For the 2025 Performance Year (PY), Providers can select from 195 quality measures approved by CMS. Data needs to be collected and submitted for each selected quality measure for the entire 2025 calendar year.

To meet the Quality performance category requirements, a MIPS eligible provider, group, or virtual group can report:

• 6 quality measures (including at least one outcome measure or high priority measure in absence of an applicable outcome measure) for the 12-month performance period; OR
• A defined specialty measure set (if the measure set has fewer than 6 measures, all measures within that set need to be submitted)

Data Completeness

For 2025, the data completeness requirement is 75%. Providers need to report performance or exclusion/exception data for at least 75% of patients or encounters that are eligible for the measure’s denominator.

What’s New with Quality in 2025?

• The quality performance category weight remains 30% for individual MIPS eligible providers, groups, and virtual groups participating in traditional MIPS.
• Minimum criteria for a submission for the quality performance category has been defined as numerator and denominator information for at least one quality measure from the list of MIPS quality measures to be considered a data submission and scored.
• CMS finalized a total of 195 quality measures for the 2025 performance period.
• CMS has finalized an alternative benchmarking methodology to a subset of topped out measures that belong to specialty sets with limited measure choice.
• One measure achievement point would be added for each submitted eCQM for an APM Entity or virtual group that meets data completeness and case minimum requirements. This is the new policy of complex organization adjustment to account for the organizational complexities facing APM Entities (including Shared Savings Program ACOs) and virtual groups when reporting eCQMs.

What’s New with Promoting Interoperability (PI) in 2025?

What’s New with Improvement Activities (IA) in 2025?

• Addition of 2 new IAs, it includes an MVP-specific improvement activity titled “Practice-Wide Quality Improvement in MIPS Value Pathways”.
• Modification of 1 existing improvement activities.
• Removal of 4 existing improvement activities.
• Activity weightings are removed to simplify scoring and complement the ongoing efforts to refine and improve the Inventory.
• Minimum submission criteria is that a submission for the improvement activities performance category must include a “yes” response for at least one improvement activity to be considered a data submission and scored.

For the 2025 PY, the Cost category is included in the final score and is weighted for 25% of the final score. Cost will be calculated directly by CMS and therefore no submission will be required.

• The reporting period will be for the full PY in 2025.
• Individual eligible providers or groups will be scored on 29 measures included in the Cost performance category.
• Addition of 6 new Episode-based measures.
• New cost measure exclusion policy beginning with the CY 2025 performance period.
• CMS has revised the cost scoring benchmarking methodology starting in 2025 performance period. The finalized cost scoring methodology will use a new distribution for cost scoring in which the median cost for a measure will be set at a score derived from the performance threshold established for that MIPS payment year.

Reweighting of Performance Categories

Beginning with the 2025 performance period, automatic reweighting will only apply to MIPS eligible clinicians, groups, and virtual groups with the following special statuses

• Ambulatory Surgical Center (ASC)-based
• Hospital-based
• Non-patient facing
• Small practice

Merit-Based Incentive Payment (MIPS) Background

The Centers for Medicare and Medicaid Services (CMS) introduced the Quality Payment Program in 2015 with two tracks: MIPS and Advance Payment Model (APM).

In MIPS, performance-based payment adjustments are made for the services provided to Medicare patients based on a Final Score. Performance is measured across 4 areas – Quality, Improvement Activities (IA), Promoting Interoperability (PI) and Cost.

As the MIPS program has matured, the difficulty of avoiding payment penalties has been steadily increasing. Also, clinicians and stakeholders have expressed that MIPS is overly complex.

What are MVPs?

MVP is a conceptual participation framework applying to future proposals beginning with the 2025 performance year. The MVP framework aims to align and connect measures and activities across the Quality, Cost, PI, and IA performance categories of MIPS for different specialties or conditions. MVPs are based on a specialty, medical condition, or episode of care and are established through the CMS rule- making process.

How are MVPs going to make reporting more meaningful?

Traditional MIPS reporting can be confusing. Scoring logic and the reporting requirement of each category are unique. In addition, there are many measures and activities to choose from, many of which are not relevant to a clinician’s specialty.

The introduction of MVPs is a landmark change aimed at reducing the reporting burden while also moving away from certain activities and measures. Reporting on an aligned set of performance measure options relevant to a clinician’s scope of practice is more meaningful to clinicians, allows patients and caregivers to make more informed choices using comparative performance data and places greater emphasis on patient care. MVPs also reduce barriers to APM participation and support the transition to digital quality measures.

For multispecialty groups, the MVP subgroup reporting option provides a way to report performance information meaningful to the various specialties and teams within the group.

Who can report MVPs?

For the 2025 MIPS performance period, MVPs may be reported by individual MIPS eligible clinicians, multi-specialty groups, single-specialty groups, subgroups, or APM Entities.

First steps to prepare for MVP reporting

MVPs will be available for submission in performance year 2025. Being informed about the nuances of the evolution of MVPs will enable clinicians to choose the best possible option for their reporting, aiming to earn positive payment adjustments, simplify the reporting and enable better focus on patient care. What MIPS Value Pathways (MVPs) are available for reporting in 2025?

• Adopting Best Practices and Promoting Patient Safety within Emergency Medicine
• Advancing Cancer Care
• Advancing Care for Heart Disease
• Advancing Rheumatology Patient Care
• Complete Ophthalmologic Care
• Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes
• Dermatological Care
• Focusing on Women’s Health
• Gastroenterology Care
• Improving Care for Lower Extremity Joint Repair
• Optimal Care for Kidney Health
• Optimal Care for Patients with Urologic Conditions
• Patient Safety and Support of Positive Experiences with Anesthesia
• Prevention and Treatment of Infectious Disorders Including Hepatitis C and HIV
• Pulmonology Care
• Quality Care for Patients with Neurological Conditions
• Quality Care for the Treatment of Ear, Nose, and Throat Disorders
• Quality Care in Mental Health and Substance Use Disorders
• Rehabilitative Support for Musculoskeletal Care
• Surgical Care
• Value in Primary Care

1. If you identify a relevant MVP, check if you are already submitting for the quality measures. If so, how do your previous year’s scores look like? Then look at the listed IAs to see if you are already reporting on them.
2. Ideas for an additional MVP that supports meaningful measurement of a specialty, condition or public health priority that is meaningful to patient care can be brought to CMS as they have published guidelines for Candidate Development and Submission.
3. It is expected that CMS will publish more MVPs in the proposed rule 2025. After reviewing if any of the MVPs pertain to your specialty/practice, send your comments to CMS.
4. Remember that all PI measures are mandatory unless exceptions are claimed. Review and update your health-IT systems as per the requirements.