MIPS Value Pathway Available for Gastroenterology in 2025

May 2, 2025

The Centers for Medicare and Medicaid Services (CMS) finalized the new Gastroenterology Care MVP in 2025.

Although MVP reporting is currently voluntary, CMS has expressed the intention of sunsetting traditional MIPS and transitioning to MVPs entirely in the future. In the 2025 MIPS proposed rule, CMS requested feedback on the possibility of making MVPs mandatory as early as 2029.

Anatomy IT will continue to advocate for MVPs to be optional and for improvements to this MVP to make it possible for all gastroenterologists to be successful.

In this blog, we’ll break down what MVPs are, how to report them, and what measures and activities are included in the Gastroenterology Care MVP.

What is a MIPS Value Pathway (MVP)?

CMS introduced MVPs as an alternative reporting option to traditional MIPS in 2023. According to CMS, MVPs aim to simplify MIPS, reduce reporting burden, and help patients make more informed decisions when choosing their clinicians.

Each MVP has its own specific set of quality measures, improvement activities (IAs), and cost measures, and you are limited to those measures and activities when reporting the MVP. The Promoting Interoperability (PI) category is included as part of a “foundational layer,” meaning that PI requirements are the same for every MVP. Also included in the foundational layer is a population health measure, which contributes to your overall Quality score.

Can I Report an MVP Through a Registry?

Since 2023, Qualified Registries (QRs) and Qualified Clinical Data Registries (QCDRs), such as the American College of Gastroenterology and American Society for Gastrointestinal Endoscopy’s GIQuIC QCDR, have been required to support all measures in the Quality, IA, and PI categories of the MVPs relevant to their clinicians. They are not required to support the Cost category, Population Health measures, QCDR measures, or the CAHPS for MIPS Survey.

How Are MVPs Different from Traditional MIPS?

The table below highlights the differences by category between reporting traditional MIPS versus reporting an MVP.

If you choose to report both traditional MIPS and an MVP, CMS will assign you the higher of the two scores.

How Do I Report an MVP?

To report an MVP for the 2025 performance year, you must register between April 1, 2025, and December 1, 2025, at 8 pm ET. Registration is available through your QPP account.

At the time of registration, you must include the following information:

The MVP you are choosing to report,
Any administrative claims measures you would like to be included as 1 of your 4 required Quality measures,
Whether you are planning to count the CAHPS for MIPS Survey measure towards 1 of the 4 required Quality measures, and
Your participation level (group, subgroup, individual, APM).*

*If you report at the group level and are part of a multispecialty group, you will be required to report at the subgroup level starting in 2026.

If you are an Anatomy IT client, we will discuss whether to report an MVP during your kickoff call.

What Measures Are Included in the MVP for Gastroenterology?

Click on the category names below to see the measures and activities included in the Gastroenterology Care MVP.

Gastroenterology Care Measures (Specific to This MVP)

Quality

Gastroenterology Care MVP Quality Measures

Report 4 of the following (at least 1 outcome or high priority measure):

113: Colorectal Cancer Screening
130: Documentation of Current Medications in the Medical Record (high priority)
185: Colonoscopy Interval for Patients with a History of Adenomatous Polyps - Avoidance of Inappropriate Use (high priority)
226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
275: Inflammatory Bowel Disease (IBD): Assessment of Hepatitis B Virus (HBV) Status Before Initiating Anti-TNF (Tumor Necrosis Factor) Therapy
320: Appropriate Follow-Up Interval for Normal Colonoscopy in Average Risk Patients (high priority)
374: Closing the Referral Loop: Receipt of Specialist Report (high priority)
400: One-Time Screening for Hepatitis C Virus (HCV) and Treatment Initiation
401: Hepatitis C: Screening for Hepatocellular Carcinoma (HCC) in Patients with Cirrhosis
487: Screening for Social Drivers of Health (high priority)
503: Gains in Patient Activation Measure (PAM®) Scores at 12 Months (outcome)
GIQIC23: Appropriate follow-up interval based on pathology findings in screening colonoscopy (high priority)
GIQIC26: Screening Colonoscopy Adenoma Detection Rate (outcome)
NHCR4: Repeat screening or surveillance colonoscopy recommended within one year due to inadequate bowel preparation (high priority)

Improvement Activities

Gastroenterology Care MVP Improvement Activities

Report 1 of the following:

AHE_3: Promote use of Patient-Reported Outcome Tools
AHE_6: Provide Education Opportunities for New Clinicians
AHE_9: Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols
BE_4: Engagement of patients through implementation of improvements in patient portal
CC_7: Regular training in care coordination
CC_9: Implementation of practices/processes for developing regular individual care plans
CC_10: Care transition documentation practice improvements
CC_13: Practice improvements to align with OpenNotes principles
PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B
PCMH: Electronic submission of Patient Centered Medical Home accreditation
MVP: Practice-Wide Quality Improvement in MIPS Value Pathways

Cost

Foundational Layer (Applies to All MVPs)

Population Health

Population Health Measures

You will be automatically scored on both of the following population health measures. CMS will assign you the highest of the two scores.

479: Hospital-Wide, 30-Day, All-Cause Unplanned Readmission (HWR) Rate for the Merit-Based Incentive Payment Systems (MIPS) Groups
484: Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions

Promoting Interoperability

Promoting Interoperability Requirements

The PI requirements for an MVP are the same as those for traditional MIPS.

All of the following attestations and measures are required (no exclusions):

Use of CEHRT
Actions to Limit or Restrict Interoperability of CEHRT
ASTP/ONC Direct Review
High Priority SAFER Guides Assessment
Security Risk Analysis
Provide Patients Electronic Access to Their Health Information

All of the following measures are required (unless claiming an exclusion):

e-Prescribing
Query of Prescription Drug Monitoring Program (PDMP)
Immunization Registry Reporting
Electronic Case Reporting

One of the following options is required:

Option 1: Support Electronic Referral Loops by Sending Health Information + Support Electronic Referral Loops by Receiving and Reconciling Health Information
- Exclusions are available for both measures in this option.
Option 2: Health Information Exchange (HIE) Bi-Directional Exchange
Option 3: Enabling Exchange Under the Trusted Exchange Framework and Common Agreement (TEFCA)

You can optionally report on one (only one) of the following measures for 5 bonus points in the PI category:

Syndromic Surveillance Reporting
Clinical Data Registry Reporting
Public Health Registry Reporting

Is Reporting the Gastroenterology Care MVP in 2025 Worth It?

Yes. CMS is considering making MVP reporting mandatory starting in 2029. That means there are only a few MIPS performance years left to find flaws, gather data, and recommend improvements before MVPs become the only way in which you can participate in MIPS and avoid a penalty. By reporting this MVP, you will:

Gain invaluable experience to prepare you for mandatory MVP reporting,
Not negatively impact your MIPS payment adjustment as long as you also report traditional MIPS (even if you score poorly in the MVP), and
Be able to provide real-world feedback to CMS to help them improve the MVP available to you before MVP reporting becomes mandatory. You can communicate with us to describe your experience with the MVP or you can tell CMS directly by commenting on the 2026 Medicare Physician Fee Schedule Proposed Rule this summer or by following the steps outlined here by CMS.

Next Steps

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Written By: Sarrah Hakim, MHSA