MIPS 2025: A Guide for Eligible Clinicians and Providers
The Merit-based Incentive Payment System (MIPS) is part of the Quality Payment Program (QPP), aiming to enhance patient care quality while controlling costs. This program impacts how eligible clinicians are reimbursed for services under Medicare Part B fee for service model. Below is a guide to MIPS 2025, highlighting important updates and key details.
1. Overview of MIPS 2025
MIPS healthcare functions as a value-based care reimbursement model, adjusting Medicare payments based on clinicians’ performance across multiple categories. Designed to reward high-quality, cost-effective care, MIPS for 2025 includes updates reflecting the Centers for Medicare & Medicaid Services’ (CMS) focus on improving healthcare quality while managing costs.
2. Eligibility Requirements
Eligibility for 2025 hinges on clinicians’ participation in Medicare Part B and adherence to specific thresholds. Eligible clinicians include:
- Physicians (MD, DO)
- Nurse Practitioners
- Physician Assistants
- Certified Registered Nurse Anesthetists
- Clinical Nurse Specialists
- Groups or Virtual Groups
To qualify, clinicians must meet at least one low-volume threshold, such as:
- Billing above a defined amount in Medicare Part B.
- Serving a specified number of Medicare patients.
- Delivering a certain number of professional services covered by Medicare Part B.
3. Performance Categories
CMS evaluates clinicians across four main MIPS performance categories, each contributing a certain percentage to the overall score:
- Quality (30%)
Clinicians report data on various quality measures aligned with their specialty and practice type. - Cost (30%)
This category measures the total cost of care for patients, calculated automatically by CMS using Medicare claims data. - Improvement Activities (15%)
Clinicians select activities from a CMS-provided list focusing on care coordination, patient engagement, and safety. High- and medium-weight activities contribute to the overall score. - Promoting Interoperability (25%)
This category assesses the use of certified electronic health record technology (CEHRT) to improve patient care, including e-prescribing and health information exchange.
4. Scoring and Payment Adjustments
- MIPS scores clinicians on a 0-100 point scale, combining performance across all categories.
- Each year, CMS sets a performance threshold; clinicians scoring above this threshold receive positive payment adjustments, while those below may incur penalties.
- High performers may be eligible for additional exceptional performance bonuses.
5. Reporting Requirements
- Clinicians can report individually, as a group, or as part of a virtual group.
- Data submission methods include claims, electronic health records (EHRs), Qualified Clinical Data Registries (QCDRs), and the CMS Web Interface.
6. Proposed Changes and Updates for 2025
CMS continually refines MIPS to enhance its efficiency and impact. Key highlights from the 2025 MIPS Proposed Rule are below:
- Performance Threshold and Data Completeness
The MIPS performance threshold for 2025 remains at 75 points, unchanged from 2023 and 2024, with data completeness criteria also set at 75% through 2028 for all collection types. - Quality Category
- The proposal includes 196 quality measures for 2025, featuring:
- Nine new measures, including two patient-reported outcome measures.
- Removal of 11 measures.
- Significant updates to 66 existing measures.
- Topped Out Measure Benchmarks
- CMS plans to implement a flat benchmarking approach for certain topped-out measures, particularly in specialty areas with limited options. Specific measures will be proposed annually.
- Quality Data Submission Criteria
- To be scored, submissions must include both numerator and denominator data for at least one MIPS quality measure; submissions with only a date and practice ID will be considered invalid.
- For multiple submissions from different organizations, the highest score will be assigned; for the same organization, the most recent submission will take precedence.
- The proposal includes 196 quality measures for 2025, featuring:
- Improvement Activities
The Improvement Activities inventory for 2025 will see:- Two new activities.
- Modifications to two existing activities.
- Removal of eight activities.
- Scoring will be simplified by removing activity weightings, with clinicians only required to attest to one activity under MVP reporting and one or two activities under traditional MIPS, depending on practice size and status.
- For multiple submissions from different organizations, scoring will consider the highest score. The most recent submission will be scored for those from the same organization.
- Promoting Interoperability
- No major changes are proposed; however, automatic reweighting will no longer be available for clinical social workers starting in 2025. Automatic reweighting will only apply to MIPS eligible clinicians with specific special statuses.
- Promoting Interoperability submissions must include performance data, required attestations, a CMS EHR Certification ID, and performance period dates to be valid.
- Cost Category
- Six new episode-based cost measures will be introduced, including one for respiratory infection hospitalization and five for chronic conditions.
- Significant updates will be made to two existing measures to reflect new evaluations.
- A revised cost scoring methodology will be introduced, setting median costs based on the performance threshold. Point ranges will be calculated using standard deviations from this median.
- MIPS Value Pathways (MVPs)
- CMS encourages the adoption of MVPs, which remain voluntary. Feedback is sought on clinician readiness for MVP reporting and policies needed to transition away from traditional MIPS by the 2029 performance period.
- Six new MVPs will be added, covering specialties such as dermatology and urology. The Optimal Care for Patients with Episodic Neurological Conditions and Supportive Care for Neurodegenerative Conditions MVPs will be consolidated into one.
- MVP participants will have all available population health measures calculated, with the highest scoring measure applied to their quality score, removing the requirement to select one.
- Performance Category Reweighting
- Clinicians may request reweighting for quality, improvement activities, or Promoting Interoperability categories if data is inaccessible due to third-party issues.
- Requests must be submitted via the QPP Service Center by November 1 before the relevant MIPS payment year.
7. Preparing for MIPS 2025
- Review Eligibility: Regularly check your eligibility status and thresholds.
- Select Appropriate Measures: Choose quality measures that align with your practice.
- Utilize Certified EHRs: Ensure your technology meets CMS interoperability standards.
- Monitor Performance: Use dashboards and feedback reports to track your progress throughout the year.
- Collaborate with Registries: Engaging with QCDRs can streamline data collection and reporting.
8. Key Deadlines for 2025
- Performance Year: January 1 – December 31, 2025.
- Data Submission Deadline: Generally, by the end of the first quarter (e.g., March 2026).
- Payment Adjustment Year: Adjustments based on 2025 performance will be applied in 2027.
9. MIPS Exemptions and Special Considerations
- Some clinicians may be exempt from MIPS if participating in an Advanced Alternative Payment Model (APM) or if they do not meet low-volume thresholds.
- Hardship exceptions are available for specific situations, such as lack of internet access.
TriumpHealth MIPS Consulting Services
MIPS 2025 aims to incentivize high-quality, cost-effective care. Clinicians should stay informed about updates, carefully select their reporting measures, and utilize available resources to optimize their performance. Successful participation in MIPS can lead to positive payment adjustments, benefiting practices in improving care while maintaining financial viability. The 2025 MIPS payment adjustments are expected to range between -9% and greater than +2% with a perfect score of 100 points expected to yield a positive adjustment of around 2%.
TriumpHealth’s tailored MIPS compliance consulting services help you optimize your score and maintain consistent performance. With expert guidance and innovative tools, we relieve the burdens of MIPS compliance and help you secure the incentives your practice rightfully deserves. Are you ready to embark on your MIPS journey with us? Connect with us today at (888) 747-3836 x0!
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