Medicare QPP

Physicians Advocacy Institute

Frequently Asked Questions Updated for 2023

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1. What if I don’t have an electronic health record

  1. Physicians and practices are required to use certified electronic health record technology (CEHRT) meeting the 2015 edition certification criteria. However, there is an opportunity to submit a hardship exemption. The reporting mechanisms that can be used to submit your MIPS data depend on (1) the reporting options designated for that category and (2) whether you participate as an individual, group, or Virtual Group. Moreover, you can report different categories using different reporting mechanisms; you are not required to submit MIPS data using one reporting mechanism across all the categories.

    The table below details the alternative reporting mechanisms available:
    Category Reporting Options   
    Quality Individual (themselves or working with a Qualified Registry, QCDR, or CEHRT Medicare Part B Claims; Direct; Log-In and Upload
    Group or Virtual Group (themselves or working with a Qualified Registry, QCDR, or CEHRT Medicare Part B Claims; Log-In and Upload (only for those with 15 or fewer clinicians in group, virtual group, or APM entity)

    Log-In and Upload (only for those with 16-24 clinicians in group, virtual group, or APM entity)

    Log-In and Upload; Direct (25 or more clinicians in group, virtual group, or APM entity)
    Improvement Activities Individual, Groups, Virtual Groups, and Third-Party Intermediaries (e.g., Qualified Registry, QCDR, CEHRT, CMS-approved survey vendor) Direct; Log-In and Upload; 
    Log-In and Attest (via qpp.cms.gov)
    Promoting Interoperability Individual

    Groups, Virtual Groups, and Third-Party Intermediaries (e.g., Qualified Registry, QCDR, CEHRT,)
    Log-In and Upload; 
    Log-In and Attest (via qpp.cms.gov)
    Third-Party Intermediaries Log-In and Upload; Direct
    Cost Individual No submission required. CMS will use administrative claims data.
    Group or Virtual Group

    To learn more about the reporting mechanisms at the individual, group, or Virtual Group level for each category, please see the MIPS Reporting Mechanism resource.



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