The Merit-based Incentive Payment System (MIPS) is a key component of the Quality Payment Program (QPP) that determines Medicare reimbursement for eligible healthcare providers. MIPS assesses performance based on four categories—Quality, Cost, Promoting Interoperability, and Improvement Activities.
For 2025, the Centers for Medicare & Medicaid Services (CMS) have introduced several updates aimed at refining reporting requirements, improving data integrity, and adjusting scoring methodologies. These changes impact how clinicians report their performance and the potential payment adjustments they may receive.
Understanding MIPS
MIPS evaluates healthcare providers based on their performance in four categories:
Quality (30%) – Measures the effectiveness of patient care.
Cost (30%) – Assesses spending efficiency and cost reduction.
Promoting Interoperability (25%) – Evaluates the meaningful use of certified electronic health record (EHR) technology.
Improvement Activities (15%) – Encourages engagement in activities that enhance patient care and clinical practices.
Each category contributes to the final MIPS score, which determines Medicare payment adjustments. A high MIPS score can lead to positive payment adjustments, while a low score can result in penalties.
For a detailed explanation of MIPS, visit CMS’s official website.
Key 2025 MIPS Updates
CMS has introduced several important changes for the 2025 MIPS performance year, impacting reporting requirements, scoring methodologies, and data submission procedures.
1. Performance Category Weights Remain the Same
CMS has maintained the weighting of MIPS performance categories for 2025:
Quality: 30%
Cost: 30%
Promoting Interoperability: 25%
Improvement Activities: 15%
These allocations ensure that clinicians focus equally on quality and cost while emphasizing digital health records and practice improvement initiatives.
2. Performance Threshold Remains at 75 Points
To avoid a negative payment adjustment in the 2027 payment year, clinicians must achieve a minimum of 75 points in their MIPS final score for 2025. This threshold is unchanged from previous years, providing predictability for providers in planning their performance strategies.
3. Increased Data Completeness Requirements
CMS has extended the requirement for clinicians to report on at least 75% of their patients for each quality measure. This data completeness threshold will be enforced through the 2028 performance year.
Impact: This change ensures more comprehensive and reliable data collection, improving the accuracy of performance assessments. However, it may pose a challenge for smaller practices with limited reporting capabilities.
4. Improvement Activities (IA) Reporting Adjustments
CMS has streamlined Improvement Activities reporting to reduce administrative burden:
Small practices, rural clinicians, and those in health professional shortage areas (HPSAs) must attest to only one improvement activity.
All other clinicians must attest to two improvement activities.
Impact: This change makes it easier for small and rural practices to meet MIPS requirements while maintaining the focus on meaningful improvements in clinical care.
5. Revised Cost Performance Category Scoring
CMS has updated the cost performance category scoring methodology:
The median cost measure score is now tied to the performance threshold for the payment year. The new scoring model may result in higher cost scores, starting with the 2024 performance period.
Explanation: The new scoring methodology means that cost measures will be assessed in relation to the performance threshold rather than a purely comparative model against peers.
This shift may lead to higher costs being reflected in the final MIPS score, making it imperative for providers to analyze spending trends, implement cost-containment strategies, and adopt efficient clinical workflows.
Investing in data analytics, care coordination, and preventive care measures can help mitigate the risks associated with cost score adjustments.
Impact: Providers with lower cost efficiency may see a negative impact on their MIPS scores. Clinicians must carefully manage resource utilization and seek ways to optimize cost-effective care delivery.
6. Stricter Data Submission Requirements
CMS has introduced stricter data submission policies to enhance accuracy and completeness:
Quality Performance Category: Submissions must include numerator and denominator information for at least one quality measure to be scored.
Promoting Interoperability Performance Category: Submissions must include:
- Performance data for each measure in the objectives.
- Required attestation statements.
- CMS-certified electronic health record technology (CEHRT) ID.
- Start and end dates for the performance period.
Impact: These changes ensure more reliable data submission but require clinicians to pay closer attention to completeness and accuracy when reporting.
7. Protections for Clinicians Using Third-Party Intermediaries
For clinicians relying on third-party data submission intermediaries, CMS has introduced a policy allowing for reweighting of affected performance categories if the intermediary fails to submit data on time. Clinicians must provide evidence that the failure was beyond their control.
Impact: This update protects clinicians from penalties due to third-party submission errors, offering greater security when outsourcing data reporting responsibilities.
Implications for Healthcare Practitioners
These changes present both challenges and opportunities for healthcare providers participating in MIPS:
1. Reduced Administrative Burden
The reduction in required improvement activities will ease reporting requirements, particularly for small and rural practices.
Clearer data submission rules help clinicians avoid incomplete or inaccurate reporting.
2. Increased Financial Stakes
The 75-point performance threshold remains a critical benchmark to avoid penalties.
Cost performance scoring changes may impact providers with less efficient resource utilization.
The maximum penalty remains at 9%, reinforcing the need for strong performance across all MIPS categories.
3. More Reliable Data Reporting
Enforcing stricter submission criteria ensures that reported data is complete and accurate.
Clinicians must ensure they meet data completeness requirements to avoid score reductions.
4. Additional Support for Small Practices
Adjustments to improvement activities and protections for third-party reporting failures recognize the unique challenges small practices face. However, solo practitioners may still be at higher risk for penalties, highlighting the need for additional resources and guidance for these groups.
Conclusion
The 2025 MIPS updates reflect CMS’s ongoing effort to refine the program, enhance data integrity, and provide targeted support for small and rural practices. Healthcare providers must stay informed about these changes to optimize their MIPS performance and avoid negative payment adjustments.
Key Takeaways:
- The 75-point threshold remains unchanged, making strong performance crucial to avoid penalties.
- Stricter data submission requirements necessitate greater attention to accuracy.
- Cost performance scoring changes may lead to financial adjustments for some providers.
- Reduced improvement activities requirements lessen the reporting burden for small and rural practices.
- Protections for third-party submission failures provide security for clinicians relying on external intermediaries.
To ensure compliance with 2025 MIPS policies, healthcare providers should review the full guidelines on CMS’s Quality Payment Program website for further details.
How UnisLink Can Help Your Practice Succeed with MIPS in 2025
Navigating the complexities of MIPS reporting can be challenging for healthcare practices, but UnisLink offers support that helps a practice to streamline this process.
With UnisLink, practices can connect their MIPS technology to a registry that reports the data. UnisLink’s ONC Certified HIT systems integrate seamlessly with most EHR platforms, facilitating accurate and efficient clinical quality measures reporting.
Contact us for more information on MIPS reporting, a free quote for RCM services and gap analysis for how much revenue your practice can expect with systems improvement.