MIPS for Physical Therapy:
Is It Worth the Effort?
The Merit-based Incentive Payment System (MIPS) has been reshaping Medicare reimbursement for physical therapy practices since 2017. Physical therapists in private practice became MIPS-eligible clinicians beginning with the 2019 performance year — a change that catches many PT owners off-guard. The stakes are real: penalties of up to 9% of your Medicare revenue for non-participation, or bonuses for exceptional performance. This whitepaper breaks down the program mechanics, the math, the compliance burden, and the single question most PT owners fail to ask: what does your MIPS track record do to your practice valuation when you decide to sell?
The Silent Penalty: CMS Does Not Warn You. Non-participation is the default state for any clinician who takes no action. CMS does not send a warning letter, a bill, or a notification that you have missed the program. The penalty is simply applied to your Medicare remittances two years after the performance year — often catching practice owners completely off-guard. Many PT practices first discover their MIPS exposure — potentially dating back to 2019 — when a buyer’s due diligence team pulls their QPP participation history mid-transaction. At that point, the penalty is already locked in and non-remediable. The only way to avoid it is to act before the March 31 submission deadline of the year following your performance year.
Origins: MACRA & the End of SGR
MIPS was created by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which replaced the widely despised Sustainable Growth Rate (SGR) formula. MIPS formally launched in performance year 2017. MACRA created two pathways: MIPS and Advanced Alternative Payment Models (APMs). Most PT practices fall under MIPS. The program consolidates three prior CMS programs — PQRS, Value Modifier, and Meaningful Use — into a single composite score.
PTs Have Been MIPS-Eligible Since the 2019 Performance Year
Physical therapists in private practice became MIPS-eligible clinicians beginning with the 2019 performance year — meaning if your practice has billed Medicare Part B above the low-volume threshold at any point since 2019 and failed to report, your penalty exposure may extend back further than you realize. If your practice bills Medicare Part B and meets the low-volume threshold, you are in the program. The question is not whether to engage — it is how to engage efficiently, and how to assess any historical exposure.
Who Is Exempt?
CMS provides a low-volume exemption. For performance year 2024, clinicians are excluded if they meet any of the following: (1) ≤ $90,000 in Medicare Part B allowed charges; (2) ≤ 200 Medicare patients; or (3) ≤ 200 covered professional services. Practices at or below these thresholds are not required to participate, though they may elect to do so voluntarily.
Individual vs. Group Reporting
Clinicians may report as individuals (by NPI) or as a group (by TIN). Group reporting averages performance across all eligible clinicians in the practice under one tax ID. For multi-clinician PT practices, group reporting is often preferable — it averages out lower performers and reduces administrative burden. The election must be made before the performance year ends.
PTA Differential Payment: How It Affects Your MIPS Math. Since January 1, 2022, Medicare reimburses services provided by Physical Therapist Assistants at 85% of the standard Medicare Part B rate (a 15% reduction) when a modifier is applied indicating PTA delivery. This differential has two direct MIPS implications. First, if your practice relies heavily on PTAs, your Medicare revenue — and therefore your penalty exposure — may be lower than expected, which could affect whether you clear the $90,000 low-volume threshold. Second, MIPS quality measures must be attributed to the supervising PT of record, not the PTA — meaning your reporting infrastructure must correctly capture and assign patient encounters where PTAs delivered the service. Practices with mixed PT/PTA staffing models should confirm with their billing team that their QCDR is correctly attributing quality measure data under the supervising PT’s NPI.
Quality
The Quality category requires reporting on at least 6 measures for at least 75% of applicable patients over the performance period. PT-relevant measures include functional outcome tools (FOTO, PROMIS), patient experience measures, and care coordination measures.
High-value PT measures:
- Functional Outcome Assessment (Measure #182)
- Functional Status Change for Hip Impairments
- Functional Status Change for Low Back Pain
- Falls: Screening for Future Fall Risk — verify current availability in your QCDR’s measure library, as CMS periodically retires and replaces measures
- Pain Assessment and Follow-Up (Measure #131) — tracks whether pain is reassessed after initial documentation
- Pain Assessment and Follow-Up
Scores are benchmarked against national peer data. High scores require consistent EHR-integrated documentation throughout the performance year.
Promoting Interoperability (PI)
PI measures electronic health information exchange. Most PT practices qualify for a PI hardship exception — physical therapists are not required to use a certified EHR system and may attest to the PI hardship, which reweights these points to Quality.
If claiming the hardship exception: The 25% PI weight is redistributed to other scored categories (primarily Quality), making Quality the dominant driver of your score. If Cost is also reweighted out (common for PT practices), Quality can represent an even larger share. This is the most common path for PT practices and significantly simplifies compliance.
If not claiming exception: You must use a 2015 Edition Certified EHR and report on e-prescribing, health information exchange, and patient access measures — a meaningful administrative lift for most PT practices.
Improvement Activities (IA)
The IA category rewards clinicians for participating in practice improvement activities. This is the easiest category to score well in for most PT practices. You must earn 40 points from a menu of approved activities over a continuous 90-day period.
High-value PT activities:
- Use of telehealth services for patient visits (high-weight = 20 pts, requires active telehealth delivery)
- Chronic care and preventive care management
- Patient safety training completion
- Falls prevention programs
- Regular review of care plans with patients
- Participation in QCDR or clinical data registry
Two high-weight activities (20 pts each) are sufficient to achieve full category credit.
Cost
The Cost category measures the total cost of care attributed to your practice across Medicare claims. PTs do not need to submit any data for Cost — CMS calculates it automatically from administrative claims. This is both a relief and a risk: you have no ability to curate what gets measured.
Attribution methodology: Cost is measured through episode-based cost measures. For PTs, the most relevant is the Elective Primary Total Hip and/or Total Knee Arthroplasty episode measure — though many PT-only practices will not have sufficient episode attribution and Cost will be reweighted out.
If Cost cannot be calculated: The 30% weight is redistributed proportionally to the other categories, most commonly boosting Quality’s share substantially.
2024 MIPS Payment Adjustment Framework (Applies to 2026 Medicare Payments)
Full Penalty Scenario
Example: A PT practice billing $400,000 in annual Medicare Part B takes a $36,000 annual hit applied in 2026 for 2024 non-participation. A multi-provider practice billing $1.2M in Medicare loses $108,000 per year — compounding across future performance years.
Score ≥ 75 Points
Break-even target: A score of 75 crosses the performance threshold and enters the budget-neutral positive adjustment pool — meaning even a score right at 75 may yield a small positive adjustment, not a literal zero. Most importantly, scores at or above 75 avoid any negative penalty. Achievable for most PT practices with proper measure selection and PI hardship attestation.
Score ≥ 75 Points
Upside scenario: Scores above the 75-point threshold qualify for a positive budget-neutral payment adjustment — funded by penalties collected from low scorers and non-participants. The actual adjustment percentage varies annually. Note: The separate exceptional performance bonus pool (for scores ≥ 89) expired after the 2022 performance year and is no longer available. Scoring higher still improves your position within the budget-neutral pool.
The Positive Adjustment Is Budget-Neutral — Not Guaranteed. CMS funds positive adjustments from the penalty pool collected from low scorers and non-participants. The actual positive adjustment percentage varies year-to-year based on how many clinicians score above threshold and the total pool available. The exceptional performance bonus (for scores ≥ 89) is funded separately and is currently capped by statute. Do not budget positive MIPS adjustments as guaranteed revenue.
| Performance Year | Payment Year Affected | Annual Medicare Revenue | Penalty Applied | Dollar Impact |
|---|---|---|---|---|
| 2022 (Did Not Submit) | 2024 | $400,000 | −9% | −$36,000 |
| 2023 (Did Not Submit) | 2025 | $420,000 | −9% | −$37,800 |
| 2024 (Did Not Submit) | 2026 | $440,000 | −9% | −$39,600 |
| Total Three-Year Revenue Loss (Non-Remediable) | −$113,400 | |||
| Estimated 3-Year QCDR Subscription Cost (at $3,000/yr) | $9,000 | |||
| Net Cost of Non-Participation vs. Basic Compliance | −$104,400 | |||
The penalties above are not hypothetical — they are non-negotiable and non-remediable once the submission deadline passes. Each performance year generates its own independent adjustment, applied to claims paid during the corresponding payment year. A practice that ignored MIPS in 2022, 2023, and 2024 is simultaneously taking three separate haircuts to its Medicare revenue across 2024, 2025, and 2026 — and practices eligible since 2019 may carry even deeper historical exposure — all while any 2025 buyer underwrites the practice on its actual collected revenue, which now reflects all three reductions. At a 5x EBITDA multiple, if these revenue reductions flow through to EBITDA dollar-for-dollar, the enterprise value impact of $113,400 in compounding penalties could approach $567,000 in lost purchase price — though buyers will model the actual impact based on your specific margin structure.
MIPS Participation Decision Matrix for PT Practices
How to Reach a Neutral Score in 90 Days
Most PT practices can achieve a score of 75 with a focused reporting approach. Note: Quality measures must be reported for a minimum 12-month period (at least 75% of eligible patients); the 90-day minimum window applies specifically to Improvement Activities.
- Attest to the PI Hardship Exception (eliminates PI category)
- Select 6 quality measures via a QCDR (e.g., FOTO, WebPT)
- Report quality measures for ≥ 75% of eligible patients over the full performance year
- Complete 2 high-weight Improvement Activities (40 pts)
- Ensure Cost is reweighted out (most PT practices are unscored)
How to Actually Submit Your Data
CMS accepts MIPS data through four primary submission mechanisms. PT practices most commonly use:
- QCDR — e.g., FOTO Analytics, WebPT, Clinicient. Bundles reporting into existing workflow; best for most PT practices
- EHR Direct Submission — requires 2015 certified EHR; not common in PT
- Claims-Based Submission — via G-codes on claims; manual and error-prone
- Registry/QCDR or EHR submission — the CMS Web Interface was retired after 2022; large groups now submit via registry or EHR pathways
What Compliance Actually Costs
The most common MIPS QCDRs used by PT practices price as follows (approximate annual subscription costs):
- QCDR subscriptions (e.g., FOTO Analytics, WebPT, others) — typically range from ~$1,000–$4,000/yr depending on provider count and platform; some are bundled into existing EMR subscriptions
- MIPS compliance consulting (standalone advisor) — typically ~$2,000–$6,000/yr for smaller practices
- Note: Pricing varies and changes frequently. Request current quotes directly from vendors before budgeting.
Against a −9% penalty on even $150,000 in Medicare revenue ($13,500/yr), every one of these options is strongly ROI-positive. The break-even point on a $3,000 QCDR subscription is approximately $33,333 in annual Medicare revenue — well below the $90,000 low-volume threshold that triggers mandatory participation.
Know Your Number Before You Do Anything Else
Your MIPS exposure is directly proportional to your Medicare Part B revenue. If you don’t know that number, here is how to find it quickly:
- Billing system report: Run a collections report filtered by payer = Medicare Part B for the prior 12 months. This is your baseline exposure figure.
- QPP portal: Log in at qpp.cms.gov with your NPI. CMS displays your estimated Medicare revenue and patient/service counts used to determine threshold status.
- EOB summary: Your Medicare Administrative Contractor (MAC) sends remittance advice on all paid claims. Your billing team can pull a payer-level summary from your practice management system.
- Ask Mihama: As part of any preliminary practice review, Mihama pulls publicly available Medicare utilization data that confirms your approximate Medicare billing volume within minutes.
Penalty History Creates Revenue Risk in Buyer Models
If your practice has been receiving Medicare payment adjustments due to MIPS penalties, institutional buyers will model those as recurring revenue haircuts. A $30K annual penalty applied at a 5x EBITDA multiple = $150K in enterprise value destroyed — simply from inaction on a compliance program with a manageable implementation cost.
Quality Infrastructure Signals Operational Maturity
Buyers are not just buying patient volume — they are buying the operating infrastructure of your practice. A documented, consistently executed MIPS program signals that your clinical team operates with data discipline. Buyers building multi-site platforms want to know your practice integrates without a quality overhaul.
Reps & Warranties Exposure on Unknown Penalties
MIPS adjustments apply two years retroactively. A penalty generated in 2023 affects 2025 payments. If a sale closes in early 2025, the buyer inherits an already-booked penalty adjustment on their first full year of revenue — creating reps-and-warranties liability if not properly disclosed and indemnified in the purchase agreement.
MIPS Compliance Is a Due Diligence Checkbox
Mihama’s due diligence preparation process includes a regulatory compliance section covering QPP participation status, penalty history, and reporting documentation. Practices that arrive at LOI with clean MIPS records face far fewer diligence queries and price re-trade conversations than those addressing it for the first time under buyer scrutiny.
A Strong MIPS Score Supports Your Quality-of-Earnings Narrative
A multi-year track record of high MIPS scores provides evidence of clinical quality and documentation rigor — arguments Mihama’s bankers use in the Quality of Earnings narrative presented to buyers. Practices with consistently strong MIPS scores can credibly support a premium multiple through demonstrated care efficiency and documentation discipline.
Remediation Before Go-to-Market Is Always Possible
If your MIPS history has gaps, Mihama works with sellers to assess remediable vs. non-remediable exposure ahead of marketing. In many cases, 12–18 months of clean, high-scoring participation before go-to-market is sufficient to reframe the narrative and neutralize the discount a buyer would otherwise apply.
| Mistake | Why It Happens | Consequence | The Fix |
|---|---|---|---|
| Non-participation | Unaware that PT MIPS eligibility began in 2019 — penalty exposure may extend back multiple years | Automatic −9% Medicare payment adjustment, two years compounded | Assess low-volume threshold immediately; enroll in a QCDR for next performance year |
| Missing the submission deadline | MIPS data must be submitted by March 31 of the year following the performance period | Treated as non-participation; full penalty applies regardless of internal documentation | Set calendar reminders; use a QCDR that auto-submits before the deadline |
| Failing to claim PI hardship | Unaware that PTs qualify for the Promoting Interoperability exception | PI category scored at 0 due to no EHR infrastructure — severely depresses overall score | Attest to the PI hardship exception via the QPP portal before year-end |
| Picking the wrong quality measures | Selecting measures with low case volume or no benchmark data available | Measures score at decile 1 by default — not enough to reach the performance threshold | Use a QCDR that recommends measures based on your patient population and payer mix |
| Reporting on too few patients | Misunderstanding the 75% data completeness requirement (raised from 70% in prior years) | Quality score is severely suppressed; overall CPS likely falls below the 75-point performance threshold; penalty applies | Monitor reporting rates in real time via QCDR dashboard; flag gaps before year ends |
| Ignoring Improvement Activities entirely | IA category viewed as optional or overly complex | 15% of CPS scores at 0 — forces Quality to carry the entire load, often unsuccessfully | Select two high-weight IA activities at year start; document over a 90-day window |
| Reporting as individual when group is better | Defaulting to individual NPI without analyzing group performance | Individual clinicians with lower documentation drag down scores that could average upward in a group submission | Model both scenarios before year-end; elect group reporting at the TIN level if favorable |
| Not disclosing MIPS penalties to buyers | Seller unaware that pending payment adjustments constitute a disclosure obligation | Reps-and-warranties breach post-close; buyer clawback; deal renegotiation at closing | Have Mihama prepare a regulatory disclosure schedule as part of pre-marketing process |
Reasons to Participate
Penalty Avoidance Is the Primary ROI Driver
The most compelling reason to participate is simply avoiding the penalty. A −9% reduction on Medicare revenue is material at any practice size above the low-volume threshold. The compliance cost of achieving a neutral score (75 pts) is almost always significantly less than the penalty it avoids. For a $500K Medicare practice, the math is $45,000 at risk vs. a QCDR subscription that typically runs $1,000–$5,000 annually.
Upside Revenue Potential for Above-Threshold Performers
Practices that achieve scores above 75 qualify for a positive budget-neutral payment adjustment — funded by penalty collections from non-participants and low scorers. The actual dollar amount varies annually. Note that the separate exceptional performance bonus (for scores ≥ 89) expired after the 2022 performance year and is no longer available. That said, achieving higher scores still improves your position within the budget-neutral adjustment pool and strengthens your quality narrative at exit.
Demonstrates Clinical Quality to Buyers and Payors
A documented MIPS compliance program and a track record of strong scores signals to institutional buyers, payers, and referral sources that your practice operates with data discipline. In competitive acquisition processes, this type of documentation differentiates practices and directly supports premium multiple arguments. Commercial payers increasingly weight quality program participation in contract negotiations as well.
Protects Practice Valuation Pre-Sale
As detailed in Section 5, MIPS history is reviewed in institutional due diligence. Practices with clean, documented participation histories face smoother transactions, fewer reps-and-warranties negotiations over undisclosed penalty exposure, and stronger quality-of-earnings narratives. Building a MIPS track record 12–24 months before go-to-market is one of the highest-ROI pre-sale preparation activities a PT owner can undertake.
Outcome Data Improves Clinical Decision-Making
The Quality measures required for MIPS — particularly functional outcome tools like FOTO, PROMIS, and the falls screening measure — generate data that has genuine clinical value independent of the payment program. Practices that build MIPS reporting into their clinical workflow often find that the outcome data improves their ability to track patient progress, identify high-performing clinicians, and demonstrate value to referral sources.
PI Hardship Exception Makes Compliance Manageable for PT
Unlike many other provider types, physical therapists can attest to the Promoting Interoperability hardship exception, eliminating the most technically burdensome category (25% of the score) without penalty. This exception — which reweights PI points to Quality — is specifically designed to reduce the compliance burden for therapy providers and makes the program far more accessible than it would otherwise be.
Limitations and Risks to Understand
Administrative Burden Is Real and Ongoing
MIPS is not a one-time enrollment — it requires active, ongoing documentation and reporting every performance year. Staff must be trained on outcome measure administration, reporting rates must be monitored throughout the year, and submission deadlines cannot be missed. For single-provider practices or clinics without dedicated billing support, this represents a meaningful time investment. Unlike a one-time project, the burden recurs annually and must be sustained.
Positive Adjustments Are Budget-Neutral and Unpredictable
The positive payment adjustment pool is funded by penalty collections from low scorers and non-participants. As more practices achieve scores above the threshold, the per-practice adjustment shrinks. Additionally, the pool amount changes year to year based on aggregate clinician performance. This makes it difficult to forecast positive MIPS income, and practices should not budget it as a reliable revenue line. Exceptional performance bonuses are somewhat more predictable, but still subject to annual appropriation rules.
The Program Rules Change Every Year
CMS publishes an annual Physician Fee Schedule Final Rule each November that updates MIPS thresholds, category weights, measure availability, and submission requirements for the following performance year. Performance thresholds have risen substantially over time (starting at just 3 points in the inaugural 2017 performance year, rising to 75 points in 2024), and there is no guarantee they will stabilize. A compliance approach that achieves a score of 78 in 2024 may fall below threshold in future years without adjustment. Annual review of your approach is not optional — it is required for sustained compliance.
Cost Category Is Outside Your Control
The Cost category (30% of the composite score) is calculated entirely by CMS from administrative claims, with no opportunity to select, curate, or appeal the measures used. If your practice is attributed to episode-based cost measures for which you score poorly, you cannot opt out or substitute alternative measures. Many PT-only practices are not scored on Cost at all (because episode attribution thresholds are not met), which is favorable — but practices with higher Medicare volumes may find themselves scored on cost measures they have limited ability to influence.
The Payment Adjustment Is Delayed Two Years
MIPS performance in year N affects payments in year N+2. This structural lag means that practices face a two-year horizon between their compliance investment and its Medicare payment impact. A practice that begins participating in 2024 for the first time will not see the payment adjustment (positive or negative) until 2026. The flip side is equally important: a practice that plans to sell in 2025 is already carrying the financial exposure from their 2023 MIPS performance, regardless of what they do in 2024–2025.
Low Medicare Mix Practices Get Limited Benefit
The MIPS payment adjustment applies only to Medicare Part B fee-for-service reimbursements. A PT practice that generates 80% of its revenue from commercial payers and only 20% from Medicare may find that the mathematical benefit of a positive MIPS adjustment is small relative to the compliance cost. In these cases, the primary value of MIPS participation is penalty avoidance and the due diligence narrative benefit rather than direct revenue enhancement. Practices should calculate their specific Medicare revenue exposure before sizing their investment in compliance infrastructure.
The bottom line for most PT practices billing Medicare: MIPS participation is not optional in any meaningful sense. The penalty for non-participation is too large, the compliance path to a neutral score is achievable, and the valuation consequence of a poor MIPS history is material in any institutional sale process. The question Mihama helps clients answer is not whether to comply — it is how to comply in a way that is minimally disruptive to operations while maximizing the quality narrative at exit.
Aim for the Performance Threshold — Nothing More
The rational strategy is straightforward: achieve a score of 75 or above with the minimum administrative overhead. Use a QCDR, claim the PI hardship exception, complete two high-weight Improvement Activities, and select quality measures that benchmark well for your patient population. Do not over-invest in chasing an exceptional performance bonus — the positive adjustment is budget-neutral and unpredictable in size year-to-year.
Invest in a Clean, Documented Track Record
If a transaction is on your horizon, Mihama recommends shifting from a “minimum compliance” posture to a “quality narrative” posture. Aim for 85+ scores over the last two to three performance years prior to go-to-market. Document your compliance program. When Mihama’s bankers present your Quality of Earnings to buyers, a strong MIPS record is one more data point supporting the premium multiple you deserve — and one fewer issue for a buyer to discount.
A note on APM eligibility: A small number of PT practices may qualify for participation in Advanced Alternative Payment Models (APMs) — the other MACRA pathway — through Accountable Care Organizations or bundled payment arrangements. APM participants are generally exempt from MIPS and historically received a 5% Medicare payment bonus (this bonus expired after performance year 2024 under current law — confirm current APM incentive status with a qualified healthcare compliance advisor). If your practice participates in an ACO or bundled payment program, confirm your QPP pathway before investing in MIPS infrastructure.
| Timeframe | What Happens | Action Required |
|---|---|---|
| January 1 — December 31 | Performance Year (e.g., 2024). Quality measures must be reported across the full calendar year. IA activities must be completed over any continuous 90-day period within the year. | Begin quality measure collection from day one of the year. Select your IA activities by Q1 and complete a documented 90-day window. Monitor QCDR dashboards monthly for reporting rate gaps. |
| October — November | CMS publishes the Physician Fee Schedule Final Rule, which sets the MIPS performance threshold, category weights, and measure list for the following performance year. | Review the Final Rule annually. Confirm your quality measures remain available and well-benchmarked for the upcoming year. Adjust your measure selection if thresholds or benchmarks have shifted. |
| January 1 — March 31 | Data Submission Window. MIPS data for the prior performance year must be submitted through your chosen pathway (QCDR, EHR, claims, or web interface) by March 31. This is a hard deadline. | Confirm submission with your QCDR vendor before March 31. Do not wait until the last week — technical issues close to the deadline are common and CMS grants no extensions for individual practices. |
| Late Summer / Fall (following year) | CMS releases individual MIPS feedback reports, typically late summer through fall of the year following the performance period. Clinicians can review their scores, category-level performance, and measure-level detail via the QPP portal at qpp.cms.gov. | Review your feedback report immediately upon release. Identify underperforming measures and adjust your selection or documentation approach for the current performance year. |
| January 1 (two years later) | Payment Adjustment Applied. The positive or negative adjustment from the performance year is applied to all Medicare Part B claims paid during the payment year. The adjustment is applied automatically by CMS — no action required. | Track your Medicare remittances for the payment adjustment period. If a negative adjustment is applied unexpectedly, review your feedback report and consult a MIPS compliance specialist to understand the root cause. |
The Program Is Evolving Toward MVPs
CMS has been rolling out MIPS Value Pathways (MVPs) since 2023 as a streamlined reporting alternative to traditional MIPS. MVPs bundle condition- or specialty-specific measures across all four MIPS categories into a single cohesive reporting pathway. CMS has signaled a preference for MVPs as the long-term direction, though no firm timeline for phasing out traditional MIPS reporting has been established. For PT practices, this means the specific measures available, and the way performance is benchmarked, will continue to evolve. Practices should monitor MVP development for therapy-specific pathways.
The Bar Will Keep Moving Higher
The MIPS performance threshold has risen from 3 points in 2017 to 75 points in 2024. CMS has the statutory authority to continue raising this threshold, and has indicated its intent to do so as the program matures. Practices that barely clear the threshold today may find themselves below it in future years without investing in stronger quality documentation. This trajectory reinforces the value of building genuine outcome measurement infrastructure rather than simply meeting the minimum each year.
Buyers Are Pricing in Regulatory Trajectory
Sophisticated institutional buyers model not just the current MIPS exposure of an acquired practice but the trajectory of quality compliance requirements. A practice that has built genuine outcome measurement infrastructure — integrated into its EHR and clinical workflow — is better positioned for the value-based care environment that buyers know is coming. This makes quality infrastructure a forward-looking asset in the M&A narrative, not just a compliance cost. Mihama’s bankers make this argument explicitly in quality-of-earnings discussions with institutional buyers.
Monitor Legislative Developments
Congressional budget reconciliation and the annual appropriations process can modify MIPS parameters, extend or eliminate bonus structures, and alter the program’s long-term timeline. The 5% APM bonus, for example, was not renewed beyond 2024. PT practices and their advisors should monitor CMS rulemaking and legislative developments annually. Mihama incorporates current QPP program status into its pre-sale regulatory due diligence process as part of standard engagement preparation.
Step Zero for Everyone: Check Your QPP Participation History Today
Go to qpp.cms.gov, log in with your CMS credentials, and pull your participation history for the last three performance years. Look for any years where your status shows as “Did Not Submit” or where a negative payment adjustment is pending. If you find gaps, contact Mihama or a MIPS compliance specialist immediately — the window to remediate prior-year exposure is narrow and the clock is always running.
If You Have Never Participated
First, confirm whether you are above the low-volume threshold. If you are, you may have been accruing penalties since the 2019 performance year (the first year PTs were MIPS-eligible). Quantify your exposure (years above threshold × Medicare revenue × 9% per year), then enroll in a QCDR immediately for the current performance year. You cannot undo past penalties, but you can stop the bleeding. If a sale is within 3 years, disclose the penalty history to Mihama now so it can be managed in the transaction narrative.
If You Are Participating but Scoring Below 75
Review your most recent feedback report on the QPP portal. Identify which categories are pulling your score down. The most common culprits: PI category not hardship-attested (costing you 25% of score), Improvement Activities left at zero (costing 15%), or Quality measures selected with no benchmark data. Switch to a QCDR that actively guides measure selection and monitors your reporting rate in real time. A score of 75 is achievable in most cases with targeted adjustments.
If You Are Scoring 75–84 and Not Planning to Sell
You are in a good position. Your primary objective is maintaining compliance year-over-year as thresholds rise. Review the Final Rule each November, confirm your measures remain available and well-benchmarked, and verify your PI hardship attestation is renewed annually. Consider whether any Improvement Activities you are already doing qualify for MIPS credit — many practices are completing qualifying activities without documenting them for IA credit.
If You Are Planning to Sell Within 3 Years
Shift your posture from compliance to narrative-building. Target scores of 85 or above for the 2–3 performance years before go-to-market. Document your compliance program formally — measure selection rationale, submission confirmation, feedback report review. Pull your full QPP participation history and give it to Mihama for review. Any prior-year penalties that will still be in the payment window at close need to be disclosed and indemnified in the purchase agreement. Do not let a buyer discover this on their own.
If You Are Below the Low-Volume Threshold
No action is required. However, if your Medicare volume is growing, model your trajectory against the threshold ($90K / 200 patients / 200 services). If you expect to cross any one of these in the next 12–24 months, begin exploring QCDR options now so you have a submission pathway ready when you become mandatory. Voluntary participation while below threshold can also establish a performance baseline that is useful in a pre-sale quality narrative.
Not sure where you stand? Mihama can pull your QPP participation history and provide a plain-language assessment of your MIPS exposure, penalty risk, and pre-sale remediation options as part of a no-cost, no-retainer preliminary practice review. Contact us at info@mihamainc.com or call 347-878-2141.
Your MIPS Track Record Is Part of Your Exit Valuation.
Make Sure It Reflects Well on Your Practice.
Whether you are building compliance from scratch, remediating a gap in your participation history, or preparing the regulatory section of your due diligence package, Mihama’s advisory team works alongside your billing staff, QCDR vendor, and legal counsel to ensure your MIPS narrative is clean, documented, and defensible before a buyer ever sees it. The practices that achieve the highest valuations are the ones that have managed every regulatory detail with the same discipline they bring to patient care.
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