Merit-Based Incentive Payment System (MIPS) & QPP

MIPS 2024

MIPS-eligible clinicians (ECs) must participate and submit their data on or before March 31, 2025, to avoid a 9% payment penalty. Eligible clinicians, groups, and virtual groups that encountered extreme and uncontrollable circumstances may apply for an exception.

The Extreme and Uncontrollable Circumstances (EUC) exception reweights your MIPS performance categories to as low as 0%. The MIPS EUC exception application for the 2024 performance year will be available until 8 p.m. ET on December 31, 2024.

Our team of attestation experts can help you apply for the EUC exception without the hassle. To learn more about the MIPS 2024 exceptions, click here.

Quality Measures

The Quality performance category accounts for 30% of your final MIPS score over a 12-month performance period (January 1–December 31, 2024).

Eligible clinicians must select 6 individual measures, 1 of which must be an outcome or a high-priority measure. You may also choose to submit data for a specialty measure set that best fits your practice.

• There must be at least 20 cases per measure.
• If fewer than 6 measures apply, then you have to report on each applicable measure.
• Eligible clinicians from small practices (15 or fewer ECs) who submit data on at least 1 quality measure may qualify for the Small Practice bonus and earn 6 points.
• You can also receive up to 10 additional percentage points based on your improvement in the Quality performance category from the previous year.

Instead of the usual 70% data completeness threshold, the Centers for Medicare and Medicaid Services (CMS) now requires you to report performance data for at least 75% of the denominator-eligible cases for each quality measure. Measures can generally earn between 1 and 10 points based on the following:

• Your performance if the measures have a benchmark
• If you meet the 75% data completeness threshold
• If you meet the minimum requirement of 20 cases per measure

New Quality measures in their first year have a scoring floor of 7 points, while new Quality measures in their second year have a scoring floor of 5.

Measures that fail to meet the data completeness criteria receive zero points (small practices will continue to receive 3 points).

You can review the available Quality measures here.

Cost Measures

The Cost performance category accounts for 30% of your final MIPS score over a 12-month performance period (January 1–December 31, 2024). 

Qualified participants can continue to earn a 1% improvement score if they have improved their Cost performance category score from the previous year.

Beginning the 2024 performance period, the acute inpatient medical condition measure Simple Pneumonia with Hospitalization has been removed from the Cost performance category. On the other hand, the following new episode-based cost measures have been introduced, each with a 20-episode case minimum:

• An acute inpatient medical condition measure (psychoses and related conditions)
• 3 chronic condition measures (depression, heart failure, and low back pain)
• A measure focusing on care provided in the emergency department setting (emergency medicine)

Cost Measure Case Minimums

• Case minimum of 20 for Total per Capita Cost measure and 35 for MSPB
• Case minimum of 20 for acute inpatient medical condition episodes
• Case minimum of 10 for procedural episodes

CMS uses Medicare claims to calculate your Cost measure performance, so you don’t have to submit any data for this category.

To learn more about the Cost measures, click here.

Promoting Interoperability

The Promoting Interoperability (PI) category accounts for 25% of your final MIPS score. Its performance period spans 180 consecutive days  in the same performance year, an increase from last year’s 90-day period. 

For the 2024 performance year, CMS requires you to use an electronic health record (EHR) that meets the 2015 Edition certification criteria, 2015 Edition Cures Update certification criteria, or a combination of both. You must submit collected data for specific measures from each of the 4 objectives.

You can review the PI measures here.

To earn a score for the PI category, an eligible clinician must:

• Provide their EHR’s CMS identification code.
• Collect data in EHR technology with the 2015 Edition functionality for 180 consecutive days.
• Submit a “yes” to the Actions to Limit or Restrict Interoperability of CEHRT attestation.
• Answer the ONC Direct Review attestation. This is optional, so you may attest “yes” or “no.”
• Submit a “yes” to the Security Risk Analysis measure. 
• Submit a “yes” to the new SAFER Guides attestation. 
• Report the 5 to 6 required measures or claim their exclusion(s).

CMS has also exempted several clinician types from reporting PI data, including those with special status designations that result in automatic reweighting.

• Clinician Type: Clinical social workers
• Special Status: Ambulatory surgical center (ASC)-based, hospital-based, non-patient facing, and small practice

Meanwhile, physical therapists, occupational therapists, qualified speech-language pathologists, qualified audiologists, clinical psychologists, and registered dieticians or nutrition professionals are now required to report PI data.

You may apply for a MIPS Promoting Interoperability Performance Category Hardship Exception to reweight your PI measures to 0%. Learn more about the PI exception here.

Improvement Activities



The Improvement Activities (IA) category accounts for 15% of your final MIPS score over a continuous 90-day period in the same performance year. 

To earn full credit in the IA category of your 2024 MIPS reporting, you must generally submit one of the following combinations of activities:

• 2 high-weighted activities,
• 1 high-weighted activity and 2 medium-weighted activities, or
• 4 medium-weighted activities.

You can earn a maximum of 40 points for attesting to activities in the IA performance category. High-weighted activities receive 20 points, while medium-weighted activities receive 10. Meanwhile, clinicians with special statuses (i.e., small practices, HPSA providers, non-patient facing, and rural) may receive double points for each high-weighted or medium-weighted activity they submit.

Practices that are certified patient-centered medical homes (PCMH) may earn the maximum Improvement Activity performance category.

For group reporting, at least 50% of the clinicians in the group need to attest to performing the same activity during the 90-day period.

To learn more about the IA measure, click here.