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  • Succeeding at MIPS

    This content was excerpted from EyeNet’s MIPS 2019; also see the Academy’s MIPS hub page

    What is your MIPS goal for 2019? Whether it is to earn the exceptional performance bonus or simply to avoid the payment penalty, the Acad­emy can help you to succeed.

    Start by asking yourself the following six questions.

    Q1. Do you have to take part in MIPS? Use the QPP Participation Status Lookup tool and enter your 10-digit National Provider Identifier (NPI) to see whether CMS considers you to be a MIPS eligible clinician, and to learn about other aspects of your MIPS status, such as whether CMS classifies your practice size as small or large. Tip: If you are in more than one practice, scroll down to see your status at each practice.

    Q2. Have you signed up for the IRIS Registry? Ophthalmology’s tool-of-choice for MIPS reporting is free for Academy members. Learn more about using the IRIS Registry for MIPS.

    Q3. Should you participate in MIPS as an individual or as part of a group? There are some advantages to group-level reporting, but also some caveats—for example, if you qualify for a low-volume exclusion from MIPS, you may lose that exclusion if reporting as part of a group. Download the CMS guide to group-level reporting (PDF).

    Q4. Has your practice named a MIPS point person? This can be a physician or an office administrator; if the latter, your practice also should have a physician MIPS champion.

    Q5. Are you up to speed on MIPS? See Your Nine-Step To-Do List for MIPS Resources. For a quick introduction to MIPS, start with either the Small Practice Roadmap or the Large Practice Roadmap, and make sure you know the key dates for performance year 2019.

    Q6. What if you have a MIPS conundrum? If you can’t find your answer among the Academy’s extensive MIPS resources, you can email the Academy with questions about MIPS ( or about the IRIS Registry (irisregistry@ And, the e-Talk listserv provides AAOE members with a popular forum for exchanging MIPS tips. (Not a member of the AAOE? Visit to learn more about member benefits and how to join).

    Table 1: Help! I Am a Solo Practitioner With no EHR

    There is a common misconception that you cannot avoid the MIPS payment penalty if you don’t have EHR. That is not the case in 2019.
    Example: Dr. Argus, a solo practitioner with no EHR, avoids the payment penalty.
    To avoid a payment penalty, Dr. Argus needs a 2019 MIPS final score of at least 30 points. There are accommodations for small practices that can help him achieve that score.
    Improvement activities: Dr. Argus selects one high-weighted activity and performs it for 90 days. Because small practices score double for improvement activities, this earns him an improvement activities performance category score of 100%, which contributes 15 points to his MIPS final score.    
    Quality measures: For six quality measures, Dr. Argus reports one patient at least one time. He earns 24 points (3 points per quality measure,* plus a small practice bonus of 6 points), which translates to a quality score of 40%. This contributes 18 points to his MIPS final score. (Note: If Dr. Argus is reporting manually via the IRIS Registry, he would need to submit data-completeness totals for those measures.)
    Dr. Argus’ MIPS final score: 33 points. 
    Note: If a promoting interoperability (PI) exception applies, quality’s weight in the final score will increase, as a result, Dr. Argus’ MIPS final score would get a boost.   
    What if Dr. Argus was in a large practice? Clinicians in large practices need to do more to avoid the payment penalty. They must report more improvement activities and must do more than minimal reporting to earn 3 achievement points for a quality measure.  
    * To earn more than 3 achievement points for a quality measure, Dr. Argus would have to meet the two data submission thresholds and the measure must have a benchmark

    Previous: Your 9-Step To-Do List for MIPS Resources

    Next: Fundamentals: Timeline for Performance Year 2019

    DISCLAIMER AND LIMITATION OF LIABILITY: Meeting regulatory requirements is a complicated process involving continually changing rules and the application of judgment to factual situations. The Academy does not guarantee or warrant that regulators and public or private payers will agree with the Academy’s information or recommendations. The Academy shall not be liable to you or any other party to any extent whatsoever for errors in, or omissions from, any such information provided by the Academy, its employees, agents, or representatives.

    COPYRIGHT© 2019, American Academy of Ophthalmology, Inc.® All rights reserved. No part of this publication may be reproduced without written permission from the publisher. American Academy of Ophthalmic Executives® and IRIS® Registry, among other marks, are trademarks of the American Academy of Ophthalmology®.

    All of the American Academy of Ophthalmology (AAO)–developed quality measures are copyrighted by the AAO’s H. Dunbar Hoskins Jr., MD, Center for Quality Eye Care (see terms of use).