On July 10, 2024, the Centers for Medicare & Medicaid Services (CMS) released the proposed rule for the 2025 Medicare Physician Fee Schedule (PFS). The proposed rule outlines CMS's plans for eligible clinicians and groups to participate in the Merit-based Incentive Payment System (MIPS), Alternative Payment Models (APM), and other aspects of the Quality Payment Program (QPP) for the 2025 performance year. This blog summarizes the proposed changes and examines how they could impact MIPS reporting in 2025 and beyond.
Key Takeaways from the 2025 PFS Proposed Rule
No Changes to the MIPS Performance Threshold and Data Completeness Criteria
While the 2025 PFS rule introduces several changes, key aspects such as the MIPS performance threshold and data completeness requirements will stay the same. The MIPS performance threshold will remain at 75 points for the 2025 performance period (the same as the 2023 and 2024 performance years). Additionally, the data completeness criteria will stay at 75% through the 2028 performance period for all available collection types.
Quality Category
The proposal includes a total of 196 quality measures for the 2025 performance period. These proposals reflect:
- Nine new quality measures, including 2 patient-reported outcome measures
- Removal of 11 quality measures
- Substantive changes to 66 existing quality measures
Quality Measure Inventory Updates
A list of new measures, along with their collection types, are outlined in the table below.
| Proposed New Quality Measures | Collection Types |
|---|---|
| Positive PD-L1Biomarker Expression Test Result Prior to First Line Immune Checkpoint Inhibitor Therapy | MIPS CQM |
| Appropriate Germline Testing for Ovarian Cancer Patients | MIPS CQM |
| Patient-Reported Pain Interference Following Chemotherapy among Adults with Breast Cancer | MIPS CQM |
| Patient-Reported Fatigue Following Chemotherapy among Adults with Breast Cancer | MIPS CQM |
| Adult COVID-19 Vaccination Status | MIPS CQM |
| Melanoma: Tracking and Evaluation of Recurrence | MIPS CQM |
| First-Year Standardized Waitlist Ratio (FYSWR) | MIPS CQM |
| Percentage of Prevalent Patients Waitlisted (PPPW) and Percentage of Prevalent Patients Waitlisted in Active Status (aPPPW) | MIPS CQM |
Note: In the CY 2024 PFS final rule, measure Q494: Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults (Clinician Level), was finalized with a 1-year delay to the CY 2025 performance period.
Below is a list of measures that have been proposed for removal from MIPS.
| Quality Measures Proposed for Removal | Collection Types |
|---|---|
| #104: Prostate Cancer: Combination Androgen Deprivation Therapy for High Risk or Very High Risk Prostate Cancer | MIPS CQM |
| #137 Melanoma: Continuity of Care – Recall System: Oncology: Medical and Radiation – Plan of Care for Pain | MIPS CQM |
| #144 Oncology: Medical and Radiation – Plan of Care for Pain | MIPS CQM |
| #254 Ultrasound Determination of Pregnancy Location for Pregnant Patients with Abdominal Pain | MIPS CQM |
| #260 Rate of Carotid Endarterectomy (CEA) for Asymptomatic Patients, without Major Complications (Discharged to Home by Post-Operative Day #2) | MIPS CQM |
| #409 Clinical Outcome Post Endovascular Stroke Treatment | MIPS CQM |
| #433 Proportion of Patients Sustaining a Bowel Injury at the time of any Pelvic Organ Prolapse Repair | MIPS CQM |
| #436: Radiation Consideration for Adult CT: Utilization of Dose Lowering Techniques* | MIPS CQM |
| #439 Age Appropriate Screening Colonoscopy | MIPS CQM |
| #452 Patients with Metastatic Colorectal Cancer and RAS (KRAS or NRAS) Gene Mutation Spared Treatment with Antiepidermal Growth Factor Receptor (EGFR) Monoclonal Antibodies | MIPS CQM |
| #472 Appropriate Use of DXA Scans in Women Under 65 Years Who Do Not Meet the Risk Factor Profile for Osteoporotic Fracture | eCQM |
*Measure #436: Radiation Consideration for Adult CT: Utilization of Dose Lowering Techniques was already finalized for removal with a 1-year delay to the CY 2025 performance period.
Topped Out Measure Benchmarks
CMS is proposing to use a flat benchmarking methodology for certain topped-out measures, specifically those within specialty sets that have limited options and a high number of topped-out measures, where there is a lack of new measure development. This approach aims to address challenges in meaningful MIPS participation in these areas. Each year, CMS will propose the specific measures to which this policy will apply and detail the corresponding benchmarks.
| Performance Rate | Available Points |
|---|---|
| 84-85.9% | 1-1.9 |
| 86-87.9% | 2- 2.9 |
| 88-89.9% | 3-3.9 |
| 90-91.9% | 4-4.9 |
| 92-93.9% | 5-5.9 |
| 94-95.9% | 6-6.9 |
| 96-97.9% | 7-7.9 |
| 98-99.9% | 8-8.9 |
| 100% | 10* |
Complex Organization Adjustment
CMS is proposing to add an adjustment to address the challenges APM entities face (including Medicare Shared Saving Program ACOs) when reporting eCQMs. Specifically, the proposed rule would:
- Give one extra measure achievement point for each submitted eCQM submitted that meets data completeness and case minimum requirements.
- This adjustment would not exceed 10% of the total measure achievement points available in the quality performance category.
Quality Data Submission Criteria
CMS has proposed that for a quality performance category submission to be considered valid and scored, it must include both numerator and denominator data for at least one MIPS quality measure. Submissions containing only a date and practice ID will be deemed invalid and assigned a null score. This change aims to reduce negative scoring for submissions with incomplete data, which currently result in a zero score.
Additionally, in the event of multiple quality submissions for an individual clinician, group, subgroup, or virtual group from different organizations (e.g., a qualified registry and a practice administrator), CMS proposes to codify its current process to calculate and score each submission and assign the higher score. For multiple submissions from the same organization (e.g., by two practice administrators), CMS proposes to score the most recent submission, with the new submission overriding any previous one of the same type. This proposal does not apply to different submission types from the same organization; for example, a small practice can report some quality measures through Medicare Part B claims and others via a file upload.
MVPs
CMS continues to promote the broader adoption of MIPS Value Pathways (MVPs). While MVP reporting remains voluntary and no end date for traditional MIPS has been officially proposed, CMS is working on a timeline for transitioning fully to MVPs. The agency is also seeking feedback on clinician readiness for MVP reporting and the MIPS policies required to phase out traditional MIPS by the 2029 performance period and the 2031 MIPS payment year.
Expansion of MVP Inventory
The proposed rule focuses on developing and maintaining MVPs that are relevant and meaningful for MIPS participants. It would add six new MVPs to the MVP inventory that address a range of specialties, including dermatology, gastroenterology, ophthalmology, pulmonology, surgical care, and urology. It would also consolidate the Optimal Care for Patients with Episodic Neurological Conditions MVP and the Supportive Care for Neurodegenerative MVP Conditions into one MVP called the Quality Care for Patients with Neurological Conditions MVP.
Newly Proposed MVPs |
|---|
| Complete Ophthalmologic Care MVP |
| Dermatological Care MVP |
| Gastroenterology Care MVP |
| Optimal Care for Patients with Urological Conditions MVP |
| Pulmonology Care MVP |
| Surgical Care MVP |
Population Health Measure Calculation Changes
CMS proposes to calculate all available population health measures for an MVP participant and apply the highest scoring measure to their quality score. MVP participants would no longer be required to select a population health measure as part of their MVP registration.
Improvement Activities
The proposed rule updates the Improvement Activities inventory for the 2025 performance period with the following proposed changes:
- Two new activities
- Modification of 2 existing activities
- Removal of 8 activities
Improvement Activity Inventory Updates
New Improvement Activities Proposed for the 2025 Performance Period and Future Years include:
- Implementation of Protocols and Provision of Resources to Increase Lung Cancer Screening Uptake
- Save a Million Hearts: Standardization of Approach to Screening and Treatment for Cardiovascular Disease Risk
The table below lists the Improvement Activities proposed for removal in 2025:
| Improvement Activities Proposed for Removal in the 2025 Performance Period and Future Years |
|---|
| EPA_1 Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real-Time Access to Patient's Medical Record |
| PM_12 Population Empanelment |
| CC_1 Implementation of Use of Specialist Reports Back to Referring Clinician or Group to Close Referral Loop |
| CC_2 Implementation of Improvements that Contribute to More Timely Communication of Test Results |
| ERP_4 Implementation of a Personal Protective Equipment (PPE) Plan |
| ERP_5 Implementation of a Laboratory Preparedness Plan |
| BMH_8 Electronic Health Record Enhancements for BH Data Capture |
| PSPA_27 Invasive Procedure or Surgery Anticoagulation Medication Management |
Improvement Activity Scoring and Reporting Policy Changes
Under the proposed rule CMS would remove activity weightings to simplify scoring and reduce the number of activities clinicians are required to attest to completing to achieve a full score
in this performance category.
- MVP Reporting - Clinicians, groups, and subgroups (regardless of special status) would have to attest to one activity.
- Traditional MIPS Reporting
- Clinicians, groups, and virtual groups with a small practice, rural, non-patient facing, or health professional shortage area special status would have to attest to one activity.
- All other clinicians, groups, and virtual groups would have to attest to 2 activities.
Improvement Activity Data Submission Criteria
When multiple improvement activity submissions are received from different organizations, CMS proposes to codify the current process of scoring each submission and assigning the higher score. For multiple submissions from the same organization, CMS will score only the most recent submission, which will override any prior submissions of the same type. Different submission types from the same organization will be treated separately and not override each other.
Promoting Interoperability
No significant changes have been proposed for the Promoting Interoperability category. However, automatic reweighting will no longer be available for clinical social workers starting with the 2025 performance period and 2027 MIPS payment year, as this provision was only in effect through 2024. From 2025 onward, automatic reweighting will only apply to MIPS eligible clinicians, groups, and virtual groups with specific special statuses:
- Ambulatory Surgical Center (ASC)-based
- Hospital-based
- Non-patient facing
- Small practices
Promoting Interoperability Data Submission Criteria
Starting with the 2024 performance period and 2026 MIPS payment year, CMS proposes that Promoting Interoperability data submissions must include performance data, required attestations, a CMS EHR Certification ID, and performance period dates to be considered valid and scored. This proposal aims to prevent accidental submissions that lack necessary data, which would otherwise result in a null score and not override reweighting. Additionally, for multiple data submissions, CMS will calculate and assign the highest score received.
Cost Category
CMS is proposing to introduce six new episode-based cost measures starting with the 2025 performance period. These will be implemented at both the group (TIN) and clinician (TIN/NPI) levels, with a minimum of 20 episodes required. The new measures include:
- 1 acute inpatient medical condition measure: Respiratory Infection Hospitalization
- 5 chronic condition measures: Chronic Kidney Disease, End-Stage Renal Disease, Kidney Transplant Management, Prostate Cancer, and Rheumatoid Arthritis
Additionally, CMS is proposing significant updates to two existing episode-based cost measures to reflect re-evaluated versions:
- Cataract Removal with Intraocular Lens (IOL) Implantation (formerly Routine Cataract with IOL Implantation)
- Inpatient Percutaneous Coronary Intervention (PCI) (formerly ST-Elevation Myocardial Infarction [STEMI] PCI)
Cost Measure Benchmarking
CMS is proposing to revise the cost scoring benchmarking methodology starting with the 2024 performance period and 2026 MIPS payment year. If finalized, these changes would take effect when the 2024 final scores are released in the summer of 2025. The new methodology would set the median cost for a measure at a score based on the performance threshold for that MIPS payment year. For instance, in the 2024 performance period, the median would be set at 7.5, matching the performance threshold. Benchmark point ranges would then be determined by calculating standard deviations from this median.
Performance Category Reweighting
CMS proposes allowing clinicians to request reweighting of quality, improvement activities, or Promoting Interoperability categories if their data is inaccessible or not submitted due to issues with a third-party intermediary. CMS will consider whether the clinician was aware of the issue, took steps to correct it, and if the issue resulted in no data being submitted. Requests must be submitted through the QPP Service Center by November 1 before the relevant MIPS payment year, starting with the 2024 performance period and 2026 MIPS payment year.
Medicare Shared Savings Program (MSSP) Accountable Care Organizations (ACOs)
CMS proposes several significant updates to the quality measure reporting and scoring process for MSSP ACOs starting in 2025. It would establish the new APP Plus quality measure set, which MSSP ACOs will be required to use starting in 2025. The measure set will begin with eight measures and expand to eleven by 2028. CMS would also limit reporting options to eCQMs and Medicare CQMs, using flat benchmarks for Medicare CQMs during the first two performance periods, and continuing incentives for full eCQM reporting. More information about these proposed changes can be found here.
Public Comment Period
This proposed rule is open for public comment, and stakeholders are encouraged to provide feedback to help shape the final regulations. The public comment period will close on September 9, 2024. A final rule is expected to be released sometime in November.
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