2025 MIPS Updates: What You Need to Know
2025 MIPS Updates: What You Need to Know
New changes to the Quality Payment Program’s (QPP) Merit-based Incentive Payment System (MIPS) may impact how you manage your practice.
The MIPS categories — Quality, Cost, Promoting Interoperability, and Improvement Activities — will remain the same for calendar year (CY) 2025, but each of the categories have updates that were issued in the Centers for Medicare & Medicaid Services (CMS) MIPS Final Rule.
Here, we’ll review some of the key changes that may impact ModMedⓇ clients.
2025 MIPS key rules
While there are a number of detailed changes to program measures, here are a few key rules that have NOT changed this year:
- You must submit a score of at least 75 out of 100 points in order to avoid a penalty of up to -9% on your 2027 Medicare reimbursements.
- If you score 75 or above, you may be eligible for a positive payment adjustment in 2027. The amount paid out will be scaled to meet budget neutrality.
- If you choose to report a MIPS Value Pathway (MVP), you’ll need to register with CMS. MVP registration is slated to open in April 2025, but be sure to keep an eye on the CMS website for official registration deadlines.
- The weight of each category remains as follows:
- Quality: 30%
- Cost: 30%
- Promoting Interoperability: 25%
- Improvement Activities: 15%
Take the time to prepare your practice for upcoming changes now. ModMed clients can sign up for our MIPS Advisory Services to get extra MIPS support.
MIPS Value Pathways
MIPS Value Pathways (MVPs) are a predetermined subset of measures and activities related to a specialty or medical condition. It’s important to understand MVPs, since CMS plans to sunset traditional MIPS in the future and make reporting MVPs mandatory for nearly all participants.
For the 2025 performance year, CMS has added six new and modified 12 existing MVPs.
New MVPs
- Complete Ophthalmological Care
- Dermatological Care
- Gastroenterology Care
- Optimal Care for Patients with Urologic Conditions
- Pulmonary Care
- Surgical Care
In the 2025 performance period, ModMed plans to support the orthopedic and dermatological MVP measures within our EMA EHR. As additional measures are finalized, our teams will assess them and make them available in EMA and gGastro EHRs, when appropriate.
To see the full list of MVPs available for reporting in 2025, download the 2025 Finalized and Modified MVPs Guide.
Updated MVP registration requirement: Population health measure
New in 2025, MVP participants are no longer required to select a population health measure as part of their MVP registration. CMS will now calculate all available population health measures for an MVP participant and apply the highest-scoring one to their Quality performance category score.
Quality performance category
Changes to the Quality performance category for the 2025 reporting year include updated measures, submission requirements and more.
1. New + updated quality measures
CMS added seven, removed 10 and updated 66 existing measures – for a total of 195 quality measures for the 2025 performance period.
2. Policy for multiple quality submissions
CMS announced their policy for processing multiple quality submissions from the same organization or from different organizations. This is not a new policy – it is the current process already in use by CMS – but this is the first year it’s been announced in the Final Rule as official methodology.
From the same organization:
If multiple submissions are received from the same organization (i.e. two admins from the same practice) via the same submission method, the most recent submission is scored, overriding all previous submissions.
From different organizations:
If multiple submissions are received from different organizations (i.e. a practice admin and a qualified registry), CMS will score all submissions and assign a score based on the highest-scoring measures submitted.
Cost performance category
CMS announced updates to the Cost performance category measures and scoring methodologies for the 2025 performance period.
Cost measures
CMS added six new measures and updated two existing measures, for a total of eight episode-based cost measures available for reporting in the 2025 calendar year.
New episode-based cost measures
- Respiratory Infection Hospitalization (acute inpatient medical condition)
- Chronic Kidney Disease (chronic condition)
- End-Stage Renal Disease (chronic condition)
- Kidney Transplant Management (chronic condition)
- Prostate Cancer (chronic condition)
- Rheumatoid Arthritis (chronic condition)
Updated cost measures
- Cataract Removal with Intraocular Lens (IOL) Implantation [previously: Routine Cataract with Intraocular Lens (IOL) Implantation]
- Inpatient Percutaneous Coronary Intervention (PCI) [previously: ST-Elevation Myocardial Infarction (STEMI) Percutaneous Coronary Intervention]
Review the full description of new and modified cost measures on the CMS website.
Cost scoring methodology
CMS has made changes to the benchmarking methodology they use when assigning participants’ cost scores. Previously, participants’ cost performance would be ranked on a national percentile scale (1st – 100th percentile) and assigned points on a 1-10 scale corresponding to the percentile. For example, participants in the 1st percentile (lowest costs) might receive a score of 10 points and those in the 99th percentile (highest cost) might receive one point, etc.
New cost benchmarking methodology
Starting in 2025, CMS will determine the national median cost for each measure and assign it a score of 1–10 points, derived from the performance threshold for that MIPS payment year. Participants’ scores are then calculated based on where their average costs land on the point scale in relation to the national median.
For more information on this methodology, CMS provides explanation and an example for reference in their 2025 Final Rule Guide.
Promoting Interoperability (PI) performance category
CMS announced updates to their Promoting Interoperability performance category reweighting and submission policies for the 2025 MIPS reporting year.
1. Automatic Reweighting
All participants are required to submit PI data unless they qualify for automatic reweighting (meaning the PI category is adjusted to represent 0% of their overall MIPS score.) For the 2025 performance period, automatic reweighting is available for the following groups:
- Ambulatory Surgical Center (ASC)-based
- Hospital-based
- Non-patient facing
- Small practice
Automatic reweighting is no longer available for clinical social workers.
2. Policy for multiple PI submissions
Applies to 2024 performance year submissions (due January 2 – March 31, 2025)
If multiple PI submissions are received, CMS will score each submission and assign a score based on the highest-scoring submission.
Since CMS requires a 180-day minimum PI performance period, the final date you can begin your 2025 PI performance period will be July 5, 2025.
Both ModMed EHR systems, EMA® and gGastro® meet the necessary ONC certification criteria required for submitting PI data for the 2025 performance year.
Improvement Activities (IA) performance category
In their 2025 Final Rule, CMS announced updates to the IA measures, weighting and scoring policies, and submission requirements.
1. Improvement activity measures
CMS has added two new improvement activities, removed four and modified one, for a total of 104 available IA measures for the 2025 performance period.
New improvement activities
- 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
Removed improvement activities
- Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real-Time Access to Patient’s Medical Record
- Implementation of a Personal Protective Equipment (PPE) Plan
- Implementation of a Laboratory Preparedness Plan
- Invasive Procedure or Surgery Anticoagulation Medication Management
CMS modified the Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B improvement activity in the population health subcategory (formerly Emergency Response and Preparedness).
2. Activity weighting eliminated
Starting in the 2025 performance year, all activity weighting has been eliminated and improvement activities are no longer categorized as high- or medium-weighted activities. All activities are now worth equal point values.
3. Minimum activity requirements
To accompany the new activity weighting policy, CMS has also simplified the minimum number of required activities needed to satisfy the IA category for the 2025 performance year, as follows:
- MVPs: required to report one activity
- MIPS small practices: required to report one activity
- MIPS large practices: required to report two activities
4. New IA submission requirements
New this year, all IA submissions must include a “yes” response for at least one improvement activity to be eligible for scoring. This prevents participants from receiving a zero score for unintentional (or redundant) submissions that only contain non-scorable data, such as the practice name and date. Any IA submissions that do not include the “yes” response for at least one activity will be marked null and will not be scored.
5. Multiple IA submissions
CMS announced their policy for processing multiple IA submissions from the same or different organizations.
From the same organization:
If multiple submissions are received from the same organization (i.e. two admins from the same practice), via the same submission method, the most recent submission will be scored, overriding all previous submissions.
From different organizations:
If multiple submissions are received from different organizations (i.e. practice admin and qualified registry), CMS will score all submissions and assign a score based on the highest-scoring activities submitted.
Additional updates
Final score reweighting request
CMS announced a new policy allowing participants to request reweighting of their Quality, IA or PI performance categories (meaning the weight of that category would be adjusted to 0% of their final MIPS score) if certain conditions are met.
If a participant’s submission data is inaccessible and can’t be submitted for reasons outside their control (for example, they delegated data submission to a third party, but the third party failed to submit their data by the required deadline), they can request reweighting. To determine eligibility, CMS will determine if certain criteria have been met on a case-by-case basis.
Managing change
ModMed offers a range of solutions and resources that can help make these MIPS changes easier on your practice:
- Our award-winning1, ONC-certified2 EHR, EMA, records your MIPS measures as you document and offers a built-in, easy-to-read scorecard with your estimated MIPS performance.3
- ModMed users can submit their MIPS data directly to CMS through the Modernizing Medicine Qualified Registry2 and we offer interfaces with several third party registries, such as Patient360, Healthmonix, GIQuIC and a number of academy registries for seamless data transfer. Learn more about the registry solutions we have available.
- Get personalized guidance from our team of Certified MIPS Health Professionals (CMHP) who can help you track your progress and meet your 2025 MIPS goals. Discover what our MIPS Advising Services for EMA and gGastro have to offer.
Find out how ModMed solutions can help you navigate MIPS in 2025
For more information on all the MIPS updates announced in the 2025 Quality Payment Program Final Rule, download the 2025 QPP Final Rule Fact Sheet and the 2025 Finalized MIPS Value Pathways (MVPs) Guide.
1 2025 Black BookTM
2 Information relating to our EHR certification, including certain mandatory disclosures, can be found here.
3 Subject to satisfaction of data completeness and similar requirements.
This blog is intended for informational purposes only and does not constitute legal or medical advice. Please consult with your legal counsel and other qualified advisors to ensure compliance with applicable laws, regulations, and standards.
