The submission window for the 2019 Merit Based Incentive Program (MIPs) performance year has officially opened. If you are an eligible clinician that participates in the MIPs program, now is the time to log in and complete your attestations or work with your chosen vendor on finalizing submission data.

Physicians who participate in MIPS through an Alternative Payment Model (APM) are subject to a different set of guidelines, which should be coordinated with your respective facility/hospital.

Here are some key reminders for the 2019 submission year for Radiologists:

The submission window is January 2nd , 2020 – March 31st, 2020. Score 30 points or higher to avoid a penalty, the maximum penalty for 2019 is -7% on future Medicare payments in 2021. Scores of 75 points or higher are eligible for the “exceptional performance bonus” category.

Performance Categories and weights:

Quality: 45%

Improvement Activities: 15%

Promoting Interoperability: 25%

Cost: 15%

MIPs Eligibility – individuals who exceed the low volume threshold are required to participate in MIPs.

To check eligibility, use the tool on the site here:

Low Volume Threshold

$90,000 or more in Medicare part B claims AND See 200 or more Medicare part B patients AND provide 200 or more covered professional services to Part B patients.

Special Statuses – MIPs eligible clinicians may also qualify for special statuses that can impact category specific reporting. Special statuses can also be checked on the participation tool on

Non-Patient Facing – bill 100 or fewer patient facing encounters during the performance year. To qualify, 75% of clinicians in a group must obtain this status for the group to be considered “non patient facing”. This status then automatically reweights Promoting Interoperability to the Quality category and grants twice the amount of points for Improvement Activities. Many, if not most, Radiology practices will be included in this status group.

Hospital Based – 75% or more of a clinician’s services are furnished at the hospital level. To qualify, all clinicians in a group must have this status for the group to be considered “hospital based” in 2019. This status automatically reweights Promoting Interoperability to the Quality category similar to the status above.

Small Practice – Groups of 15 or fewer are designated as small practices and may report the Quality category via claims submission if you receive this status. Clinicians or Groups without this status must use a Qualified Registry or a QCDR to report Quality data for 2019.

2020 is already poised to be a busy regulatory year with issues like Surprise Billing and Clinical Decision Support (Appropriate Use Criteria) set to impact the healthcare industry, so getting your MIPs submission out of the way early will free up valuable time to focus on other important areas. Of course, plan to stay focused throughout the year on MIPs too, as it is also very important and because the threshold to avoid a penalty has gone up to 45 points (from 30) for the 2020 performance year.

As always, ADVOCATE will keep you up to date throughout the year on MIPs related topics.


Kayley Jaquet

Manager of Regulatory Affairs