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Participation Options Overview

"Participation options" refers to the levels at which data can be collected and submitted, or "reported," to CMS for MIPS. There are 5 participation options: individual, group, virtual group, subgroup, and APM Entity. Use the QPP Participation Status Tool to view your eligibility status, which informs your participation options. You can also learn more about how we determine eligibility and the eligibility determination period and snapshots

The participation options available to you are also informed by your chosen MIPS reporting option(s).

A clinician submits their own individual performance data specific to a . You can report traditional MIPS, the APM Performance Pathway (APP) if you're a MIPS APM Participant, and/or a MIPS Value Pathway (MVP) as an individual. Learn more about Individual Participation

A practice submits aggregated performance data on behalf of all clinicians billing under their TIN. If your practice chooses to participate as a group, the MIPS eligible clinicians who aren't eligible as individuals will be included in MIPS and receive a payment adjustment. A group can report traditional MIPS, the APP (if the practice includes clinicians in a MIPS APM), and/or an MVP. Learn more about Group Participation.

A virtual group is a combination of 2 or more TINs that elect to form a virtual group for the performance year. Virtual group participation is only available for reporting traditional MIPS and requires CMS approval. Virtual groups can't report the APP or an MVP. Learn more about Virtual Group Participation

Subgroup (New for 2023) 

A subgroup is a subset of clinicians in a group (at least 2 clinicians) which contains at least one individually eligible MIPS eligible clinician. Subgroup participation is only available for reporting an MVP and requires advance registration. Subgroups can't report traditional MIPS or the APP. Learn more about the MVP reporting option

APM Entity

If you're MIPS eligible at the individual and/or group level and are a MIPS APM participant, you can participate in MIPS as an APM Entity. An APM Entity can report traditional MIPS, the APP, and/or an MVP.  Learn more about APM Entity Participation.

Participating in multiple ways

It’s possible to participate in MIPS in multiple ways. If a clinician (identified by a single, unique TIN/NPI combination) has more than one MIPS final score, here’s how we’ll determine which final score and payment adjustment you’ll receive:

  • If you participate as a virtual group, you’ll receive a payment adjustment based on the virtual group’s final score, even if you have additional final scores from other participation options.
  • If you participate as an individual, group, subgroup, and/or an APM Entity under the same TIN/NPI combination, we’ll assign the highest available score and associated payment adjustment.

Next steps

  1. Check the QPP Participation Status Tool to determine if you’re required to participate in MIPS. If you're not required to participate in MIPS, determine if you want to elect to opt-in to MIPS (if applicable), report voluntarily, or not report MIPS data at all.
  2. Determine how you’ll participate. This choice varies based on which reporting framework you’ll follow to collect and submit data. Learn more about MIPS reporting options.
  3. Determine if you qualify for any reporting factors that may impact your reporting requirements.
  4. Review the current performance year’s quality measures and determine which collection types (eCQMs, claims measures, etc.) make the most sense for your reporting requirements.
  5. Start collecting your quality data now. Plan to collect at least 180 days of data for the MIPS Promoting Interoperability performance category. Plan to perform up to 4 improvement activities for 90 days each. You don’t have to collect cost data; we collect cost measure data on your behalf.
  6. Check updates to your eligibility status to help plan your reporting requirements. Learn more about the factors that can cause eligibility to change.