The Merit-based Incentive Payment System (MIPS) is one way healthcare providers can participate in the Quality Payment Program (QPP) established by the Centers for Medicare and Medicaid Services (CMS). MIPS is one way to participate in the Quality Payment Program (QPP).

MIPS combines three previously separate quality and value reporting programs into a single, streamlined system:

• Physician Quality Reporting System (PQRS)

• Value-Based Modifier (VBM)

• Electronic Health Record (EHR) Meaningful Use program

MIPS was created through the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), which was designed to change how Medicare rewards clinicians for value over volume. MACRA created the Quality Payment Program that repeals the Sustainable Growth Rate formula, changes the way that Medicare rewards clinicians for value over volume, and streamlines multiple quality programs under the new Merit Based Incentive Payments System (MIPS).

Key Changes for 2025:

• Performance Threshold: For the 2025 performance year, CMS has maintained the performance threshold at 75 points, the same as the 2023 and 2024 performance years. CMS finalized maintaining the current threshold to avoid a penalty at 75 points in 2025. Due in part to advocacy efforts, CMS proposes to maintain the current performance threshold of 75 points in 2025.
  
  

• Category Weights: There will be no changes to performance category weights in 2025. There will be no changes to performance category weights in 2025. The weights will remain:
  
  

  • Quality: 30%

  • Cost: 30%

  • Improvement Activities: 15%

  • Promoting Interoperability: 25%

• Data Completeness Threshold: CMS will maintain the data completeness threshold at 75% through performance years 2025-2028. CMS will maintain the data completeness threshold at 75% in performance years 2025 – 2028.
  
  

• Improvement Activities Scoring Change: Starting in 2025, CMS is removing activity weightings for improvement activities to simplify scoring. CMS will remove activity weightings for the 2025 performance year to simplify scoring and reduce the number of activities clinicians are required to attest to completing to achieve a full score in this performance category.
  
  

Hardship Exemptions: The MIPS hardship exemptions related to COVID-19 are no longer available for the 2025 performance year. Similarly, the Change Healthcare cyberattack exemption was specific to the 2024 performance year and is not available for 2025. CMS will not accept MIPS EUC exception applications due to COVID-19 for the 2024 performance year and this policy continues into 2025. For the 2025 performance year, providers must apply for standard hardship exemptions based on current extreme and uncontrollable circumstances, which typically include natural disasters, practice closures, severe financial distress, or vendor issues.

Clinicians are required to participate in MIPS if they are:

• An eligible clinician type (physicians, physician assistants, nurse practitioners, etc.)

• Have enrolled as a Medicare provider before January 1 of the performance year

• Meet certain threshold requirements for Medicare patients and charges

A clinician is required to participate in MIPS (i.e., is MIPS-eligible) if he/she is an eligible clinician type and has enrolled as a Medicare provider before January 1, 2024.

To check if you need to submit MIPS data, you can visit the CMS MIPS Participation Status website, which will tell you whether you're required to participate based on your specific circumstances. To view your eligibility status, use the QPP Participation Status Tool.

Some healthcare providers may be exempt from MIPS reporting requirements, including:

• Newly-enrolled Medicare providers

• Providers who don't exceed the low-volume threshold

• Qualifying participants in Advanced Alternative Payment Models (APMs)

Extreme and uncontrollable circumstances are defined as rare events entirely outside of your control and the control of the facility in which you practice. Extreme and uncontrollable circumstances are defined as rare events entirely outside of your control and the control of the facility in which you practice.

Clinicians impacted by such events can apply for a hardship exemption for MIPS performance categories. The MIPS hardship exception application period usually opens on January 1 of the following MIPS performance year and closes on December 31 of the same year.

For the 2024 performance year, CMS has added an option specifically for practices affected by the Change Healthcare cyberattack. Due to the ongoing impact of the Change Healthcare cyberattack on physician practices, the Centers for Medicare & Medicaid Services (CMS) has added an option to cite the cyberattack when requesting a hardship exemption within the 2024 Merit-based Incentive Payment System (MIPS).

Yes, providers have multiple participation options for MIPS:

"Participation options" refers to the levels at which data can be collected and submitted, or "reported," to CMS for MIPS. There are 5 participation options: individual, group, virtual group, subgroup, and APM Entity.

• Individual: A single National Provider Identifier (NPI) tied to a single Tax Identification Number (TIN). Your MIPS score will be calculated based on your individual performance.
  
  

• Group: At least 2 clinicians identified by their individual NPIs sharing a common TIN. All the eligible clinicians in the group will get one MIPS score based on the group's performance.
  
  

• Virtual Group: A combination of two or more TINs assigned to one or more solo practitioners or one or more groups consisting of 10 or fewer eligible clinicians that elect to form a virtual group for a performance period.
  
  

• Subgroup: A subset of a group that contains at least one MIPS eligible clinician. Subgroups will consist of a subset of a group that contains at least one MIPS eligible clinician and is identified by a combination of the group TIN, the subgroup identifier, and each eligible clinician's NPI.
  
  

APM Entity: Clinicians participating in an Alternative Payment Model.