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Navigating MIPS Reporting: Updates for 2025

October 14, 2024

The Medicare Merit-Based Incentive Program System (MIPS) remains a cornerstone of the U.S. Government’s efforts to ensure quality healthcare delivery while containing costs. As we delve into the changes for the 2025 reporting year, it's crucial to understand how these adjustments will influence your MIPS reporting journey. Let’s explore the key policy updates and their implications.

provider completing MIPS report

Performance Threshold and Quality Performance Category Updates

The performance threshold for 2025 remains at 75 points, mirroring preceding years. Final MIPS scores are juxtaposed against this threshold to ascertain the MIPS payment adjustment.

Clinicians must still meet a 75% data completeness threshold, up from 70% in 2023. This adjustment ensures that reported data adequately reflects quality performance.

Additionally, the Quality measure inventory has several proposed changes by way of additions and possible removal of over ten measures. Notably, CMS is proposing to flatten several topped-out measure benchmarks for certain specialty sets which see limited new measure development and limited options.

Improvement Activities Category and Promoting Interoperability Updates

The Improvement Activities (IA) category proposes addition of two new activities, removal of eight activities, and modification to two others. The proposed new measures are:

  • Implementation of Protocols and Provision of Resources to Increase Lung Cancer Screening Uptake
  • Save a Million Hearts: Standardization of Approach to Screening and Treatment for Cardiovascular Disease Risk

Promoting Interoperability (PI) category measures have not seen a significant change in the proposed rule. There is an adjustment starting with the 2025 performance period where Clinical Social Workers no longer have automatic reweighting, and reweighting will only apply to MIPS eligible clinicians or groups in certain categories.

Cost Category Enhancements and MIPS Value Pathways (MVPs)

The cost category is proposed to introduce six new measures at the group clinician levels, as long as such reporters have a minimum of twenty episodes. There are also significant updates to two existing measures after re-evaluation:

  • Cataract Removal with Intraocular Lens (IOL) Implantation (formerly Routine Cataract with IOL Implantation)
  • Inpatient Percutaneous Coronary Intervention (PCI) (formerly ST-Elevation Myocardial Infarction [STEMI] PCI)

Cost measurement may undergo a revision starting with the 2024 performance year (for scores released in mid-2025). This entails revising cost methodology such that median cost for a measure is set at a score based on the performance threshold for that payment year. 

ACO Impact

The latest CMS proposal indicates changes to the quality measure reporting and scoring process for thos ACOs enrolled in the Medicare Shared Savings Program (MSSP). This proposal would establish a new, eight measure quality measure set with required use by MSSP ACOs starting in 2025. More information is available about this update here.

While the final rule is not set to be released until November, 2024 we can anticipate that there are several important changes to MIPS reporting for clinicians in the coming year. Though the reporting process for MIPS is now well-established, complexities in data aggregation or EHR reporting capabilities may further complicate an already challenging annual process. 

Don’t let MIPS reporting difficulties hinder your practice's success. Reach out to the ZapEHR team today at [email protected] to discover how we can simplify your reporting journey and help you achieve maximum reimbursement. 

FAQs about MIPS Reporting for 2025

1. What is MIPS and who is eligible to participate?

MIPS, or the Merit-based Incentive Payment System, is a performance-based payment adjustment system for Medicare clinicians. Eligible participants include physicians, nurse practitioners, clinical nurse specialists, and physician assistants who bill Medicare Part B.

2. What are the key MIPS updates for the 2025 reporting year?

For 2025, the performance threshold remains at 75 points, data completeness increases to 75%, and new quality and cost measures have been introduced. There are also changes to Improvement Activities and updates for Accountable Care Organizations (ACOs).

3. What is the MIPS performance threshold for 2025?

The performance threshold for MIPS in 2025 is set at 75 points, the same as in previous years.

4. What are the new quality measures in MIPS 2025?

The 2025 updates propose adding new quality measures, especially in specialty sets like lung cancer screening and cardiovascular disease prevention, while removing certain outdated measures.

5. What is the data completeness threshold for MIPS 2025?

Clinicians must report on at least 75% of their patients for the quality measures they choose, an increase from the 70% threshold in 2023.

6. What changes are happening in the MIPS Improvement Activities category for 2025?

The 2025 proposal includes two new Improvement Activities focused on lung cancer screening and cardiovascular disease prevention, while eight existing activities are set to be removed.

7. What are MIPS Value Pathways (MVPs), and how do they affect reporting in 2025?

MIPS Value Pathways (MVPs) offer streamlined reporting options by focusing on specific clinical areas. In 2025, new MVP options will be available, particularly in cost measurement categories.

8. How does the MIPS cost category change in 2025?

Six new cost measures are being introduced, and updates are proposed for existing measures like cataract surgery and coronary intervention procedures.

9. What impact do these MIPS updates have on ACOs?

Starting in 2025, ACOs participating in the Medicare Shared Savings Program (MSSP) will need to comply with a new eight-measure quality set to continue their participation.

10. How can MIPS participants maximize their score and avoid penalties?

Clinicians can maximize their MIPS score by carefully selecting quality measures, participating in improvement activities, and using certified EHR technology to track and report performance data accurately.

11. What happens if a clinician fails to meet the MIPS performance threshold?

Failing to meet the MIPS threshold results in a negative payment adjustment to Medicare Part B reimbursements for the following year.

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Mordechai Raskas
Mordechai Raskas

Chief Medical Information Officer at PM Pediatric Care