Simplifying MIPS: Your Guide to 2025 Improvement Activities

As clinicians begin planning for the 2025 MIPS performance year, the Improvement Activities (IA) performance category remains a key opportunity to maximize your MIPS score with relatively low effort. The Centers for Medicare and Medicaid Services (CMS) finalized some notable updates to the IA category this year, including a smaller number of required attestations and simplified scoring. This post outlines the key updates for 2025 and shares a practical list of Improvement Activities that are both broadly relevant and commonly used across specialties, making them simple for most practices to implement.

What’s New for 2025?

For the 2025 performance year, the Improvement Activities inventory includes:

• 104 total activities
• 2 new activities
• 4 activities removed

NOTE: On May 13th, 2025, CMS suspended the following activities for the 2025 performance period: IA_AHE_5, IA_AHE_8, IA_AHE_9, IA_AHE_11, IA_AHE_12, IA_PM_6, IA_ERP_3, and IA_PM_26. However, if any of the suspended improvement activities have already been completed or were in the process of being completed, clinicians will still be able to attest to completing them and receive credit.

New Activities:

These activities have been added to the MIPS Improvement Activities inventory starting in the 2025 performance year.

• IA_PM_24: Implementation of Protocols and Provision of Resources to Increase Lung Cancer Screening Uptake
• IA_PM_25: Save a Million Hearts: Standardization of Approach to Screening and Treatment for Cardiovascular Disease Risk

Retired Activities:

These activities have been removed from the MIPS Improvement Activities inventory and are no longer available for attestation starting in the 2025 performance year.

• EPA_1: Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real-Time Access to Patient's Medical Record
• ERP_4: Implementation of a Personal Protective Equipment (PPE) Plan
• ERP_5: Implementation of a Laboratory Preparedness Plan
• PSPA_27: Invasive Procedure or Surgery Anticoagulation Medication Management

2025 IA Reporting Requirements

To receive full credit in the Improvement Activities category:

• Small practices (15 or fewer clinicians under a TIN) and clinicians with special statuses (Non-patient Facing, HPSA, or Rural) only need to attest to 1 activity.
• Larger practices (16 or more clinicians) must attest to 2 activities.
• Clinicians reporting under MVPs also need to attest to 1 activity regardless of group size or special status.

As a reminder, group reporting requires that at least 50% of clinicians under the TIN have completed the activity/activities being attested to. Additionally, small practices that are not reporting Promoting Interoperability, the IA score can contribute up to 30 points toward the final MIPS score.

Each Improvement Activity must be implemented for a minimum of a continuous 90-day period during calendar year (CY) 2025, unless a different duration is specified in the activity description. These activities do not need to be performed concurrently. The final continuous 90-day period to complete an activity begins on October 3, 2025.

Implementation and Documentation Tips

Once you've selected your activities, it's important to implement them fully and maintain documentation that supports your attestation.

• The CMS 2025 MIPS Data Validation Criteria is now available and outlines the acceptable forms of documentation for each Improvement Activity.
• Keep records that demonstrate completion and alignment with the criteria, and retain documentation for at least 6 years in case of an audit.
• Acceptable documentation may include:
  • Screenshots or exported EHR data showing completion
  • Written policies, workflows, or protocols
  • Patient communications, logs, or improvement plans

Easy & Popular Improvement Activities to Consider

To help simplify your selection process, here are several Improvement Activities that are commonly recommended, broadly applicable across specialties, and relatively easy for most practices to implement.

• IA AHE_1: Enhance Engagement of Medicaid and Other Underserved Populations
• IA AHE_6: Provide Education Opportunities for New Clinicians
• IA_BE_4: Enhancements to Patient Portal Functionality
• IA_CC_1: Referral Loop Closure
• IA_CC_13: Adoption of OpenNotes Principles
• IA_EPA_2: Use of Telehealth Services to Expand Access
• IA EPA_3: Collection and use of patient experience and satisfaction data on access
• IA_PM_16: Medication Management Improvements
• IA PM_21: Advance Care Planning
• IA_PSPA_8: Use of Patient Safety Tools
• IA_PSPA_21: Fall Risk Screening and Assessment
• IA PSPA_22: CDC Training on CDC’s Guideline for Prescribing Opioids for Chronic Pain

Final Thoughts

Choosing the right Improvement Activities is one of the easiest ways to boost your MIPS score. With streamlined requirements and a broad selection of applicable activities, 2025 is a great year to leverage this category for maximum impact with minimal burden. Make sure to plan early, document as you go, and check the MIPS Data Validation Criteria to ensure you're meeting CMS requirements and audit expectations.

If you're not sure where to start, begin with activities you're likely already doing, such as telehealth, patient portal use, or medication reconciliation. These simple steps can go a long way in helping your practice succeed in MIPS 2025.