must report: Clinicians billing more than $90,000 in Medicare Part B charges, seeing more than 200 Medicare patients, and providing more than 200 covered professional services are required to participate. Eligibility is assessed at the TIN/NPI level.

Key MIPS Terms

QPP

Quality Payment Program — the CMS framework under MACRA that encompasses MIPS and other Medicare payment programs.

MIPS

Merit-based Incentive Payment System — the reporting and scoring program that generates positive, neutral, or negative Medicare payment adjustments.

Performance Threshold

The minimum score to avoid a negative adjustment. Set at 75 points through the 2028 performance year.

Exceptional Performance

A higher score threshold above which clinicians earn an additional bonus from a separate CMS incentive pool.

Data Completeness

The requirement that 75% of eligible patients or encounters be included in Quality measure reporting. Below 75% = zero points for that measure.

TIN/NPI

Tax Identification Number / National Provider Identifier. MIPS eligibility is assessed at the TIN/NPI level — each combination is evaluated separately.

Payment Year

The year in which MIPS adjustments are applied. Approximately 2 years after the performance year ends.

Security Risk Analysis

A mandatory attestation within the Promoting Interoperability category. In 2026, requires two separate "Yes" confirmations or the entire PI category scores zero.

Payment Adjustment Outcomes

How MIPS Scores Translate to Payment Adjustments

Every MIPS-eligible clinician receives one of four payment outcomes based on their final performance score. The 75-point threshold is maintained through the 2028 performance year. CMS estimates that 11.92% of eligible clinicians receive a negative adjustment for the 2026 performance year.

The 2-year lag effect: Payment adjustments from the current performance year will not appear in your Medicare payments for approximately two years. Most practices do not realize they have been penalized until the adjustment is already being applied — at which point the performance year causing it has already passed.

Below 18.75 pts−9%

Maximum Penalty

Providers scoring below 18.75 receive the maximum negative adjustment — currently up to 9% — applied to every Medicare Part B payment across the full calendar year.

18.75 – 74 ptsNegative

Partial Penalty

Scores between the low-volume threshold and the 75-point performance threshold result in a negative payment adjustment, scaled proportionally to performance.

75 pts (Exact)Neutral

No Adjustment

Scoring exactly at the performance threshold results in no payment adjustment in either direction. The threshold is set at 75 points through the 2028 performance year.

76 – 100 ptsPositive

Positive Adjustment

Scores above the 75-point threshold earn a positive payment adjustment, with the size of the bonus determined by the performance funding pool each year.

Exceptional PerformanceAdditional Bonus

Additional Incentive

Clinicians who score above the Exceptional Performance threshold (currently set annually by CMS) are eligible for an additional positive adjustment from a separate incentive pool.

The Four Performance Categories

What MIPS Actually Measures — All Four Categories Explained

MIPS performance is calculated across four weighted categories. Each has different requirements, timelines, and scoring logic. Missing requirements in any category creates scoring gaps that directly affect your final payment adjustment.

Quality

30% of final score

Report 6 measures (including at least one outcome or high-priority measure) for the full 12-month performance period. Scored against CMS benchmarks on a 1–10 point scale per measure. Data completeness threshold: 75% of eligible patients.

  • 195 measures available for the 2026 performance year
  • At least one outcome or high-priority measure required
  • Full-year data collection (January 1 – December 31)
  • 75% data completeness requirement per measure
  • Benchmarked against national performance data
  • Specialty measure sets available for focused reporting

Cost

30% of final score

CMS calculates cost performance automatically from Medicare claims data — no separate submission required. Scored on 35 episode-based and population-based cost measures. New cost measures enter a 2-year informational period before affecting scores.

  • No separate submission — CMS calculates from claims
  • 35 measures scored for the 2026 performance year
  • 6 new episode-based measures added in 2026
  • New cost measures undergo 2-year testing before scoring
  • Performance-period benchmarks (not historical data)
  • Attribution based on plurality of allowed charges

Improvement Activities

15% of final score

Attest to completing activities that improve clinical practice: care coordination, patient engagement, population management, and practice transformation. Most practices need 2–4 activities depending on size and designation.

  • Minimum 90 continuous days of activity completion
  • High-weighted activities earn double points
  • Small practices and PCMHs may earn full credit with fewer activities
  • Activities span care coordination, patient engagement, population health
  • Rural and underserved area clinicians have additional options
  • Must attest through the QPP portal or a qualified registry

Promoting Interoperability

25% of final score

Measures meaningful use of certified EHR technology across objectives: e-Prescribing, Health Information Exchange, Provider-to-Patient Exchange, and Public Health Reporting. Requires a minimum of 180 continuous days of data collection.

  • Minimum 180 continuous days of data collection required
  • Security Risk Analysis attestation mandatory (2 "Yes" required in 2026)
  • Must use 2025 SAFER Guides for security self-assessment
  • HIE objective: choose Send/Receive/Reconcile, Bi-Directional Exchange, or TEFCA
  • eCR measure suppressed for 2025 PY — still report for full credit
  • Up to 5 bonus points for Public Health and Clinical Data Exchange
Our Approach

How MedVersify Manages Your MIPS Reporting

Effective MIPS management is not a single submission — it is a structured, year-round process. We follow a four-phase approach that covers every compliance requirement from initial eligibility through post-submission review.

01
01

Eligibility Assessment & Strategy

We begin with a comprehensive review of every TIN/NPI combination in your practice — confirming who is required to report, identifying low-volume exemptions, and establishing the performance category strategy that best positions your practice for a positive adjustment.

  • MIPS eligibility confirmed at TIN/NPI level
  • Low-volume threshold and opt-in analysis
  • Group vs. individual reporting determination
  • Performance category weight strategy
  • Baseline performance position and gap review
02
02

Measure Selection & Benchmarking

We select quality measures by reviewing current CMS benchmark data — choosing measures where your documented performance falls in the highest scoring deciles. The right six measures can be the difference between an exceptional score and a penalty.

  • CMS benchmark analysis for all candidate measures
  • Outcome and high-priority measure identification
  • Specialty-aligned measure set development
  • Data completeness feasibility review per measure
  • eCQM and registry-based measure support
03
03

Year-Round Performance Monitoring

MIPS is not a year-end event. PI data collection windows, IA minimum periods, and data completeness thresholds all run throughout the performance year. We monitor every requirement continuously and alert your team before gaps become scoring failures.

  • Ongoing data completeness tracking per quality measure
  • PI 180-day minimum window monitoring
  • IA 90-day documentation compliance tracking
  • Mid-year performance score projections
  • Real-time alerts when thresholds are at risk
04
04

Submission & Post-Submission Review

The March 31 deadline is absolute. We manage the full submission lifecycle — pre-submission data audit, QPP portal management, final submission confirmation — and review your published performance score to inform the following year's strategy.

  • Pre-submission data integrity audit
  • QPP portal and registry submission management
  • Final submission confirmation and documentation
  • Post-submission score review and analysis
  • Year-over-year performance trend reporting
Scope of Services

What MedVersify Manages Across the Full MIPS Lifecycle

MIPS reporting is not a single event — it is a year-round management responsibility across four performance categories, each with its own tracking, documentation, and submission requirements.

Eligibility & Strategy

  • MIPS eligibility assessment at TIN/NPI level
  • Performance category weight analysis and scoring strategy
  • Specialty measure set identification and benchmarking
  • Low-volume threshold and opt-in eligibility assessment
  • Group vs. individual vs. virtual group reporting determination
  • Baseline performance gap analysis and scoring projections

Quality Reporting

  • Measure selection based on current CMS benchmark analysis
  • Numerator and denominator validation against clinical documentation
  • Data completeness monitoring throughout the performance year
  • Outcome and high-priority measure identification
  • CAHPS for MIPS survey administration coordination
  • Specialty measure set and eCQM support

Promoting Interoperability

  • EHR certification verification for PI eligibility
  • Security Risk Analysis attestation support (2026 dual requirement)
  • SAFER Guides compliance review
  • HIE objective pathway selection and documentation
  • e-Prescribing measure tracking and compliance
  • Public Health Reporting bonus measure coordination

Improvement Activities

  • Activity selection aligned with existing clinical workflows
  • High-weighted activity identification for maximum credit
  • Small practice and PCMH credit determination
  • Activity documentation and attestation preparation
  • 90-day minimum tracking and compliance monitoring
  • Rural and underserved care designation credit assessment

Submission & Compliance

  • Registry or QPP portal submission management
  • Pre-submission audit and data integrity review
  • Final submission confirmation and documentation
  • Post-submission performance score review
  • Audit trail documentation and recordkeeping
  • Year-over-year performance trend analysis
Performance Year Timeline

Key Dates in the MIPS Reporting Calendar

Each performance category has its own minimum data collection window. Missing a start date or submission deadline creates scoring gaps that cannot be corrected after the fact.

January 1

Performance Year Begins

Data collection starts for Quality and Cost. PI minimum 180-day window opens. IA minimum 90-day window opens.

April 1

CAHPS Registration Opens

Groups electing CAHPS for MIPS patient experience survey must register by June 30.

July 5

Last PI Start Date

Last day to begin Promoting Interoperability data collection and meet the 180-day minimum requirement.

October 2

Last IA Start Date

Last day to begin Improvement Activities and meet the 90-day minimum requirement before year end.

December 31

Performance Year Ends

Final day of data collection for Quality, PI, and IA. Cost is calculated from Medicare claims data by CMS.

March 31

Submission Deadline

All MIPS data must be submitted to CMS by March 31 of the following year. Late or missing submissions result in the maximum negative adjustment.

~18 Months Later

Payment Adjustment Applied

MIPS payment adjustments — positive, neutral, or negative — are applied to Medicare Part B payments approximately two years after the performance year ends.

Common Reporting Errors

The Reporting Mistakes That Cost Practices the Most

Most MIPS penalties are not caused by poor clinical performance. They result from administrative errors in measure selection, data completeness, attestation, and submission — all of which are entirely preventable with the right management processes.

Selecting measures without reviewing benchmarks

Consequence

A measure that looks achievable on paper can score 1–3 points per measure if the benchmark decile is highly competitive. Poor measure selection can cost 20+ points off your final score.

MedVersify Prevention

MedVersify reviews CMS benchmark data for each candidate measure before finalizing your measure set — selecting measures where your documented performance can earn maximum points.

Missing the 75% data completeness requirement

Consequence

Failing to meet the 75% data completeness threshold for a measure results in zero points for that measure — equivalent to not reporting it at all.

MedVersify Prevention

We track data completeness throughout the performance year and alert your practice to gaps before they become scoring failures at submission.

Submitting Promoting Interoperability without the Security Risk Analysis

Consequence

A "No" attestation on the Security Risk Analysis — or failing to provide the second "Yes" (added in 2026) for risk management activities — results in zero points for the entire PI category.

MedVersify Prevention

We audit PI requirements before any submission, including the 2026 dual-attestation requirement for the Security Risk Analysis.

Ignoring MIPS eligibility at the TIN/NPI level

Consequence

MIPS eligibility is determined separately for each TIN/NPI combination. A provider working at two practices may be required to report at one but not the other — and missing an obligation results in a penalty.

MedVersify Prevention

We assess eligibility at the TIN/NPI level for every clinician in your practice and manage reporting obligations accordingly.

Missing the submission deadline

Consequence

Late submissions are treated as non-submissions. The March 31 deadline is absolute — missing it means automatic zero scores and the maximum negative payment adjustment.

MedVersify Prevention

We manage the entire submission timeline, including early audit preparation, portal management, and final submission confirmation well before the March 31 deadline.

Treating Improvement Activities as a formality

Consequence

Selecting activities that do not align with your actual clinical workflows and cannot be documented produces attestation risk and zero credit if audited.

MedVersify Prevention

We select Improvement Activities that reflect your existing or easily adoptable workflows — activities you can genuinely document, not just check off.

Eligibility & Requirements

Who Is Required to Participate in MIPS?

Clinicians are required to participate in MIPS if they exceed all three of the low-volume thresholds during both segments of the CMS determination period. Meeting only one or two thresholds does not trigger a reporting requirement.

Eligibility is assessed at the TIN/NPI level — meaning the same physician may be required to report under one practice's tax ID but exempt under another. Practices with multiple locations or shared providers need to assess each TIN/NPI combination independently.

Clinicians exempt from mandatory participation may still opt in voluntarily if they meet certain billing criteria — and earning a positive adjustment from an optional submission can be valuable for practices near the volume thresholds.

Newly enrolled Medicare clinicians during a performance period are automatically excluded from mandatory reporting for that year.

Mandatory Participation Thresholds

Medicare Part B Billing

More than $90,000 in allowed charges

During both segments of the determination period

Patient Volume

More than 200 Medicare patients

Unique patients during the determination period

Service Volume

More than 200 covered professional services

Furnished to Medicare Part B patients

Determination Period

Two 12-month assessment segments

CMS publishes initial eligibility; final eligibility in December

All three thresholds must be exceeded

A clinician who bills $95,000 but sees only 180 Medicare patients is not required to report. Only clinicians exceeding all three criteria in both determination segments are mandatory participants. MedVersify assesses eligibility for each TIN/NPI combination in your practice.

Get Started

Take the MIPS Burden Off Your Practice

MIPS compliance is a year-round responsibility that grows more complex each performance year. MedVersify manages every component — so your clinical team focuses on patient care while we protect your Medicare reimbursements.

Mon – Fri, 9am–5pm EST

(507) 312-9282

Email our compliance team

info@medversify.com
  • No long-term contracts required
  • CMS-aligned reporting for every performance year
  • Dedicated MIPS specialist assigned to your practice
  • All specialties and all practice sizes supported
  • Response within 24 hours

Request a Free MIPS Compliance Review

Share your practice details and we'll assess your current MIPS exposure and identify your optimal reporting strategy.

No obligation. HIPAA-compliant. CMS-aligned. Response within 24 hours

Request Received

A MedVersify specialist will review your MIPS details and reach out within 24 business hours.

MedVersify MIPS Reporting Services

Medicare Reimbursements You've Earned Deserve to Stay Intact.

MedVersify manages MIPS compliance for eligible clinicians across all specialties and practice sizes nationwide — so performance year obligations never create avoidable payment reductions.