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Navigating the Merit-based Incentive Payment System (MIPS) under the Quality Payment Program (QPP) can be challenging for physical therapy practices. One of the most important aspects to understand is whether your providers are required to report MIPS data. Our best advice: prepare for the worst and hope for the best. Since you won’t know for sure if any providers are required to report until after Snapshot 2 is released (late 2025), it’s crucial to plan ahead. By preparing for the possibility of being required to report, you can avoid getting caught off-guard and facing the maximum -9% penalty adjustment.
If you have providers that may meet the Low-Volume Thresholds (LVTs), you’ll need to plan to collect MIPS measure data for the entire performance period (1/1/25-12/31/25). This ensures that you’re ready in case they are ultimately required to report. In this post, we’ll break down what the LVTs are, and how to use the QPP website and Participation Lookup Tool to stay on top of your providers’ eligibility.
The Low-Volume Thresholds (LVTs) are the criteria that determine whether a provider must participate in MIPS for a given performance year. These thresholds are based on the volume of Medicare Part B patients a provider sees and the Medicare billing charges associated with their practice.
For a provider to be required to report MIPS data, they must exceed all of the following LVTs during the snapshots for the performance period:
The QPP reviews past and current Medicare Part B claims and PECOS data for clinicians and practices twice for each performance period. Each snapshot, or “segment,” analyzes data from a 12-month period. Analysis of data from segment 1 is released as preliminary eligibility determinations. Analysis of data from segment 2 is reconciled with the results from segment 1 and released as the final eligibility determination.
Even though the official MIPS eligibility determination is made after Snapshot 2 (in late 2025), it’s important to prepare for the worst by collecting MIPS measure data throughout the entire performance period. Here's why:
To start understanding whether a provider in your practice might be required to report MIPS, use the QPP Participation Lookup Tool. This tool will help you determine eligibility based on individual National Provider Identifier (NPI) or Taxpayer Identification Number (TIN).
If you want to check multiple providers or want to check your entire practice's eligibility, you can log into the QPP website using your HARP account (Healthcare Electronic Administrative and Reporting Portal). Once logged in, and successfully connected to your organization, you’ll be able to view eligibility for all the providers in your practice, as well as track any changes.
Since you won’t know definitively if a provider will meet the LVTs until Snapshot 2, it’s important to plan to collect MIPS measure data for the full performance period. Even if you believe a provider will be exempt, don’t take the risk of not collecting the data—especially since eligibility can change for new providers with the second snapshot.
Start collecting data for the following MIPS categories:
Having the necessary data on hand ensures you're ready to report as required, whether a provider is ultimately eligible or not, and gives you the option to pursue a positive bonus.
By adopting the right processes and staying proactive, you give your practice the flexibility and options needed to succeed under MIPS. Preparing early not only helps you avoid getting backed into a corner unprepared, but it also opens up opportunities to maximize your performance and potentially earn incentives. With a little planning and the right tools, you can turn the uncertainty of MIPS into an opportunity to elevate your practice and provide even better care for your patients. Stay ahead of the curve, and you’ll be ready for whatever comes your way—empowered, confident, and fully equipped to succeed!
Disclaimer: The information provided is for general information purposes only and represents an interpretation of the CMS and MIPS Program rules. Eligibility for MIPS can be complex, and different TIN/staff scenarios may impact eligibility requirements or reporting responsibilities. As such, it is recommended that you consult the official CMS Quality Payment Program website at qpp.cms.gov for the most up-to-date and detailed information. For any specific questions or unique circumstances, please reach out directly to the QPP help desk for personalized assistance.
