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MIPS Reporting 2025: How to Stay Compliant Without an EHR

MIPS

MIPS Reporting 2025: How to Stay Compliant Without an EHR

Why MIPS Reporting Still Matters in 2025

Many providers assume that without a certified Electronic Health Record (EHR), they cannot participate in the Merit-Based Incentive Payment System (MIPS). This misconception can be costly, leading to missed incentives and penalties as high as 9% on future Medicare reimbursements.

With CMS raising the MIPS performance threshold each year, failing to report puts providers at serious financial risk. The good news: even without an EHR, there are two clear pathways to meet CMS requirements and protect your bottom line.

Option 1: Claims-Based MIPS Reporting

For solo practitioners and small practices (≤15 clinicians), Claims-Based Reporting is the most straightforward path.

  • How it Works:
    Quality measures or a MIPS Value Pathway (MVP) are reported directly through Medicare Part B claims using Quality Data Codes (QDCs) or modifiers.
  • Advantages:
    • No additional fees
    • Simple, low-cost entry point
    • Designed for small practices and solo providers
  • Limitations:
    • Only applies to the Quality category
    • Risk of missed codes resulting in lost credit
Best for solo providers or very small practices seeking a cost-effective solution.

Option 2: Registry MIPS Reporting

Registry Reporting is more comprehensive and preferred by many providers without an EHR.

  • How it Works:
    Data is extracted from billing software or paper charts, compiled in spreadsheets, and uploaded into a CMS-approved Qualified Registry or QCDR.
  • Advantages:
    • Covers multiple categories: Quality, Improvement Activities, and (where applicable) Promoting Interoperability
    • Reduces risk of missed coding
    • More reliable than claims-only reporting
  • Considerations:
    • Registry fees typically start at ~$350–$500 per provider
    • Requires additional setup and data submission processes
Best for providers seeking a robust, reliable, and compliant reporting solution.

Choosing the Right Pathway

  • Solo providers may benefit from the simplicity of claims-based reporting.
  • Growing practices may find registry reporting worth the investment for its reliability and broader category coverage.

The most important takeaway: not having an EHR does not exclude you from MIPS. Both options keep you compliant, help avoid Medicare penalties, and open the door to performance-based incentives.

How TriumpHealth Supports MIPS Success

At TriumpHealth, we partner with providers to ensure seamless MIPS reporting in 2025. Our expert consultants help you:

  • Select the right measures or MVP for your specialty
  • Ensure documentation and coding meet CMS requirements
  • Manage data collection, validation, and timely submission
  • Optimize scores to avoid penalties and maximize incentives

Whether you report through claims, a registry, or an EHR, TriumpHealth MIPS consulting team ensures compliance and helps you turn reporting into a strategic advantage. Unsure which option fits your practice? Schedule a Consultation with MIPS experts, or contact us at [email protected] or call (888) 747-3838 x0.

Disclaimer:

The content provided by TriumpHealth is for informational purposes only and does not constitute legal, medical, or financial advice. Regulations and payer requirements may change; please consult a qualified professional for guidance specific to your situation. Click here to review our full legal disclaimer.