On November 1, 2024, the Centers for Medicare & Medicaid Services (CMS) released the 2025 Medicare Physician Fee Schedule (PFS) Final Rule, unveiling important changes to the Merit-based Incentive Payment System (MIPS) for the 2025 performance year. With CMS’s ongoing commitment to advancing value-based care, these updates reflect a push for simplification, better quality measures, and improved interoperability. Here’s a breakdown of what’s new and what clinicians need to know to succeed in MIPS for 2025.
1. 2025 MIPS Final Rule Performance Thresholds and Scoring Updates
Performance Threshold: The minimum score to avoid a penalty remains at 75 points, maintaining the same threshold as in recent years.
Data Completeness: Practices must report 75% of all eligible cases for quality measures, a requirement that remains consistent to ensure robust data collection.
Exceptional Performance Bonus: The exceptional performance bonus is no longer available as the program continues its transition toward more streamlined scoring.
2. Quality Performance Category Changes (30% of the Final Score)
CMS introduced seven new quality measures and removed 10 outdated measures to ensure relevance and accuracy.
Measures now reflect broader priorities, such as health equity and patient outcomes, with changes to 66 existing measures.
Removal of the 7-point cap for topped-out measures in limited specialty sets, addressing challenges for specialties with fewer reporting options.
3. Cost Performance Category Updates (30% of the Final Score)
Six new episode-based cost measures have been added, focusing on specialty-specific and procedure-specific costs.
Adjustments to existing cost measures reflect better alignment with clinical outcomes, making it crucial for practices to monitor their efficiency and resource utilization.
4. Promoting Interoperability (PI) Adjustments (25% of the Final Score)
CMS has updated interoperability requirements to include better integration of Health Information Exchange (HIE) measures.
The final rule streamlines the handling of multiple submissions and provides new flexibility for practices managing complex EHR systems.
Small practices and clinicians facing significant hardships can continue to apply for PI category reweighting.
5. Streamlined Improvement Activities (IA) (15% of the Final Score)
The Improvement Activities category now features simplified reporting requirements, aiming to reduce administrative burden while ensuring meaningful participation.
CMS continues to emphasize initiatives like telehealth, care coordination, and patient engagement, which many practices already implement.
6. Expansion of MIPS Value Pathways (MVPs)
CMS finalized six new MVPs for specialties such as:
Dermatology
Pulmonology
Gastroenterology
Urology
Surgical care
These pathways consolidate traditional MIPS measures, focusing on aligned sets of activities and outcomes relevant to specific specialties.
7. APP Plus for APM Participants
Introduction of the APP Plus measure set, incorporating 11 measures, including the six current APP measures and five from the Adult Universal Foundation measure set.
This expanded pathway simplifies reporting for ACOs and other Advanced Payment Models (APMs).
What This Means for Clinicians
The 2025 Final Rule reflects CMS’s intention to refine the MIPS program while encouraging greater participation and aligning with the goals of value-based care. Here are key takeaways:
Stay Ahead of Deadlines: Familiarize yourself with the updated requirements and begin planning your reporting strategies early.
Monitor New Cost Measures: Evaluate how new cost measures may impact your practice and implement efficiency-focused changes where needed.
Leverage MVPs: Specialty practices should consider adopting MVPs, which offer streamlined reporting tailored to specific fields.
Apply for Hardship Exceptions: Practices facing significant challenges with Promoting Interoperability should explore reweighting options to avoid penalties.
The 2025 MIPS Final Rule introduces critical updates designed to streamline reporting and enhance care quality. Whether through new cost measures, expanded MVPs, or simplified improvement activities, CMS is aligning MIPS with broader value-based care goals. Clinicians and practices must stay informed, adapt to the changes, and optimize their strategies to succeed in this evolving landscape.
If you’re looking for guidance on navigating these changes, our consulting services can help you optimize your MIPS performance while minimizing administrative burdens. Contact us today to get started! (803-205-2544)
