The Merit-based Incentive Payment System (MIPS) continues to evolve, bringing new challenges and opportunities for clinicians aiming to optimize their performance and meet the Centers for Medicare and Medicaid Services (CMS) reporting requirements. As in past years, success with MIPS in 2025 will require a proactive strategy, careful planning, and timely data collection throughout the year. In this article, we’ve outlined a step-by-step checklist to help your practice stay organized, reduce reporting burdens, and achieve success with 2025 MIPS.
1. Confirm Your 2025 MIPS Eligibility
Before developing your reporting plan, it’s important to determine if you are required or eligible to participate in MIPS for the 2025 performance year. The CMS QPP Participation Status Tool is your go-to resource for verifying:
- Individual and group MIPS eligibility
- Whether you are a Qualifying APM Participant (QP) or a Partial QP
- Eligibility to opt-in or voluntarily report
- Special statuses such as Small Practice, Non-Patient Facing, Rural, or HPSA designation
Eligibility can change during the year, especially if you join an APM Entity or begin billing under a new Tax Identification Number (TIN). Be sure to check again at the end of 2025 for any updates.
*MDinteractive customers can also check their dashboard to view current MIPS eligibility status.
2. Choose How You’ll Report: Individual, Group, or APM Entity
One of your first decisions is how you plan to report your MIPS data. You can:
- Report as an individual, based on your own NPI/TIN performance
- Report as a group, where performance is aggregated across all clinicians billing under the same TIN
- Participate as part of an APM Entity if you are in a qualifying alternative payment model
Group reporting can be advantageous if performance varies across clinicians, but you’ll want to ensure the aggregated score aligns with your goals. Reporting as an individual allows more control, especially if your performance differs from that of your peers.
3. Choose What You’ll Report: Traditional MIPS or an MVP
After deciding how you’ll report, you must choose what pathway to report under:
- Traditional MIPS allows you to select your own Quality, Improvement Activities (IA), and Promoting Interoperability (PI) measures
- MIPS Value Pathways (MVPs) offer pre-defined, specialty- or condition-specific sets of measures that better align with clinical workflows
If you choose to report an MVP in 2025, you must register between April 1 and December 1, 2025. Work with your reporting partner early to determine if an MVP is a good fit for your practice. More information about MVP reporting can be found here.
Traditional MIPS still offers flexibility in choosing measures, while MVPs streamline choices and may provide better scoring alignment, especially as CMS moves toward full MVP implementation in future years.
4. Understand and Prepare for Category Requirements
MIPS scores are based on four performance categories. Here’s a snapshot of what’s required in 2025:
Quality
In 2025, clinicians will have access to 195 quality measures to choose from, reflecting CMS’s continued emphasis on flexibility and specialty-specific reporting in the MIPS program. Clinicians must report 6 quality measures, including at least one outcome measure or, if an outcome is not available, one high-priority measure. Quality measures must be reported for the full calendar year (January 1, 2025 to December 31, 2025) and must include all eligible encounters across all payers, including both Medicare and commercial patients. While up to 25% of the quality data may remain unreported, information must still be collected for 100% of eligible patients.
If you're reporting through a MIPS Value Pathway (MVP), you must submit 4 quality measures from the applicable MVP list, including at least one outcome or high-priority measure. For detailed guidance, see how to report MVPs.
Promoting Interoperability (PI)
To report the Promoting Interoperability (PI) category, you must use certified electronic health record technology (CEHRT) that meets the Office of the National Coordinator for Health Information Technology (ONC) certification criteria for at least a continuous 180-day performance period during the calendar year.
Important update for 2025:
Beginning with the 2025 performance period, clinical social workers will no longer qualify for automatic reweighting in the PI category. Automatic reweighting will now only apply to MIPS-eligible clinicians and groups with the following special statuses:
- Ambulatory Surgical Center (ASC)-based
- Hospital-based
- Non-patient facing
- Small practices
Improvement Activities (IA)
Clinicians must attest to completing Improvement Activities for a minimum of 90 continuous days during the performance year.
NEW in 2025: Improvement Activities will no longer be weighted, and the number of required activities has changed depending on your reporting path and special status:
If reporting through an MVP:
- Clinicians, groups, and subgroups (regardless of special status) must attest to 1 activity
If reporting through Traditional MIPS:
- Clinicians, groups, and virtual groups with Small Practice, Rural, Non-Patient Facing, or HPSA special status must attest to 1 activity
- All other clinicians, groups, and virtual groups must attest to 2 activities
Be sure to review your special status designations and reporting pathway to determine how many activities your practice needs to complete.
Cost
This category is calculated by CMS using administrative claims data. No action is required, but performance will still impact your final score. You can review the 2025 MIPS cost measures and learn more about how they’re evaluated by visiting our detailed breakdown here.
5. Choose Your Measures Strategically
Each year, CMS retires, modifies, and updates quality measures. Carefully review the 2025 measure specifications to confirm that:
- Your selected measures are still available for reporting
- You understand how each measure must be reported and how it will be scored
- Your selected measures are not “topped out” and have established benchmarks, as both can limit the number of points you can earn
Measure selection plays a key role in your final MIPS score, so take time to align them with your workflows and patient population.
6. Begin Tracking and Submitting Early
Don't wait until the submission window opens in 2026 to start thinking about reporting. Collecting and monitoring your performance data throughout the year helps:
- Identify areas for improvement
- Avoid surprises when it’s time to submit
- Ensure all data meets completeness and accuracy standards
Working with a certified reporting partner like MDinteractive can simplify data collection and ensure your submission to CMS is accurate and on time.
Final Thoughts
MIPS reporting in 2025 doesn’t have to be overwhelming. With a solid plan and ongoing performance monitoring, you can meet CMS requirements and position your practice for success. Our team at MDinteractive is here to support you every step of the way—from eligibility verification to final submission. If you're ready to get started or have questions about your 2025 reporting strategy, contact one of our MIPS specialists today.
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