Are You on Track for 2025 MIPS Reporting Requirements?

January 16, 2025

We’re here to help you start the new year strong. In this blog, we highlight important MIPS dates and action items. You can use the key action checklists provided throughout the blog to stay on track during the 2025 performance year.

Keep in mind that EHR vendors and MIPS registries have their own deadlines throughout the year. If you are an Anatomy IT client, your MIPS Expert will notify you about any additional deadlines relevant to your practice.

Q1: January – March 2025

  • January 1
    • MIPS 2025 performance year begins.
      • Anatomy IT clients: Review the Jumpstart email sent in December 2024 for important information on 2025 MIPS.
    • Quality performance period begins.
      • Anatomy IT clients: If you have any workflow changes affecting quality measures, be sure to follow up with your MIPS Expert.
  • January 2
    • MIPS 2024 submission window opens.
      • Although CMS begins accepting submissions on January 2, you might not be able to start submitting data until a later date, depending on your submission method. If you submit through a vendor, your submission date will depend on when your data is ready in the vendor’s system.
  • Late January – Early February
    • CMS is expected to release 2025 benchmarks for quality measures.
  • March 1
    • Claims-Based Submissions: Last day to submit claims for 2024 quality reporting.
  • March 31
    • MIPS 2024 submission window for all methods closes at 8 pm ET.
Key Actions for Q1
  • Submit 2024 MIPS data.
  • Start thinking about which quality measures you will report for 2025 MIPS.
  • Start thinking about which improvement activities you will report for 2025 MIPS.
  • Begin planning for your 180-day Promoting Interoperability (PI) performance period, unless you are eligible to have the PI category automatically reweighted and are choosing not to report PI.
  • Start making a plan for completing the Security Risk Analysis (SRA) and High Priority SAFER Guide Self-Evaluation for the PI category. Note that the SRA is a HIPAA requirement and is mandatory regardless of whether you report PI.

Q2: April – June 2025

  • April 1
    • Registration opens to report an MVP in 2025.
      • Anatomy IT clients: We will discuss whether to report an MVP during the kickoff call with your practice.
      • Keep in mind that if you report traditional MIPS and an MVP, CMS will score both submissions and assign you the higher of the two scores.
    • Hardship for the failure of a third party intermediary to submit 2024 MIPS data opens. Requests must be made via the QPP Help Desk at QPP@cms.hhs.gov.
      • If you are unsure whether this hardship applies to you, take a look at our blog on this topic.
  • May
    • QPP hardship and PI exception applications become available.
  • Mid June
    • 2024 MIPS final scores are released.
    • 2024 MIPS targeted review submission period begins after final scores become available. Targeted reviews are due 30 days after payment adjustments are released.
Key Actions for Q2
  • Consider starting your 180-day PI performance period, if you are reporting PI. While not technically required in Q2, we highly recommend getting started by now.
  • Have a plan in place for completing the Security Risk Analysis (SRA) and High Priority SAFER Guide Self-Evaluation for PI, if you haven’t completed these items already.
  • Decide whether you will be reporting an MVP in 2025.
  • Decide which quality measures you will report for 2025 MIPS.
  • Decide which improvement activities you will report for 2025 MIPS.
  • Review your 2024 MIPS final score and determine whether to submit a targeted review. 

Q3: July – September 2025

  • July 5
    • Last day to start a 180-day performance period for PI.
      • Keep in mind that if you wait until this date to start your PI performance period, it will continue all the way through December 31 (holidays included).
      • Not every practice has to report PI. The following special statuses receive automatic reweighting of the PI category: small practice, ASC-based, hospital-based, and non-patient facing.
  • Early – Mid July
    • CMS is expected to publish the QPP proposed rule for the 2026 MIPS performance year. Comment period begins once the rule is posted.
      • We will post a blog about the key proposals. If there are any proposals you find particularly good or bad, please submit comments to CMS before the deadline (60 days after the proposed rule is published).
      • The Anatomy IT Health Policy team will also be submitting comments on the proposed rule. We have seen CMS make program changes based on our comments on previous rules – so rest assured that your voice matters, and CMS takes comments into account when determining the final rule.
      • 2026 payment adjustments based on 2024 MIPS final scores are released.
  • Mid August
    • Deadline for 2024 MIPS targeted reviews (30 days after payment adjustments are released).
  • September
    • Last day to provide any documentation that was requested for your targeted review (must provide it within 15 days of request).
    • Deadline to submit comments on the 2026 MIPS proposed rule.
  • Mid – Late September
    • Targeted review decisions are finalized. 
Key Actions for Q3
  • Ensure that your 180-day PI performance period is underway, if you are reporting PI.
  • Consider starting your 90-day IA performance period. While not technically required in Q3, we highly recommend getting started by now.
  • Have a plan in place for completing the Security Risk Analysis (SRA) and High Priority SAFER Guide Self-Evaluation for PI, if you haven’t completed these items already.
  • Submit a targeted review for 2024 MIPS, if warranted.
  • Submit comments on the 2026 MIPS proposed rule, if you would like CMS to consider your feedback when determining the final rule.

Q4: October – December 2025

  • October 3
    • Last day to start a 90-day performance period for the Improvement Activities (IA) category.
      • Keep in mind that if you wait until this date to start your IA performance period, it will continue all the way through December 31 (holidays included).
      • Anatomy IT clients: We will review the 2025 changes to the IA category during the kickoff call with your practice.
  • November 1
  • November 3
    • CMS is expected to publish the QPP final rule for the 2026 performance year by this date at the latest.
      • Keep an eye out for the Anatomy IT 2026 MIPS final rule webinar, where we will cover major updates to MIPS in 2026.
  • November – December
    • 2025 MIPS final eligibility is released on the QPP website.
  • December 1
    • MVP registration window closes at 8 pm ET.
  • Mid – Late December
    • Anatomy IT clients: A Jumpstart email will be sent to you regarding preparation for 2026 MIPS.
  • December 31
    • MIPS 2025 performance year ends.
    • Last day to submit a QPP hardship or PI exception; deadline is at 8 pm ET.
    • Last day to complete the Security Risk Analysis and High Priority SAFER Guide Self-Evaluation for PI.
Key Actions for Q4
  • Attend the Anatomy IT 2026 MIPS final rule webinar.
  • Complete MVP registration, if you are reporting an MVP and haven’t registered already.
  • Check your 2025 MIPS final eligibility.
  • Submit a QPP hardship and/or PI exception, if warranted.
  • Wrap up IA and PI performance period actions.
  • Complete the Security Risk Analysis (SRA) and High Priority SAFER Guide Self-Evaluation for PI, if you haven’t completed these items already.

Next Steps

  • Share this information with your colleagues.
  • Subscribe to our blog to get alerts on this and other important issues. You can subscribe using the field in our website footer below.
  • If you are an Anatomy IT client, contact your MIPS Expert if you have any questions.
  • If you are not an Anatomy IT client, contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.

If you have any questions on this, let us know!

Sarrah Hakim, MHSAWritten By: Sarrah Hakim, MHSA

About the Author: Sarrah is a Manager of Health Policy at Anatomy IT.

Posted in MIPS, blog