MIPS 2025: A Guide for Eligible Clinicians and Providers

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.
• 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.