Navigate the latest MIPS and QPP Proposed Rule: A Comprehensive Overview for CY 2025

The Centers for Medicare and Medicaid Services (CMS) has officially released the 2025 Quality Payment Program (QPP) proposed rule. The 2,248-page proposed rule contained many changes that may take place in the 2025 MIPS performance year and beyond.

This blog post breaks down the proposed changes to the QPP and MIPS for 2025.

Performance Threshold

CMS is proposing to maintain the current threshold to avoid a penalty at 75 points in 2025.

Category Weights

CMS is not proposing changes to performance category weights in 2025.

Quality Category

Measure Scoring

CMS is proposing to change the way it scores some topped out measures to instead use flat benchmarking to assign performance points (see Table below). This will only apply to measures that belong to specialty sets with limited measure choice and a high proportion of topped out measures. CMS would propose which specific measures would be subject to flat benchmarking each year in rulemaking.

The following measure scoring rules will remain in effect:

  • For large practices (>15 clinicians), remove the 3-point floor for measures meeting data completeness and case minimum. These measures would be scored on a 1-10 point scale instead of a 3-10 point scale.
  • For small practices, the 3-point floor will remain.

Bonuses

  • No change to the small practice bonus or the improvement score bonus.

Measures

CMS is proposing the following changes to the Quality measure inventory:

  • 9 new proposed measures
  • 11 measures proposed for removal
  • 66 existing measures with proposed substantive changes

In the coming weeks, we will publish our analysis of these proposed quality measures changes for the specialties we serve.

Data Completeness Threshold

  • Proposal to maintain at 75% in performance years 2025 – 2028 (previously, this threshold was only finalized through performance year 2026)

Cost Category

Scoring

CMS is also proposing to change the way in which they score cost measures beginning with the 2024 performance period.

  • Currently, CMS assigns cost measure points based on the percentile in which a clinician’s or group’s performance falls. For example, someone in the 99th percentile (the highest costs) would get 1-1.9 points.
  • Proposed Change: CMS would set the median cost for a measure as 7.5 points. The remaining deciles would be determined by using standard deviations from the median.
  • This would decrease the likelihood of inappropriately low scores for measures that have little variation in total costs.

Measures

CMS is proposing to modify two existing episode-based cost measures:

  • Cataract Removal with IOL Implantation
    • Currently named Routine Cataract with IOL Implantation
    • Reduced exclusions: The proposed revised measure includes patients with certain previously excluded ocular conditions, such as glaucoma and macular degeneration, in the measure cohort.
      • The proposed list of excluded conditions includes 563 codes (this is a 38% reduction in the available exclusions as the current list includes 1,475 codes)
    • Increased List Included Costs: Added medications (Dextenza and IHEEZO) and expanded list of services included in the measure’s cost calculation.
  • Inpatient Percutaneous Coronary Intervention (PCI)
    • Currently named ST-Elevation Myocardial Infarction [STEMI] Percutaneous Coronary Intervention [PCI])
    • Expanded patient cohort: Would include STEMI, non-STEMI, and those with PCI without either STEMI or non-STEMI diagnoses.
    • Additional Sub-Groups: Would add sub-groups for STEMI, non-STEMI, and other inpatient PCI episodes.
    • Added exclusion and risk adjuster: The proposed revised measure excludes episodes with cardiac arrest and risk adjusts for patients with a history of tobacco use.

CMS is proposing to add six new episode-based cost measures:

  • Respiratory Infection Hospitalization (acute inpatient measure)
  • Chronic Kidney Disease (chronic condition measure)
  • End-Stage Renal Disease (chronic condition measure)
  • Kidney Transplant Management (chronic condition measure)
  • Prostate Cancer (chronic condition measure)
  • Rheumatoid Arthritis (chronic condition measure)

Improvement Activities

CMS is proposing significant changes to the reporting requirements for this category. There are also significant proposed changes to the list of available Improvement Activities.

Removal of Activity Weights

Currently, improvement activities (IAs) are either medium-weighted or high-weighted. These weights correspond to how many points the IA contributes to the IA category (10 or 20, respectively). CMS is proposing to eliminate IA weights and, instead, allow all IAs to contribute equally.

Reporting Requirements Linked to the Number of IAs Submitted, Not Points

  • For all MVP Participants
    • Attest to 1 IA
  • MIPS Participants with the small practice, rural, non-patient facing, or health professional shortage area special status
    • Attest to 1 IA
  • All Other Participants
    • Attest to 2 IAs

Improvement Activities List

There are several proposed changes to the list of improvement activities (IAs), including:

  • Two proposed new IAs, neither of which are relevant to our specialists.
  • Two changes proposed to existing IAs (IA_ERP_6: COVID-19 Vaccine Achievement for Practice Staff; and IA_BE_4: Engagement of Patients Through Implementation of Improvements in Patient Portal).
  • Eight proposed removals:
    • IA_EPA_1: 24/7 Patient Access
    • IA_PM_12: Population Empanelment
    • IA_CC_1: Closing the Referral Loop
    • IA_CC_2: More Timely Communication of Test Results
    • IA_ERP_4: Implementation of a PPE Plan
    • IA_ERP_5: Implementation of Laboratory Preparedness Plan
    • IA_BMH_8: EHR Enhancements for Behavioral Health Data Capture
    • IA_PSPA_27: Invasive Procedure or Surgery Anticoagulation Medication Management

Promoting Interoperability (PI)

In a huge win for our long-term advocacy efforts, CMS is proposing to no longer assign a PI score of zero points for clinicians and groups that have multiple PI submissions. Instead, CMS proposes to calculate a score for each data submission received and assign the highest of the scores. This proposed change would begin this year (performance period 2024).

MIPS Value Pathways (MVPs)

CMS is proposing 6 new MVPs covering ophthalmology, dermatology, gastroenterology, pulmonology, urology, and surgical care.

CMS is also proposing limited modifications to current MVPs and to consolidate two neurology MVPs (Optimal Care for Patients with Episodic Neurological Conditions and Supportive Care for Neurodegenerative Conditions) into a single MVP (Quality Care for Patients with Neurological Conditions).

In the coming weeks, we will publish analyses of MVPs relevant to our clients. In the meantime, MVPs remain voluntary.

MVP Request for Information (RFI)

CMS included one significant RFI about MVPs in this proposed rule. This represents changes under consideration for proposal in a future rule. Comments submitted to CMS on this topic have the potential to impact a future proposed change as it is in development.

Although there are no current proposals to end traditional MIPS and make MVPs mandatory, CMS has made it clear for years that this is the plan. In this proposed rule, CMS included an RFI on a timeline to do just that. Specifically, CMS would like public feedback on whether to sunset traditional MIPS and require MVPs or the APM Performance Pathway (APP) beginning with performance year 2029.

Our analysis of this timeline-under-consideration is that it is too rushed. We still do not have sufficient available MVPs and, those that are available, do not provide sufficient quality or cost coverage for subspecialties.

Next Steps

  • Share this information with your colleagues.
  • Check back in coming weeks to see our Top 2025 Proposed MIPS Changes Report, an analysis of the Quality measure changes, and an analysis of the MVPs.
  • 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!


Jessica Peterson, MD, MPHWritten By: Jessica Peterson, MD, MPH

About the Author: Jessica Peterson, MD, MPH is the Senior Director of Value-Based Care Policy at Anatomy IT.