2025 Key MIPS Program Updates
On November 1, 2024, CMS released the final rule for the 2025 Medicare Physician Fee Schedule, introducing substantial updates for the Merit-Based Incentive Payment System (MIPS). These changes reflect CMS’s ongoing efforts to streamline quality reporting, enhance accuracy, and support the transition toward value-based care. Here’s a summary of the key updates and how they will impact clinicians and ACOs.
1. Quality Performance Category
Data Submission and Completeness: Clinicians must maintain a data completeness rate of at least 75% for the 2027 and 2028 performance periods.
Measure Inventory: CMS has updated the MIPS measure inventory to 195 quality measures, with 192 applicable to traditional MIPS and three specific to MIPS Value Pathways (MVPs). CMS has also codified criteria for the removal of obsolete quality measures.
2. Cost Performance Category
New Episode-Based Measures: Six new episode-based cost measures will be introduced in 2025, covering conditions like Chronic Kidney Disease, Prostate Cancer, and Rheumatoid Arthritis. This is designed to provide a more nuanced assessment of cost performance across diverse patient populations.
Case Minimums and Benchmarking: Each new measure will have a 20-case minimum requirement, ensuring accurate performance evaluation. CMS is also updating existing measures, including those for Cataract Removal and Percutaneous Coronary Intervention (PCI), to reflect revised benchmarks.
3. Improvement Activities Performance Category
Inventory Updates: CMS will add two new improvement activities, modify two, and remove four to refine the list and ensure relevance. A delayed implementation for some modifications and removals is scheduled for 2026.
Scoring and Reporting Changes: The new rule eliminates activity weighting and reduces the number of required attestations to achieve a score in this category. CMS has also codified criteria for improvement activity removal, focusing on clinical impact and alignment with program goals.
4. Promoting Interoperability Performance Category
No major updates for the Promoting Interoperability (PI) category in 2025, but CMS will maintain its role as a critical component of MIPS, supporting data sharing and health IT use.
5. MIPS Scoring and Payment Adjustments
Quality Scoring: Topped-out measures in limited specialty sets will now follow a defined benchmark with all deciles represented, improving transparency and scoring equity.
Complex Organization Adjustment: CMS introduces an adjustment for virtual groups and APM entities reporting eCQMs, giving an additional point per measure achievement, capped at 10% of available quality points.
Threshold for Payment Adjustments: A 75-point performance threshold will be established for the 2025 performance period, determining eligibility for positive adjustments in 2027.
6. Advanced APM Incentives
Threshold Adjustments: CMS will adjust thresholds for APM participation, aiming to promote continued engagement in value-based models. For 2026, a qualifying APM Participant (QP) must meet a threshold score, ensuring meaningful participation.
Incentive Payment: APM clinicians meeting the thresholds will receive a 1.88% incentive payment for the 2026 payment year, reinforcing financial rewards for value-based care.
These updates demonstrate CMS’s ongoing commitment to refining MIPS and supporting the evolution toward quality-focused, value-based care. As the program progresses, clinicians and ACOs will need to stay informed about new requirements, especially as reporting shifts further towards digital quality measures (dQMs).
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