I have 2 physical medicine doctors who are a private PC, and only see patients in the hospital setting.   When our patients are transferred to the rehab floor, we use place of service 61 - which is negating the facility based status the providers previously were categorized under.   We do bill place of service 21 also, but it does not equal 75% as required by MIPS.  Since place of service 61 is an Inpatient Rehabilitation Facility, why is this not taken into consideration when weighing the measures on the MIPS?

We have worked with the AAPM&R and they gave me a cross match to see if the codes we billed would qualify to report and they said there is no way we could meet any of the measures.