Make Your Voice Heard: CMS Calls for MIPS Improvement Activities

June 20, 2025

The Centers for Medicare & Medicaid Services (CMS) is accepting proposals for new MIPS improvement activities (IAs), as well as updates to existing ones. Submissions received by July 1, 2025, at 11:59 pm ET will be considered for the 2027 MIPS performance year IA inventory. Submissions received after July 1 will be considered for future MIPS performance years.

This is your opportunity to influence the IAs available to you under MIPS. This is especially important as several IAs were suspended this year and we expect the IA inventory to shrink further in the future. If there are activities that reflect the work happening in your practice and you’d like to see them included, now is the time to make your voice heard.

How to Submit IAs for Consideration

To recommend a new IA or a suggest an update to an existing IA, fill out the Call for IA Submission Form (PDF) and email it to CMSCallforActivities@abtassoc.com.*

Before submitting an IA for consideration, CMS recommends that you take a look at the current MIPS IA inventory to make sure you are not suggesting a duplicate activity.

*Note: Submissions must have all fields in the form completed in order to be considered.

Factors CMS Considers When Selecting IAs

To be considered for the IA inventory, the activity you submit must meet all of the following acceptance criteria:

Aligns with an existing IA subcategory (or a proposed new subcategory),
Is important for achieving improved beneficiary health outcomes,
Is feasible to implement, recognizing importance in minimizing burden, including, to the extent possible, for small practices, practices in rural areas, or practices in areas designated as Health Professional Shortage Areas (HPSAs) by the Health Resources and Services Administration (HRSA),
Is supported by evidence that the IA has a high probability of contributing to improved beneficiary health outcomes,
Can be linked to existing and related MIPS Quality, Promoting Interoperability, and Cost measures as applicable and feasible,
Can be validated by CMS,
Does not duplicate other IAs in the inventory, and
Drives improvements that go beyond purely common clinical practices.

There are also optional acceptance criteria. While not required, proposals that meet one or more of the following additional criteria may have an increased chance of being selected:

Aligns with patient-centered medical homes,
Supports the patient’s family or personal caregiver,
Responds to a Public Health Emergency (PHE) as determined by the Secretary of Health and Human Services (HHS),
Addresses improvements in practice to reduce health disparities,
Focuses on meaningful actions from the person and family’s point of view, or
Is representative of activities that multiple individual MIPS eligible clinicians or groups could perform (e.g., primary care or specialty care).

Next Steps

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Written By: Sarrah Hakim, MHSA