The Merit-Based Incentive Payment System (MIPS) continues to evolve, raising the stakes for providers and practices in 2025. With 59 measures changing, new additions, and others removed, this year’s reporting landscape introduces some of the toughest measures providers have ever faced .

For healthcare providers, practice managers, and clinical managers, understanding these changes is critical. Reporting errors or missed opportunities can mean up to a 9% penalty on future Medicare reimbursements, a serious hit to revenue. This blog highlights the most challenging measures for 2025, why they matter, and strategies to navigate them successfully.

Why 2025 MIPS Reporting Will Be Tougher

MIPS measures change every year. For 2025, CMS has introduced significant updates:

• 59 measures updated and 29 proposed for changes in 2026
• Stricter benchmarks and scoring thresholds
• Greater emphasis on outcome and patient-centered measures
• Removal of duplicative, low-value, or topped-out measures
• Introduction of new specialty-specific measures to align with value-based care goals

The result? Providers must adapt quickly to maintain compliance and protect revenue.

Benchmarking and Scoring Challenges

MIPS scoring depends heavily on benchmarks, which compare provider performance nationally. To be scored:

• A benchmark must exist for the collection type.
• At least 20 cases must be reported.
• Data completeness must meet the 75% threshold .

New measures in 2025 carry a 7-point floor, while second-year measures drop to a 5-point floor. Highly topped-out measures are capped at 7 points, no matter how well providers perform .

This makes measure selection and reporting strategy more critical than ever.

The Toughest Measures in 2025

1. M226: Preventive Care and Screening – Tobacco Use

• Requires multiple patient visits within a timeframe.
• High documentation burden with strict criteria for screening and cessation counseling.
• Audit risk increases if documentation is incomplete .

2. M178: Rheumatoid Arthritis – Functional Status Assessment

• Requires two diagnosis encounters within a set period.
• Designed to ensure attribution of specialists, but creates reporting complexity.
• Reliance on structured documentation can slow workflows.

3. M340: HIV Annual Retention in Care

• Can be met in two ways:
  —   Two eligible encounters 90 days apart
  —   One eligible encounter + viral load test 90 days apart

• Challenging for practices with small patient volumes or inconsistent follow-up rates.

These measures require data precision and consistent follow-up, making them especially tough for practices with complex patient populations.

New Measures for 2025 Worth Noting

All new measures have a 7-point floor to incentivize reporting. Examples include:

• #506: PD-L1 Biomarker Testing Before First-Line Immunotherapy
• #507: Germline Testing for Ovarian Cancer
• #508: Adult COVID-19 Vaccination Status
• #509: Melanoma Recurrence Tracking
• #510 & #511: Organ transplant waitlist ratios

While they offer new opportunities, the reporting requirements and case minimums can make them difficult for smaller or specialty practices.

Removed Measures in 2025

Providers can no longer report certain measures, such as:

• #019: Diabetic Retinopathy Communication
• #104: Prostate Cancer ADT Therapy
• #254: Ultrasound for Pregnancy Location
• #439: Age-Appropriate Screening Colonoscopy

This means practices relying on these for easier scoring will need to find replacements, often more complex measures.

Strategies to Navigate Tough Measures

1. Align with Specialty Measures: Choose measures relevant to your specialty (oncology, radiology, orthopedics, PT/OT).

2. Focus on High-Impact Measures: Prioritize outcome-based and patient engagement measures with strong scoring potential.

3. Evaluate Data Capture: Ensure your EHR, registry, or claims process can reliably capture required data.

4. Plan for Long-Term Success: Select measures that can improve both compliance and patient care over time.

5. Leverage Registry Reporting: Registries (QCDRs) often provide more reliable reporting options than claims or EHR-only submissions .

Tough vs. Easier 2025 MIPS Measures: At a Glance

How TriumpHealth Helps

At TriumpHealth, we specialize in helping providers succeed with MIPS reporting,  even with tough measures. Our experts:

• Guide you in measure selection and benchmarking strategy
• Ensure data completeness and compliance with CMS rules
• Provide audit-ready documentation support
• Maximize scoring to avoid penalties and unlock incentives

Whether you’re navigating tobacco cessation, RA functional assessments, HIV retention, or new biomarker reporting requirements, we make MIPS reporting less burdensome and more rewarding.

Need help managing tough MIPS measures?

2025 brings a tougher MIPS environment, with stricter rules, higher benchmarks, and complex measures that test both documentation and compliance processes. By understanding these challenges and strategically planning your reporting, you can protect revenue and avoid penalties.

Contact TriumpHealth today. Our experts can evaluate your specialty, patient mix, and reporting workflows to create a customized plan for MIPS success. For more details you can schedule a consultation, or call us at (888) 747-3838 x0, or email us at [email protected].