The Ultimate MIPS Adventure: Your Fun, Upbeat, and Incredibly Valuable Guide for Medical Clinics!

Heard the term MIPS buzzing around the clinic but not quite sure what it means for your practice? You’re in the right place! It’s completely understandable if government healthcare programs and their acronyms seem a bit like navigating a dense jungle without a map. They can be intimidating, packed with jargon, and often leave busy medical professionals wondering where to even begin. But this guide is different. Think of it as your friendly, expert companion, equipped with a machete to clear the confusing undergrowth and a compass to point you toward success.

The Merit-based Incentive Payment System, or MIPS, is a big deal in the Medicare world. It’s not just another set of letters to memorize; it’s a program that fundamentally changes how medical clinics are paid by Medicare, reflecting a major shift towards value-based care. The core idea is to move away from a system that simply pays for the volume of services provided, and towards one that recognizes and rewards high-quality, efficient patient care and robust patient engagement.¹ So, while the thought of another regulatory program might make one sigh, MIPS is actually designed with some positive intentions: to acknowledge the excellent work clinics do and to encourage continuous improvement in how healthcare is delivered.

What to Expect:

This article is crafted to be more than just a dry recitation of rules. The goal is to provide an engaging, upbeat, and, yes, even enjoyable journey through the world of MIPS. We’re here to demystify the program, decode the jargon, and arm your clinic with valuable, actionable information. We’ll explore what MIPS is all about, who needs to jump in, and what happens if you decide to sit on the sidelines. Next, we’ll pay special attention to small practices, uncovering the “secret weapons” CMS has provided to make MIPS more manageable for them. Let’s also peek into the future with the exciting role of Artificial Intelligence (AI) in the MIPS landscape, discuss how requirements can vary by medical specialty, and, of course, talk about the dollars and cents involved.

The very existence of a program as multifaceted as MIPS, with its detailed rules and significant financial implications, understandably creates a need for clear, accessible guidance among healthcare providers. The common perception is that resources on such topics are often dense and overly technical. This guide aims to fill that gap by being comprehensive yet easy to digest. The aim is to transform a potentially daunting subject into a manageable one, empowering your clinic with knowledge. Furthermore, MIPS is structured to “reward them for improving the quality of patient care and outcomes” and “tie payments to quality and cost-efficient care”.¹ This means that navigating MIPS strategically can actually align with your clinic’s inherent mission to provide outstanding patient care and operate efficiently. It’s an opportunity to frame compliance not just as a requirement, but as a pathway to showcasing and enhancing the great work you already do.

So, take a deep breath, grab a coffee, and let’s embark on this MIPS adventure together. By the end of this comprehensive guide, the aim is for you and your clinic to feel not just informed, but confident and ready to conquer the MIPS challenge, turning it into an opportunity for growth and recognition!

Decoding MIPS: Your A-to-Z Guide to Understanding the Basics

To truly master the Merit-based Incentive Payment System (MIPS), it’s essential to start with a solid understanding of its foundations. What is it, why does it exist, and what are its core components? Let’s break it down.

What Exactly IS the Merit-based Incentive Payment System?

The Merit-based Incentive Payment System, or MIPS, is one of two participation tracks within the broader Quality Payment Program (QPP). The QPP itself was established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), a landmark piece of legislation designed to overhaul how Medicare pays clinicians.¹ The fundamental purpose of MIPS is to shift Medicare Part B payments for eligible clinicians from a purely fee-for-service model (where payment is based solely on the quantity of services) to a system that rewards value and quality.¹ In essence, MIPS aims to pay clinicians for providing high-quality, efficient care to their Medicare patients.

For those who have been in healthcare for a while, MIPS effectively streamlines and replaces a “patchwork collection” of older Medicare reporting programs.⁴ These include the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier (VBPM), and the Medicare Electronic Health Record (EHR) Incentive Program, often remembered as “Meaningful Use”.⁴ By consolidating these, MIPS attempts to create a more unified framework for assessing and rewarding clinician performance. The program ties a clinician’s or group’s Medicare Part B payments directly to their performance across four specific categories, which we’ll delve into next.¹

The Four Pillars of MIPS: Performance Categories Unpacked

The MIPS program evaluates performance across four distinct categories. Understanding each of these “pillars” is crucial because a clinic’s efforts in these areas will ultimately determine their MIPS final score and subsequent payment adjustment.¹

Quality: This is a cornerstone of MIPS. The Quality performance category assesses the quality of care delivered by clinicians. This evaluation is based on a range of performance measures, some created by the Centers for Medicare & Medicaid Services (CMS) and others developed by professional medical groups, specialty societies, and other interested parties.¹ A key aspect here is flexibility; clinicians are generally able to pick the quality measures that best fit their practice, patient population, and specialty.² The goal is to demonstrate clinical effectiveness, adherence to evidence-based practices, and positive patient outcomes.
Promoting Interoperability (PI): Formerly known as Advancing Care Information (and before that, part of Meaningful Use), the Promoting Interoperability category focuses on how clinicians use Certified Electronic Health Record Technology (CEHRT). The emphasis is on patient engagement and the secure, electronic exchange of health information.¹ Clinicians report on a defined set of objectives and measures related to functionalities like providing patients with electronic access to their health information, e-prescribing, and exchanging information with other providers.² This category encourages the use of technology to improve care coordination, patient safety, and empower patients with greater access to and control over their health data.
Improvement Activities (IA): This performance category is designed to recognize and reward clinicians for activities they undertake to improve their clinical practice, enhance patient engagement, and increase access to care.¹ CMS provides an inventory of recognized improvement activities, and clinicians can choose those that are most relevant and impactful for their practice.² Examples might include expanding practice access through telehealth, implementing care coordination strategies, or enhancing patient safety protocols. This category values ongoing efforts to innovate and refine how patient care is delivered.
Cost: The Cost performance category evaluates the resources clinicians use to care for their Medicare patients. A significant feature of this category is that, for the most part, clinicians do not need to submit any data; CMS calculates cost performance based on Medicare administrative claims data.¹ Performance is typically assessed by comparing a clinician’s or group’s costs for specific episodes of care or overall patient care to national benchmarks, with adjustments made for patient risk factors to ensure fair comparisons.¹² This category directly addresses the national priority of making healthcare more affordable while striving to maintain or improve quality.

The MIPS program, by consolidating previous quality initiatives, aimed to streamline reporting. However, the introduction of these four distinct categories, each with its own detailed rules, measures, and reporting mechanisms, means that while some older administrative burdens might have been removed, new ones have emerged. This shift necessitates continuous learning and adaptation by medical clinics. It’s not simply a replacement of old forms with new ones; it’s a different way of thinking about and demonstrating value.

Furthermore, these four MIPS categories are not designed to be viewed in complete isolation. The structure encourages a more holistic perspective on “value.” For instance, robust performance in the Promoting Interoperability category, such as effectively using CEHRT, can directly support more accurate and complete data capture for the Quality category, especially when using electronic Clinical Quality Measures (eCQMs).¹⁴ Similarly, undertaking Improvement Activities focused on better care coordination ¹ could lead to fewer hospital readmissions or duplicative tests, which in turn could positively influence a clinic’s performance in the Cost category. This interconnectedness suggests that strategic investments and efforts in one MIPS area can yield benefits in others, encouraging a comprehensive approach to quality and efficiency.

A particularly interesting aspect is the Cost category. Since CMS calculates this based on claims data ¹, clinics don’t have a direct “reporting burden” in the same way they do for Quality or Improvement Activities. However, this doesn’t mean they have no control. The “performance burden” for Cost is continuous and deeply embedded in the daily clinical and operational decisions made throughout the entire year. Choices about treatments, referral patterns, and strategies to avoid unnecessary hospitalizations all directly influence the claims data CMS uses. Therefore, efforts in the Quality category (like preventing complications) and the Improvement Activities category (like enhancing care coordination) become primary levers for positively influencing the Cost score. Clinics must be mindful of the cost implications of their care delivery throughout the year, not just during a specific “reporting period.”

How MIPS Scores Are Calculated: The Path to Your Final Score

Performance in each of the four MIPS categories is assessed, and each category receives a score. These individual category scores are then weighted and combined to produce a single MIPS final score, which ranges from 0 to 100 points.² This final score is paramount because it directly determines the type and magnitude of the payment adjustment—positive, negative, or neutral—that will be applied to a clinician’s or group’s Medicare Part B covered professional services.²

It’s important to note that the weights assigned to each performance category can change from year to year based on CMS rulemaking. For the 2025 performance year, the general weighting is typically as follows (though variations can occur, especially for certain clinician types or circumstances like small practices or those with reweighted categories) ³:

Table 1: MIPS Performance Categories & Their Standard Weights (e.g., for 2025 Performance Year)

Performance Category	Standard Weight (2025)	Brief Description of What’s Assessed
Quality	30%	Quality of care delivered, based on performance measures related to outcomes, patient safety, care coordination, and patient experience. ¹
Promoting Interoperability	25%	Patient engagement and electronic exchange of health information using Certified EHR Technology (CEHRT). ¹
Improvement Activities	15%	Activities that improve clinical practice, care delivery, patient engagement, and access to care. ¹
Cost	30%	Cost of care provided to Medicare patients, based on Medicare claims data (generally no submission required). ¹

Sources: ¹

Understanding these category weights is fundamental for any clinic looking to strategize its MIPS efforts. This table provides a quick, clear overview of how the final score is composed, helping clinics see at a glance which areas carry the most weight and thus might require more focused attention. This foundational knowledge is key to strategic MIPS participation.

CMS also establishes a “performance threshold” each year. For the 2025 performance year, this threshold is 75 points.¹¹ Clinicians and groups must achieve a final MIPS score that meets or exceeds this threshold to avoid a negative payment adjustment and to potentially qualify for a positive payment adjustment.³ Scores below the threshold will result in a penalty.

Are You In the Game? Eligibility Rules & What’s at Stake

Navigating the Merit-based Incentive Payment System (MIPS) begins with a critical first step: determining eligibility. Not every clinician or practice that bills Medicare is required to participate in MIPS. Understanding the specific criteria, the low-volume threshold, and the implications of participation versus non-participation is essential for making informed decisions and avoiding unwelcome financial surprises.

Who Needs to Participate? Unraveling Eligibility

MIPS eligibility is determined by CMS based on a review of Medicare Part B claims data and information in the Provider Enrollment, Chain, and Ownership System (PECOS).¹⁸ This determination happens at both the individual clinician level (based on their unique National Provider Identifier (NPI) and associated Taxpayer Identification Number (TIN) combination) and at the group practice level (based on the TIN).²

CMS identifies specific clinician types as potentially eligible for MIPS. For the 2024 and 2025 performance years, these include:

Physicians (Doctors of Medicine, Doctors of Osteopathy, Doctors of Dental Surgery or Dental Medicine, Doctors of Podiatric Medicine, Doctors of Optometry, and Chiropractors)
Physician Assistants (PAs)
Nurse Practitioners (NPs)
Clinical Nurse Specialists (CNSs)
Certified Registered Nurse Anesthetists (CRNAs)
Clinical Psychologists
Physical Therapists (PTs)
Occupational Therapists (OTs)
Qualified Speech-Language Pathologists (SLPs)
Qualified Audiologists
Registered Dietitians or Nutrition Professionals
Clinical Social Workers
Certified Nurse Midwives.⁴

Any clinician group that includes one or more of these professionals may also be involved in MIPS reporting.⁴

The Low-Volume Threshold (LVT): Your Key to Exemption (Maybe!)

The most common factor determining mandatory MIPS participation is the low-volume threshold (LVT). This threshold consists of three criteria, and clinicians or groups must exceed all three during both 12-month segments of the MIPS Determination Period to be required to participate.¹⁸ The LVT criteria are:

Billing more than $90,000 for Medicare Part B covered professional services.
Providing care to more than 200 Medicare Part B patients.
Providing more than 200 covered professional services to Medicare Part B patients.¹⁸

If a clinician or group does not exceed all three of these thresholds, they are generally not required to participate in MIPS, though other options exist. CMS conducts two reviews of claims and PECOS data (each covering a 12-month segment) to make these eligibility determinations. The first review results in a preliminary eligibility status, and the second review reconciles with the first to provide a final determination.¹⁸

The LVT directly segments Medicare providers. Those falling below this threshold are generally shielded from MIPS penalties unless they choose to “opt-in.” This creates a pivotal strategic decision for those who are “opt-in eligible”: they must carefully weigh the administrative effort and potential risk of a negative payment adjustment against the possibility of earning a positive one if their performance is strong. It’s a business decision, not just a compliance checkbox.

To find out your specific MIPS eligibility status, the most reliable method is to use the QPP Participation Status Tool available on the CMS website (qpp.cms.gov). This tool requires the clinician’s 10-digit NPI to look up their status.³ It’s crucial to check this tool, as eligibility can sometimes change between the preliminary and final determination periods.²¹

Table 2: MIPS Eligibility at a Glance: Are You In? (Based on 2024/2025 Low-Volume Threshold)

Criteria	Threshold to Exceed (Annually per Determination Period Segment)	Your Clinic’s Status (Estimate)
Medicare Part B Allowed Charges for Professional Services	> $90,000
Number of Medicare Part B Patients Seen	> 200 Patients
Number of Covered Professional Services Provided to Part B Patients	> 200 Services

If your practice exceeds ALL THREE criteria during both determination segments, you are LIKELY REQUIRED to participate in MIPS. However, if you exceed ONE or TWO (but not all three), you MAY BE ELIGIBLE TO OPT-IN to MIPS. Or, if you do not exceed any, or only one or two and choose not to opt-in, you are generally exempt (but can report voluntarily). ALWAYS verify your official status using the CMS QPP Participation Status Tool!

This table offers a simple checklist for a quick preliminary assessment, but the official CMS tool is the definitive source.

Opt-In vs. Mandatory Participation vs. Voluntary Reporting

Based on the LVT and other factors, clinicians and groups fall into different participation categories:

Mandatory Participation: Clinicians or groups who exceed all three LVT criteria are required to participate in MIPS. Failure to do so will result in a negative payment adjustment.¹⁸
Opt-In Eligible Participation: Clinicians or groups who meet or exceed one or two, but not all three, of the LVT criteria are eligible to elect to opt-in to MIPS.⁵ If they opt-in, they are treated like mandatory participants, meaning they will be subject to the MIPS payment adjustment (either positive, negative, or neutral) based on their performance. The decision to opt-in is typically made by a deadline (e.g., March 31 of the year following the performance year) and is final for that performance year.¹⁹ The primary motivation to opt-in is the potential to earn a positive payment adjustment if the practice is confident in its ability to perform well.
Voluntary Reporting: Clinicians or groups who do not meet the LVT criteria (and are not otherwise required to participate, and choose not to opt-in if eligible) can still choose to report MIPS data voluntarily.¹⁹ If they report voluntarily, they will receive performance feedback from CMS but will not be subject to any MIPS payment adjustment (positive or negative). This can be a way to familiarize oneself with the program or track performance without financial risk.

Other Exemptions from MIPS

Besides the LVT, there are a few other specific exemptions:

Newly Enrolled Medicare Clinicians: Clinicians who enroll in Medicare for the very first time during a MIPS performance year are generally exempt from MIPS reporting until the following performance year. To qualify as “newly enrolled,” they cannot have previously submitted claims to Medicare under any other enrollment, either as an individual or through a group.⁴
Qualifying APM Participants (QPs) in Advanced Alternative Payment Models (APMs): Clinicians who participate sufficiently in an Advanced APM (the other track of the QPP) and achieve QP status are excluded from MIPS participation and are instead eligible for a 5% APM incentive payment.¹⁸ If they participate in an Advanced APM but do not achieve full QP status (perhaps achieving “Partial QP” status), they might still need to participate in MIPS unless they or their APM Entity elect otherwise.¹⁸

The presence of these multiple exemption categories—LVT, new enrollment, QP status—highlights that CMS acknowledges that a universal MIPS mandate isn’t practical or equitable for every provider or practice situation. These “off-ramps” offer relief but also add layers to understanding one’s precise obligations. Therefore, it’s paramount for clinicians not to assume their participation status without thoroughly checking all potential exemptions, primarily through the QPP Participation Status Tool. An incorrect assumption could lead to missed incentive opportunities (if opting-in would have been advantageous and was overlooked) or, conversely, unnecessary reporting efforts or even penalties if participation wasn’t actually required.

The Cost of Non-Participation: Understanding Penalties

For those who are required to participate in MIPS (either mandatorily or because they opted in), failing to submit data, or submitting data that doesn’t meet the program’s requirements, comes with a significant financial consequence: a negative payment adjustment.²

For recent performance years, such as the 2023 performance year (which impacts payments in 2025) and looking ahead to the 2025 performance year (impacting 2027 payments), the maximum negative payment adjustment is -9%.¹⁵ This adjustment is applied to the Medicare paid amount for covered professional services billed under Medicare Part B. The adjustment typically takes effect two calendar years after the performance year concludes. For example, performance in 2025 will affect Medicare payments received from January 1, 2027, through December 31, 2027.⁴

A potential 9% reduction in Medicare Part B revenue is a substantial financial risk that most clinics cannot afford to ignore. This figure underscores the strong financial lever CMS is using to drive participation and performance in the MIPS program. It signals a clear commitment to pushing the healthcare system towards value-based care. While positive payment adjustments are also possible for high performers (and are also subject to a maximum percentage, though influenced by budget neutrality, which will be discussed later), the penalty for non-performance or underperformance is a fixed and considerable threat.¹⁵ Clinics must factor this potential revenue impact into their financial planning and their overall strategy for engaging with the MIPS program. For most eligible clinicians, simply ignoring MIPS is not a financially sound option.

Small Practices, Big Advantages! Making MIPS Work for You

Navigating the Merit-based Incentive Payment System (MIPS) can feel particularly daunting for smaller medical practices, which often operate with tighter budgets and fewer administrative staff compared to larger healthcare systems. Recognizing these challenges, the Centers for Medicare & Medicaid Services (CMS) has built in a range of flexibilities and advantages specifically for “small practices.” Understanding these provisions is key for smaller clinics to not only comply with MIPS but also to potentially thrive within the program.

CMS Definition of a Small Practice for MIPS: Size Matters!

First and foremost, what does CMS consider a “small practice” for MIPS purposes? The definition is quite specific: a small practice is defined as a group that consists of 15 or fewer clinicians (identified by their National Provider Identifiers, or NPIs) who have reassigned their Medicare billing rights to a single Taxpayer Identification Number (TIN).¹³ CMS makes this determination by reviewing claims data submitted throughout the MIPS determination periods.¹³ This designation is incredibly valuable because it unlocks a variety of special considerations and reduced reporting burdens across the MIPS performance categories.

How Many Providers? Clarifying Small Practice Size

To reiterate, the threshold is 15 or fewer clinicians associated with the practice’s TIN.¹³ This count includes all clinicians billing under the TIN, even if some of those individual clinicians might not be MIPS eligible on their own (for example, if they are new to Medicare or fall below the low-volume threshold individually) or if they do not ultimately participate in MIPS reporting.¹³ The determination is made at the TIN level.

Claims-Based Reporting: A Lifeline for Small Practices?

One of the most significant advantages for small practices lies within the Quality performance category. Only small practices (those with 15 or fewer clinicians) are permitted to submit their MIPS Quality data via Medicare Part B claims.¹³ This option is also available to virtual groups that meet the small practice designation (i.e., the entire virtual group has 15 or fewer clinicians).²⁹

How does it work? Instead of using a third-party registry or complex Electronic Health Record (EHR) data extraction processes, small practices can report on selected quality measures by adding specific G-codes (Quality Data Codes or QDCs) to their routine Medicare Part B claims throughout the performance year.²⁷ This method leverages existing billing workflows, which can be a substantial simplification.

However, there are still crucial requirements:

Data Completeness: For claims-based measures, small practices must submit data on at least 75% of all eligible Medicare Part B patients who meet the denominator criteria for each reported measure. This data must be reported for the entire 12-month performance period (January 1 – December 31).¹⁴ This 75% threshold is an increase from the previous 70% and applies for the 2024 and 2025 performance years.
Case Minimum: Most quality measures have a case minimum of 20 eligible instances that must be reported for the measure to be scored against a benchmark.¹⁴

This claims-based reporting option can indeed be a lifeline. It potentially avoids the costs associated with third-party MIPS registries and the technical complexities of EHR-based reporting for the Quality category. However, the 75% data completeness requirement for Medicare Part B patients is a critical detail. If a small practice chooses this route, they must be diligent in applying the correct G-codes consistently throughout the entire year for all eligible Medicare patients for each chosen measure. Missing this target for a specific measure could result in that measure scoring zero points (though small practices have a 3-point floor for measures that meet data completeness but not case minimums, or lack a benchmark ²⁵). The “simplicity” of claims reporting is therefore balanced by the need for meticulous, year-long tracking and consistent application of codes by billing staff. Training for billing personnel on the specific MIPS G-codes and their proper usage is paramount to success with this reporting method.

Other Perks for Small Practices: The Good News Keeps Coming!

Beyond claims reporting, small practices benefit from several other MIPS accommodations:

Improvement Activities (IA):
Reduced Requirement: For traditional MIPS, small practices (along with those in rural areas, Health Professional Shortage Areas (HPSAs), or designated as non-patient facing) generally only need to attest to performing one improvement activity to achieve the maximum 40 points and full credit in this category.⁴ This is a significant reduction from the two activities typically required for larger practices.¹⁰ For the 2025 performance year, CMS has also removed the “medium” and “high” weighting for individual improvement activities, simplifying the selection process further.¹⁰ Each activity must still be performed for a minimum continuous 90-day period during the performance year unless otherwise specified.¹⁰
Promoting Interoperability (PI):

Automatic Reweighting: Small practices are generally not required to report data for the Promoting Interoperability category. This category is typically automatically reweighted to 0% of their final MIPS score, and its 25% weight is redistributed to other categories, most commonly to the Quality category, increasing its impact on the final score.¹³ This relieves small practices from the often complex and resource-intensive requirements of PI reporting, which heavily relies on Certified EHR Technology (CEHRT).
Option to Report: However, small practices can choose to report PI data if they have the capability (i.e., use CEHRT) and believe it would be beneficial to their score.¹³ If they submit complete and accurate PI data, it will be scored.
Hardship Exceptions: If a small practice would normally be subject to PI reporting (perhaps they don’t qualify for automatic reweighting due to other circumstances, or they choose to report but encounter issues), they can apply for a PI Hardship Exception. Reasons for hardship can include issues like decertified EHR technology, insufficient internet connectivity, extreme and uncontrollable circumstances (e.g., disaster, practice closure, severe financial distress, vendor issues), or lack of control over CEHRT availability.³⁹ An approved hardship exception will also result in the PI category being reweighted to 0%.
Quality Category Scoring Bonuses & Leniencies:

Small Practice Bonus: A significant perk is the six bonus points automatically added to the Quality performance category score for clinicians in small practices who submit data for at least one quality measure (whether reported individually, as a group, virtual group, or APM Entity).¹⁴ This is a direct boost to the numerator of the Quality score, making it easier to achieve a higher percentage in this heavily weighted category.
Measures Without a Benchmark or Not Meeting Case Minimum: Small practices receive 3 points for submitting quality measures that meet data completeness requirements but either do not have an available benchmark (historical or performance period) or do not meet the case minimum (typically 20 cases).²⁵ In contrast, other, larger practices would typically receive zero points for such measures. This provision prevents small practices from being unduly penalized for reporting on newer measures, measures with low applicability to their patient population, or measures where benchmarks are still being developed.

These combined flexibilities—claims-based Quality reporting, a reduced IA requirement, automatic PI reweighting, and specific Quality scoring advantages—collectively create a substantially lower barrier to successful MIPS participation for small practices. This indicates that CMS acknowledges the unique resource constraints these smaller entities face and is actively working to prevent the MIPS program from disproportionately penalizing them. Small practices should not be deterred by the overall complexity of MIPS; instead, they should strategically leverage these specific provisions.

Key Compliance Steps for Small Practices Navigating MIPS

Given these advantages, what are the essential steps for a small practice to navigate MIPS successfully in 2025?

Consult Key Resources: Make the “2025 MIPS Quick Start Guide for Small Practices” and the “2025 Small Practice Action Planning Tool” from CMS your primary references.¹ These documents are specifically designed to synthesize the flexibilities and offer a simplified pathway for small practices.
Verify Eligibility: Diligently check your practice’s (TIN-level) and individual clinicians’ (NPI-level) MIPS eligibility using the official QPP Participation Status Tool on the CMS website.¹³ Don’t assume your status.
Choose Quality Reporting Method: If eligible for claims-based Quality reporting and opting for it:

Identify relevant claims-based quality measures early in the performance year.
Ensure your billing staff are thoroughly trained on correctly applying the necessary G-codes/QDCs to claims.
Implement a system to track submissions throughout the year to ensure the 75% data completeness threshold for Medicare Part B patients is met for each chosen measure.

Select and Perform Improvement Activity: Choose one Improvement Activity from the CMS inventory that is meaningful to your practice. Perform this activity for at least a continuous 90-day period during 2025 and meticulously document your actions and the timeframe.¹¹
Address Promoting Interoperability: Decide whether to rely on the automatic PI reweighting (most common for small practices) or, if your practice uses CEHRT effectively and believes it can score well, plan to collect and report PI data. PI reporting requires data collection for a minimum continuous 180-day period in 2025.⁹ If facing challenges that prevent PI reporting, consider applying for a PI Hardship Exception by the deadline.³⁹
Understand Cost: Remember that the Cost category is calculated by CMS based on your claims data. Focus on providing efficient, high-value care throughout the year, as this is how you influence your Cost score.¹³
Submit Data on Time: Ensure all necessary data for Quality (if not solely claims-based), Improvement Activities, and Promoting Interoperability (if reporting) is submitted to CMS via the QPP portal by the deadline, which is typically March 31 of the year following the performance year (e.g., March 31, 2026, for 2025 data).¹³ (Note: The 2024 submission deadline was extended to April 14, 2025, due to specific circumstances, but the standard deadline should be anticipated ²²).

The availability of dedicated CMS resources like the “Quick Start Guide for Small Practices” signifies a targeted support effort. This suggests that small practices are recognized as a distinct cohort with unique needs, and CMS is attempting to address these proactively, possibly due to feedback about the MIPS burden or to ensure their continued participation and success in the value-based care landscape. Small practices should prioritize locating and utilizing these specific CMS resources as their primary starting point for MIPS planning.

Table 3: Sweet Perks for Small Practices in MIPS (2025 Performance Year)

MIPS Category / Aspect	Small Practice Advantage / Leniency	Key Details & Requirements
Definition	15 or fewer clinicians (NPIs) under a single TIN. ¹³	CMS determines based on claims data.
Quality Category	Claims-based reporting option available. ¹⁴	Report via G-codes on Medicare Part B claims. Must meet 75% data completeness for Medicare Part B patients per measure over 12 months. ¹⁴
	6 bonus points added to Quality score. ¹⁴	Awarded for submitting at least one quality measure.
	3 points for measures without a benchmark or not meeting case minimum (if data completeness met). ²⁵	Prevents being penalized for reporting newer or less common measures. Other practices typically get 0 points.
Improvement Activities	Attest to only 1 activity for full credit (40 points) in Traditional MIPS. ¹⁰	Activity performed for a continuous 90-day period. Weighting of activities removed for 2025. ¹¹ Larger practices typically need 2 activities.
Promoting Interoperability	Category is typically automatically reweighted to 0%. ¹³	Weight is redistributed (usually to Quality). No PI data submission required unless the practice chooses to report. If choosing to report, a 180-day performance period is required. ³⁵ PI Hardship Exception is also an option. ³⁹
Overall	Reduced administrative burden and increased scoring flexibility.	Access to targeted CMS resources like the “2025 MIPS Quick Start Guide for Small Practices.” ¹³

Sources: ¹⁰

MIPS Mastery: Tips, Tricks, & Cost-Effective Reporting Strategies

Successfully navigating the Merit-based Incentive Payment System (MIPS) isn’t just about understanding the rules; it’s about implementing smart strategies that make the process manageable, effective, and as cost-efficient as possible. Many practices have found ways to not only comply with MIPS but also to leverage it for genuine quality improvement. Let’s explore some user-reported wisdom and savvy alternatives to expensive reporting methods.

User-Reported Wisdom: Tips and Tricks for Managing MIPS Successfully

Clinics that have achieved MIPS success often point to a combination of proactive planning, team involvement, and smart use of resources. Here are some commonly shared tips:

Engage Your Entire Team: MIPS is not a task that can be siloed with one administrator. It truly requires a team effort.⁸ This means conducting regular training sessions and providing updates to all staff members about MIPS requirements and how their specific roles contribute to the practice’s performance. Fostering an environment of open dialogue where team members feel comfortable sharing ideas, concerns, and feedback about MIPS processes is also vital. Finally, recognizing and celebrating the team’s hard work and achievements, whether it’s meeting quality goals or successfully implementing a new improvement activity, can boost morale and maintain motivation.⁸
Leverage Technology (Wisely): Your Electronic Health Record (EHR) system and other technological tools can be powerful allies in your MIPS journey.⁸ Many modern EHRs offer functionalities specifically designed to support MIPS reporting, including interoperability features for data exchange and built-in tools for tracking and reporting quality measures. Data analytics tools, whether part of your EHR or standalone, can provide valuable insights into your practice’s performance, helping to identify areas that are doing well and those that need improvement. This data-driven approach allows for more informed decision-making and targeted efforts to enhance MIPS scores.⁸
Focus on High-Impact, Relevant Measures (Quality Category): When selecting Quality measures, avoid simply picking those that seem easiest to report. Instead, choose measures that are genuinely relevant to your patient population, align with your practice’s clinical strengths, and reflect your authentic quality improvement goals.⁸ Concentrating efforts on measures that truly matter to your practice and your patients is more likely to lead to better patient outcomes and, consequently, better MIPS performance. It’s also wise to regularly review your chosen measures based on your performance data and any changes in practice priorities or MIPS measure specifications.⁸
Implement Meaningful Improvement Activities: The Improvement Activities (IA) category should be seen as an opportunity to showcase your practice’s commitment to enhancing care. Select activities that are not just easy to attest to but that will bring tangible benefits to your patients and practice workflows.⁸ This could involve initiatives like developing patient education programs, improving care coordination processes, integrating telehealth services to expand access, undertaking specific quality improvement projects, or engaging in community health initiatives.⁸
Continuous Monitoring and Reporting Preparation: Don’t leave MIPS data collection and reporting preparation until the end of the performance year. This is a year-round endeavor.³ Establish clear performance goals for your chosen measures and activities early on. Regularly gather and review your performance data using tools like your EHR. This frequent monitoring allows you to spot trends, identify potential issues or areas for improvement proactively, and make adjustments to your strategies as needed.⁸ Problem-solving sessions and ongoing staff education can ensure everyone understands their role in meeting MIPS requirements. Planning for the actual data submission process well in advance can also make it much smoother.⁸
Prioritize Data Accuracy: The adage “garbage in, garbage out” is particularly true for MIPS reporting.⁸ Inaccurate or incomplete data can lead to poor scores and potentially missed incentives or even penalties. Practices should emphasize the importance of correct data entry from the outset. Investing in robust systems and processes for data collection, validation, storage, and analysis is crucial. Regular data audits or checks and thorough staff training on proper data input protocols can help prevent errors and ensure the integrity of the data submitted to CMS.⁸
Stay Updated on MIPS Rules: The MIPS program is not static; CMS can and does make changes to the rules, measures, and requirements from one performance year to the next.³ It’s essential for practices to stay informed about the latest QPP updates, Physician Fee Schedule Final Rules, and any specific guidance CMS releases for the relevant performance year. Subscribing to CMS listservs and regularly checking the QPP website are good practices.
Consider MIPS Scoring During Care Provision (Ethically): While the primary focus must always be on providing the best possible care for the patient, having an awareness of how certain clinical actions or documentation practices might align with MIPS quality measures can be beneficial.³ This doesn’t mean altering care inappropriately to “chase points,” but rather ensuring that good care, which often aligns with measure specifications, is accurately documented and captured. This requires careful, ethical consideration to ensure patient needs always come first.

A common thread through these tips is the idea that successful MIPS management is not a separate, isolated task performed once a year. Instead, it involves integrating MIPS considerations into the ongoing, daily operations of the practice. This includes everything from team huddles and technology utilization to data management protocols and a culture of continuous quality improvement. Clinics that proactively embed MIPS into their workflows and organizational culture are more likely to find the program manageable and may even discover that it acts as a catalyst for genuine improvements in patient care and operational efficiency, aligning perfectly with the overarching goals of the MIPS program itself.

Beyond Expensive Registries: Smart Alternatives for MIPS Reporting

One of the concerns often voiced by medical practices, especially smaller ones, is the potential cost associated with MIPS reporting, particularly if it involves engaging third-party registry services like Qualified Clinical Data Registries (QCDRs) or Qualified Registries (QRs).²⁷ While these registries can offer valuable support, data analytics, and submission services, they do come with associated fees. Fortunately, CMS provides several no-cost or lower-cost mechanisms for submitting MIPS data, which can be particularly appealing for practices looking to manage compliance expenses.⁷

Here are some key alternatives:

Medicare Part B Claims Submission (for the Quality category):

As discussed extensively in Section 4, this option is available exclusively to small practices (15 or fewer eligible clinicians) and virtual groups with a small practice designation.¹⁴
Selected Quality measures are reported by adding specific G-codes (QDCs) directly onto the Medicare Part B claims that are already being submitted for patient services.
Cost Implication: This method leverages existing billing processes and infrastructure. The primary “cost” is the staff time required for accurate G-code selection and application, and ensuring the 75% data completeness for Medicare Part B patients is met for each measure.¹⁴ There are typically no additional vendor fees for the submission itself via this route.
Direct Submission via QPP Submission Application Programming Interface (API):

This method allows third-party intermediaries—such as QCDRs, Qualified Registries, and some EHR vendors—to transmit MIPS data directly to CMS through a secure, computer-to-computer interaction.⁹
Cost Implication: The cost here depends entirely on the vendor. Some EHR systems may include this API submission capability as part of their standard package or for an additional fee. If using a QCDR or QR that utilizes this API, their service fees would apply.
Sign In and Attest (formerly known as “Log-In and Attest”):

This is a manual data entry option directly on the QPP website (qpp.cms.gov). Clinicians or their representatives can sign in to their QPP account and manually attest to their performance for the Improvement Activities and Promoting Interoperability performance categories.⁹ This involves entering numerators and denominators or confirming “yes/no” to specific attestations.
This option is available to individual clinicians, groups, and third-party intermediaries acting on their behalf.
Cost Implication: This submission method is free from CMS charges. The “cost” is the manual effort and time required to accurately compile and enter the data.
Sign In and Upload (formerly known as “Log-In and Upload”):

This method also involves signing into the QPP website. Instead of manual attestation for every data point, users can upload data files in a CMS-approved format.⁹ Common file formats include QRDA III (Quality Reporting Document Architecture Category III) for eCQMs from an EHR, or CSV files for other data.
This option is available to individual clinicians, groups, and third-party intermediaries.
Cost Implication: The upload process itself on the QPP portal is free. However, the cost depends on how the data file is generated. If an EHR system can export the required file format at no extra charge, then this can be a very low-cost option. If specialized software or vendor assistance is needed to create the file, those costs would apply.
CMS Web Interface: It’s worth noting that the CMS Web Interface is another reporting option, but its availability is very limited. It’s typically only available for Medicare Shared Savings Program Accountable Care Organizations (MSSP ACOs) and requires reporting on a pre-defined set of measures.²⁷ For most individual clinics or smaller groups not part of such ACOs, this is not a relevant option.

The availability of these no-cost or low-cost reporting options, particularly claims-based reporting for small practices and the direct attestation/upload capabilities via the QPP portal, provides a clear pathway for practices to manage their MIPS-related expenditures. The choice of reporting method can directly reduce or even eliminate specific vendor costs associated with MIPS compliance. This is a strategic lever that resource-constrained practices can use effectively.

However, it’s crucial to understand that while these “free” CMS submission methods don’t have direct vendor fees for the act of submission, they are not entirely “effort-free.” For example, the “Sign In and Attest” method requires careful and accurate manual data entry, along with internal validation to ensure correctness. The “Sign In and Upload” method requires the practice to have the capability (often through their EHR) to generate the data file in the precise, CMS-specified format, which can sometimes be technically challenging. Similarly, claims-based reporting, while leveraging existing workflows, demands meticulous G-code application on every relevant claim throughout the entire 12-month performance period to meet data completeness requirements. Therefore, the financial cost saving achieved by using these direct CMS options is often balanced by an internal operational “cost” in terms of staff time, training, and the need for internal expertise and robust processes. Clinics should not hear “free” and underestimate the internal effort or technical know-how required to utilize these options effectively and accurately. This guide aims to clarify that “low cost” doesn’t necessarily mean “no work,” but it does offer significant financial flexibility.

The Future is Here: AI and Your MIPS Journey

The landscape of healthcare is rapidly evolving, with technology playing an increasingly pivotal role. One of the most talked-about advancements is Artificial Intelligence (AI), and its potential to transform various aspects of medical practice is immense. But what does AI mean for your clinic’s journey with the Merit-based Incentive Payment System (MIPS)? Far from being a futuristic fantasy, AI is already offering practical solutions that can help practices navigate the complexities of MIPS more efficiently and effectively.

Introduction to AI in Healthcare and its Relevance to MIPS

In the context of healthcare, Artificial Intelligence refers to computer systems and applications that can perform tasks that typically require human intelligence. This includes capabilities like learning from data, solving complex problems, understanding human language, and making data-driven decisions or predictions.⁴⁶ While the term “AI” might conjure images of science fiction, its real-world applications in medicine are becoming increasingly tangible, moving from hype to habit in many clinical and operational workflows.⁴⁸

The connection between AI and MIPS is compelling. The MIPS program, with its emphasis on quality reporting, cost efficiency, promoting interoperability, and improvement activities, is inherently data-intensive. It requires clinics to collect, analyze, and report on a vast amount of patient and performance data. This is precisely where AI’s strengths in data processing, pattern recognition, and automation can offer significant advantages.

How Artificial Intelligence is Shaping MIPS Participation

AI is beginning to influence several key areas relevant to MIPS participation, offering solutions to some of the program’s most persistent challenges:

AI for Data Abstraction and Submission:

The Challenge: A major hurdle in MIPS reporting, particularly for the Quality category, is the need to extract specific clinical data from patient records. Manual chart abstraction is notoriously time-consuming, labor-intensive, and prone to human error.
The AI Solution: AI technologies, especially Natural Language Processing (NLP) and machine learning (ML), are being developed to automate this process. NLP can “read” and understand unstructured clinical notes in EHRs, while ML algorithms can be trained to identify and extract the specific data elements required for various MIPS quality measures.⁴⁶ Some automated medical coding solutions, powered by AI, can even generate relevant MIPS measures directly from clinical documentation.⁵⁴ Companies like NJII (with AutoChart AI), Autonomize AI, Pharos, Carta Healthcare, Cotiviti, and Dyania Health are among those offering AI-driven tools for chart abstraction and registry submissions.⁵⁰
Benefit for MIPS: This automation can drastically reduce the administrative burden on clinicians and staff, improve the accuracy and completeness of data collected for MIPS, and streamline the preparation of data for submission.⁴⁶
AI in Quality Improvement and Clinical Decision Support (CDS):

The Challenge: Identifying specific areas where quality of care can be improved and implementing effective, evidence-based interventions can be complex.
The AI Solution: AI-powered Clinical Decision Support (CDS) systems can integrate with EHRs to provide real-time, patient-specific recommendations to clinicians at the point of care. These systems can analyze a patient’s data against established clinical guidelines and MIPS quality measure specifications, prompting clinicians to take appropriate actions (e.g., order a necessary screening, document a specific finding) that align with best practices and MIPS requirements.⁸ An example is the use of CDS for Lyme disease, which can be built into clinician workflow.⁵⁵ Furthermore, AI can analyze practice-level data to identify patterns, anomalies, or care gaps across patient populations, highlighting opportunities for targeted quality improvement initiatives relevant to MIPS measures.⁴⁷
Benefit for MIPS: This can lead to improved performance on Quality measures by ensuring that evidence-based care is delivered more consistently and that necessary actions are documented, ultimately resulting in more proactive and higher-quality patient care.
AI for Predictive Analytics for Cost and Quality Measures:

The Challenge: The Cost category of MIPS is calculated by CMS from claims data, making it feel less directly controllable. Proactively managing both cost and quality requires deep insights into patient populations and care patterns.
The AI Solution: Predictive analytics, fueled by AI and ML, can analyze historical claims data and patient data to forecast future healthcare expenditures, identify patients at high risk for costly events (like hospital readmissions or complications), and help optimize resource allocation.⁴⁷ Specialized MIPS Cost Analytics tools are emerging that compile and analyze Medicare claims data to provide practices with a clearer picture of their performance on specific cost measures and identify actionable insights for improvement.⁵⁶ AI can also play a significant role in population health management by analyzing large datasets to identify risk factors, predict disease trends, and develop targeted interventions, all of which can inform strategies for both the Quality and Cost categories of MIPS.⁴⁷
Benefit for MIPS: These tools can provide a better understanding of a practice’s cost drivers, enabling more targeted interventions to improve efficiency. This can lead to better performance in the Cost category and also support proactive management of Quality measures by identifying at-risk patients who may benefit from specific interventions.
AI’s Potential to Improve MIPS Scores and Clinic Efficiency:
The applications described above can collectively contribute to:

Higher MIPS Scores: Through more accurate and complete data submissions, improved performance on Quality measures facilitated by CDS, and potentially better Cost scores due to optimized resource use and proactive care.⁵⁷
Increased Clinic Efficiency: By automating routine and time-consuming MIPS-related tasks such as data collection, chart abstraction, and reporting preparation, AI can significantly reduce the administrative burden on clinic staff, freeing them up for higher-value activities, including direct patient care.⁴⁷
Reduced Physician Burnout: A significant contributor to physician burnout is the overwhelming administrative workload, including extensive documentation.⁴⁶ AI tools that streamline documentation and reduce the clerical burden associated with programs like MIPS can give clinicians back valuable time, allowing them to focus more on patient interactions and less on paperwork.
While direct, quantified impacts of AI specifically on MIPS scores are still emerging in peer-reviewed literature, the efficiency gains reported by some EHR vendors incorporating AI are indicative of its potential. For instance, athenahealth has reported that its AI-enabled tools have led to significant reductions in clicks for common tasks, time spent on document processing, and clinical analysis time for prior authorizations, as well as fewer claim denials due to insurance selection errors.⁵⁸ While not direct MIPS metrics, these efficiencies can free up substantial staff resources and time that could then be redirected towards more focused MIPS activities and quality improvement efforts.

The increasing complexity and data demands of the MIPS program, such as rising data completeness thresholds and the sheer number of available measures, act as a direct catalyst for the adoption of AI tools in healthcare. As manual processes become more burdensome and costly (with MIPS compliance estimated to cost around $12,800 per physician annually and consume over 200 hours of their time ²⁴), the value proposition of AI solutions that can automate data abstraction, enhance accuracy, and provide predictive insights becomes increasingly attractive. This suggests an emerging trend where we will likely see more development and marketing of AI solutions specifically tailored to MIPS compliance and performance optimization.

Current State and Future Outlook for AI in MIPS

It’s important to acknowledge that the adoption of AI in healthcare, and specifically for MIPS, is still an evolving process. Adoption rates can be uneven, often with larger practices having more resources to invest in these technologies compared to smaller, independent clinics.⁴⁹

Several factors will influence the future trajectory of AI in MIPS:

Data Quality and Interoperability: The effectiveness of any AI tool is fundamentally dependent on the quality, completeness, and accessibility of the underlying data. The principle of “garbage in, garbage out” is highly relevant here.⁵⁹ The MIPS Promoting Interoperability category, by encouraging the use of CEHRT and fostering the electronic exchange of health information, plays a crucial, if perhaps inadvertent, role in creating a more fertile data environment for AI applications to thrive.⁶⁰ Clinics that have invested in robust EHR systems and excel in Promoting Interoperability will likely be better positioned to leverage AI for MIPS and other value-based care initiatives. This creates a positive feedback loop: good PI practices lead to better data, which enables more effective AI, which in turn can help improve performance across all MIPS categories.
Regulatory Landscape and Standards: The Office of the National Coordinator for Health Information Technology (ONC) is actively involved in promoting AI education, ensuring transparency in AI algorithms, and working towards the development of standards for AI in healthcare.⁶⁰ This governmental oversight will be crucial for building trust and ensuring the safe and ethical deployment of AI tools.
Addressing Challenges: Key challenges that need to be addressed include ensuring data quality, mitigating potential biases in AI algorithms that could exacerbate health disparities, and establishing robust AI governance frameworks within healthcare organizations.⁵⁹
MIPS Program Evolution: Currently, the MIPS framework does not explicitly offer direct bonus points or incentives for the use of AI tools themselves. Instead, it rewards the outcomes that AI might help achieve, such as improved Quality scores or better Cost performance. This means that the decision for a clinic to invest in AI for MIPS purposes is a strategic one, based on an anticipated return on investment from improved overall scores, enhanced operational efficiency, or significant penalty avoidance, rather than a direct MIPS payment for adopting AI. As clinics evaluate AI tools, they need to assess the potential impact on the specific MIPS measures they report and the overall efficiency gains that can be achieved, rather than looking for an “AI bonus” line item in their MIPS feedback.

Despite these considerations, the future looks bright. AI is poised to play an increasingly significant role in helping medical practices manage the demands of value-based care programs like MIPS, making reporting more streamlined, insights more powerful, and ultimately contributing to better patient care.⁶⁰

Table 4: AI Applications for MIPS: Streamlining Your Journey

AI Application Area	How AI Helps	Potential MIPS Impact	Example Tools/Concepts (Illustrative)
Data Abstraction for Quality Measures	NLP reviews clinical notes; ML identifies/extracts data for MIPS measures; automated coding. ⁴⁶	Improved accuracy & completeness of Quality data; reduced reporting burden; potentially higher Quality scores.	AutoChart AI ⁵⁰, Autonomize AI ⁵¹, MediMobile Automated Medical Coding ⁵⁴
Clinical Decision Support (CDS)	Real-time prompts based on guidelines & patient data; identifies care gaps. ⁸	Enhanced performance on Quality measures; more consistent adherence to best practices.	EHR-integrated CDS; AI-driven risk stratification tools.
Predictive Analytics for Cost & Quality	Forecasts expenditures; identifies high-risk/high-cost patients; optimizes resources. ⁴⁷	Better understanding of Cost drivers; potential for improved Cost scores; targeted Quality improvement interventions.	MIPS Cost Analytics software ⁵⁶; Population health management platforms with predictive capabilities.
MIPS Reporting Automation	Streamlines generation of MIPS measures; assists in formatting data for submission. ⁵⁰	More efficient submission process; reduced administrative overhead; potentially fewer submission errors.	AI-powered EHR modules; specialized MIPS reporting solutions with AI components.
Workflow Automation (General)	Automates scheduling, billing tasks, document routing. ⁴⁸	Frees up staff time that can be dedicated to MIPS compliance and quality improvement efforts; reduces burnout.	AI-powered voice assistants for EHR navigation ⁵⁸; automated prior authorization tools ⁵⁸; intelligent document processing. ⁵⁸

This table provides a snapshot of how AI can be practically applied to various facets of the MIPS program, helping clinics understand the tangible benefits these advanced technologies can bring to their compliance and performance efforts.

MIPS Across the Medical Spectrum: Specialty Spotlights & MIPS Value Pathways (MVPs)

The Merit-based Incentive Payment System (MIPS) is designed to apply to a wide array of medical specialties, but a one-size-fits-all approach to quality measurement and improvement isn’t always optimal. Recognizing this, CMS has been working towards more tailored reporting options. While the foundational elements of MIPS—the four performance categories of Quality, Promoting Interoperability (PI), Improvement Activities (IA), and Cost—remain consistent, the specific measures and activities can vary, especially with the introduction and expansion of MIPS Value Pathways (MVPs).¹

General MIPS Requirements: A Quick Refresher

Before diving into specialty specifics, it’s helpful to recall that Traditional MIPS is the original reporting framework. Under Traditional MIPS, clinicians and groups select the quality measures and improvement activities they will report from the complete inventory finalized by CMS for a given performance year.² They also report on a complete set of Promoting Interoperability measures (unless exempt or reweighted), and CMS calculates their performance in the Cost category based on administrative claims data.²

The Rise of MIPS Value Pathways (MVPs): A More Tailored Approach

MIPS Value Pathways (MVPs) represent CMS’s strategic direction for the future of MIPS. Introduced as a newer reporting option, MVPs offer a more focused and clinically coherent set of measures and activities that are relevant to a particular medical specialty, clinical condition, or episode of care.¹ The primary goals of MVPs are to:

Reduce reporting burden by offering a smaller, more targeted set of measures compared to the entire Traditional MIPS inventory.⁷
Provide more meaningful groupings of measures and activities, fostering a more connected and holistic assessment of the quality of care delivered.⁷
Align measures across the Quality, Cost, and Improvement Activities categories, often with a foundational layer of Promoting Interoperability and population health measures.³⁸

MVP Structure: An MVP typically requires participants to report on:

A specific set of 4 quality measures, one of which must be an outcome measure (or a high-priority measure if an outcome measure is not available or applicable).⁵
1 improvement activity (for the 2025 performance year, as IA weighting has been removed) selected from a list specific to that MVP.¹¹
The standard Promoting Interoperability measures (unless the participant qualifies for reweighting, such as small practices).⁶³
Specific cost measures relevant to the MVP’s clinical theme, which CMS calculates from administrative claims data.⁶³
MVPs also incorporate population health measures, which are administratively calculated by CMS. For 2025, MVP participants are no longer required to select a population health measure at registration; CMS will calculate all available population health measures for an MVP participant and apply the highest-scoring one to their Quality category score.⁶⁷

MVP Registration: Participation in an MVP requires formal registration with CMS. For the 2025 performance year, the MVP registration window is generally from April 1, 2025, to December 1, 2025, at 8 p.m. ET.³⁵ During registration, participants select their MVP, and if reporting as a subgroup, provide details about the subgroup composition.⁶⁹

The Future is MVPs: It’s critical for all clinics to understand that CMS has clearly signaled its intention to transition the MIPS program fully to MVPs, eventually sunsetting the Traditional MIPS reporting option. This transition is anticipated to occur around 2026-2028.³ This makes familiarizing oneself with the MVP framework and relevant pathways a strategic imperative, even while MVP reporting remains voluntary. Early exploration and adoption can ease the transition when MVPs become the mandatory way to participate in MIPS.

The development and annual expansion of MVPs, with new pathways being added each year, underscore this shift towards more specialized, condition-focused, or episode-based assessment in value-based care. This move from a broad, “cafeteria-style” measure selection in Traditional MIPS to more curated, clinically coherent measure sets within MVPs is a significant trend.

While MVPs aim to simplify by focusing measure selection, they introduce their own set of administrative considerations. The requirement for separate registration, the option (and eventual mandate for some) of subgroup reporting, and understanding how the foundational layer of PI and population health interacts with MVP-specific measures all add new procedural layers. For example, multispecialty groups will be required to form subgroups to report MVPs starting with the 2026 performance year.⁵ Small practices also have specific considerations, such as needing to start reporting Medicare Part B claims measures for an MVP in January, before the MVP registration period opens, to meet data completeness requirements if that is their chosen collection type within the MVP.⁷¹ Thus, MVPs are not a “set it and forget it” simplification but a new framework with its own rules that require careful review.

Table 5: Overview of Available 2025 MIPS Value Pathways (MVPs)

MVP ID	MVP Name	Most Applicable Medical Specialty(s)	Brief Clinical Theme/Focus
G0057	Adopting Best Practices and Promoting Patient Safety within Emergency Medicine	Emergency Medicine	Care for undifferentiated high-risk conditions in emergency settings. ⁶⁴
M0001	Advancing Cancer Care	Oncology, Hematology	Fundamental treatment and management of cancer care, patient experience, end-of-life care. ⁶⁴
G0055	Advancing Care for Heart Disease	Cardiology, Internal Medicine, Family Medicine	Treatment and management of costly clinical conditions contributing to or resulting from heart disease. ⁶⁴
G0053	Advancing Rheumatology Patient Care	Rheumatology	Fundamental treatment and management of rheumatological conditions. ⁶⁴
M1420	Complete Ophthalmologic Care (New for 2025)	Ophthalmology, Optometry	Meaningful outcomes in cataract, glaucoma, retinal detachment, and broadly applicable ocular care. ¹⁷
G0054	Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes	Neurology, Neurosurgical, Vascular Surgery	Fundamental prevention and treatment for patients at risk for or who have had a stroke. ⁶⁴
M1421	Dermatological Care (New for 2025)	Dermatology, Nonphysician Practitioners, Nurse Practitioner, Physician Assistants	Treatment and management of dermatologic care. ¹⁷
M1366	Focusing on Women’s Health	Gynecology, Obstetrics, Urogynecology, Nonphysician Practitioners, Certified Nurse Mid-Wives, Nurse Practitioners, Physician Assistants	Treatment and management of women’s health. ⁶⁴
M1422	Gastroenterology Care (New for 2025)	Gastroenterology, Nonphysician Practitioners, Nurse Practitioner, Physician Assistants	Treatment and management of the digestive system and the liver. ¹⁷
G0058	Improving Care for Lower Extremity Joint Repair	Orthopedic Surgery	Treatment/management of osteoarthritis & lower extremity surgical repair (fracture, total joint replacement). ⁶⁴
M0002	Optimal Care for Kidney Health	Nephrology, Internal Medicine, Family Medicine	Prevention and management of kidney disease. ⁶⁶
M1423	Optimal Care for Patients with Urologic Conditions (New for 2025)	Urology, Nonphysician Practitioners, Nurse Practitioner, Physician Assistants	Treatment and management of urologic conditions. ¹⁷
G0059	Patient Safety and Support of Positive Experiences with Anesthesia	Anesthesiology, Certified Registered Nurse Anesthetists	Patient safety and positive experiences related to anesthesia care. ⁶⁶
M1368	Prevention and Treatment of Infectious Disorders Including Hepatitis C and HIV	Infectious Disease, Internal Medicine, Family Medicine	Prevention and treatment of infectious diseases like Hepatitis C and HIV. ⁶⁶
M1424	Pulmonary Care (New for 2025)	Pulmonology, Nonphysician Practitioners, Nurse Practitioner, Physician Assistants	Treatment and management of pulmonary conditions. ¹⁷
M0004	Quality Care for Patients with Neurological Conditions (Consolidated MVP for 2025)	Neurology, Neurosurgery, Physical Medicine and Rehabilitation	Comprehensive care for patients with various neurological conditions. ¹⁷
M1367	Quality Care for the Treatment of Ear, Nose, and Throat Disorders	Otolaryngology	Treatment and management of ear, nose, and throat disorders. ⁶⁶
M1369	Quality Care in Mental Health and Substance Use Disorders	Psychiatry, Psychology, Clinical Social Work, Addiction Medicine	Care for mental health and substance use disorders. ⁶⁶
M1370	Rehabilitative Support for Musculoskeletal Care	Physical Therapy, Occupational Therapy, Chiropractic, Physiatry	Rehabilitative care for musculoskeletal conditions. ⁶⁶
M1425	Surgical Care (New for 2025)	General Surgery, Neurosurgery, Cardiothoracic Surgery, Anesthesiologists, CRNAs, NPs, PAs	Focuses on the clinical theme of surgery across various disciplines. ¹⁷
M0005	Value in Primary Care	Preventive Medicine, Internal Medicine, Family Medicine, Geriatrics	Promoting quality care to reduce risk of diseases, disabilities, and death in primary care settings. ⁶⁶

Sources: 6

This table provides a high-level overview. Clinicians should always consult the official QPP website for the most detailed and current information on each MVP’s specific measures, activities, and requirements.

Table 6: Traditional MIPS vs. MIPS Value Pathways (MVPs): A Quick Comparison (2025)

Feature	Traditional MIPS	MIPS Value Pathways (MVPs)
Measure & Activity Selection	Select from the full MIPS inventory of quality measures and improvement activities. ²	Select from a smaller, curated subset of measures and activities specific to the chosen MVP. ⁷
Reporting Burden	Generally considered higher due to broader selection and potentially more measures/activities to track. ⁶⁵	Designed to be lower by focusing on a relevant subset. ⁷
Specialty/Condition Focus	Less inherently focused; relies on clinician to select relevant items. ⁶⁵	Highly focused on a specific specialty, clinical condition, or episode of care. ⁷
Number of Quality Measures	Typically report at least 6 measures. ⁵	Typically report 4 pre-selected measures (including 1 outcome/high-priority). ⁵
Number of Improvement Activities	Report 1 (for small/special status) or 2 activities (for others) for 2025. ¹¹	Report 1 activity (for 2025) from the MVP’s list. ¹¹
Cost Measures	Scored on all applicable cost measures calculated by CMS. ²	Scored on specific cost measures included in the MVP, calculated by CMS. ⁶³
Population Health Measures	Applies if criteria met (e.g., HWR for groups). ⁵	Foundational layer; CMS calculates and assigns highest scoring applicable measure. ⁶³
Registration Required	No specific registration for Traditional MIPS participation itself (beyond general Medicare enrollment).	Yes, specific MVP registration required during a defined window (e.g., Apr 1 – Dec 1, 2025). ³⁵
Subgroup Reporting	Not an option for Traditional MIPS. ²¹	Available for MVPs; will be required for multispecialty groups starting 2026. ⁵
Future Outlook	Expected to be sunset by CMS in favor of MVPs. ³	Intended to be the primary MIPS reporting framework in the future. ³

The clinical coherence within an MVP—where Quality, Cost, and Improvement Activities are all related to a specific theme—can foster more meaningful quality improvement. Interventions in one area are more likely to have a positive, synergistic impact on other components within the same MVP. This could make it easier for clinics to demonstrate value and achieve higher overall scores, as their focused improvement efforts can have a more concentrated positive effect.

Spotlight on Family Medicine/Primary Care MIPS

Family medicine and primary care practices are at the forefront of patient care and often manage a wide range of conditions. MIPS offers pathways and measures relevant to this broad scope.

Relevant MIPS Value Pathways (MVPs) for 2025:
Value in Primary Care MVP (ID: M0005): This MVP is highly relevant, focusing on promoting quality care for patients to reduce the risk of diseases, disabilities, and death.⁶⁸
Example Quality Measures from M0005 ⁶⁹:

Quality ID: 001 – Diabetes: Glycemic Status Assessment Greater Than 9%
Quality ID: 047 – Advance Care Plan
Quality ID: 236 – Controlling High Blood Pressure

Example Improvement Activities from M0005 ⁶⁹:

Activity ID: IA_AHE_3 – Promote Use of Patient-Reported Outcome Tools
Activity ID: IA_BE_6 – Regularly Assess Patient Experience of Care and Follow Up on Findings

Other MVPs like Advancing Care for Heart Disease (ID: G0055) ⁶⁴ or Prevention and Treatment of Infectious Disorders Including Hepatitis C and HIV (ID: M1368) ⁶⁶ might also contain relevant measures depending on the practice’s patient population and focus.
Common Traditional MIPS Quality Measures for Family Medicine/Primary Care (if not using an MVP):
Practices choosing Traditional MIPS have a broader selection. Commonly relevant measures include:

Screening for Depression and Follow-Up Plan (Quality ID: 134) ⁵
Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention (Quality ID: 226) ⁷⁷
Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan (Quality ID: 128) ⁷⁴
Statin Therapy for the Prevention and Treatment of Cardiovascular Disease (Quality ID: 438) ⁷⁹
Adult Immunization Status (Quality ID: 493) ⁶⁹
Documentation of Current Medications in the Medical Record (Quality ID: 130) ⁷⁷
Common Traditional MIPS Improvement Activities for Family Medicine/Primary Care:
Many activities in the CMS inventory can fit well within a primary care setting:

Use of telehealth services that expand practice access (Activity ID: IA_EPA_2) ³²
Collection and use of patient experience and satisfaction data on access (Activity ID: IA_EPA_3) ³²
Engagement of patients, family, and caregivers in developing a plan of care (Activity ID: IA_BE_15) ³⁴
Use of evidence-based decision aids to support shared decision-making (Activity ID: IA_BE_12) ³⁴
Implementation of practices/processes for developing regular individual care plans (Activity ID: IA_CC_9) ³⁴
Use panel support tools (e.g., registry functionality) to identify services due (part of IA_PM_13) ³⁴

| Snapshot: Key MIPS Considerations for Family Medicine/Primary Care (2025) | |

| :— | :— |

| Relevant MVP(s) & ID(s): | Value in Primary Care (M0005) 68 |

| Example Quality Measures (M0005): | QID 001 (Diabetes: Glycemic Status >9%), QID 047 (Advance Care Plan), QID 236 (Controlling High Blood Pressure) 69 |

| Example Improvement Activities (M0005): | IA_AHE_3 (Promote Use of PRO Tools), IA_BE_6 (Assess Patient Experience) 69 |

| Key Reporting Tip/Resource: | For small practices, explore claims-based Quality reporting. Leverage the “2025 MIPS Quick Start Guide for Small Practices”.13 Focus on comprehensive, preventative care measures. |

Spotlight on Cardiology MIPS

Cardiology practices deal with complex patient conditions where quality and cost are intensely scrutinized. MIPS provides specialized pathways and measures for this field.

Relevant MIPS Value Pathways (MVPs) for 2025:
Advancing Care for Heart Disease MVP (ID: G0055): This is the primary MVP for cardiology, focusing on the fundamental treatment and management of costly clinical conditions that contribute to, or may result from, heart disease.⁶
Example Quality Measures from G0055 ⁷¹:

Quality ID: 005 – Heart Failure (HF): Angiotensin-Converting Enzyme (ACE) Inhibitor or Angiotensin Receptor Blocker (ARB) or Angiotensin Receptor-Neprilysin Inhibitor (ARNI) Therapy for Left Ventricular Systolic Dysfunction (LVSD)
Quality ID: 006 – Coronary Artery Disease (CAD): Antiplatelet Therapy
Quality ID: 047 – Advance Care Plan

Example Improvement Activities from G0055 (selected from the MVP’s specific list on QPP website, cross-referencing general IA lists ¹⁰):

IA_BE_6: Regularly assess patient experience of care and follow up on findings
IA_CC_2: Implementation of improvements that contribute to more timely communication of test results

Common Traditional MIPS Quality Measures for Cardiology (if not using an MVP):
Cardiology has a robust set of specialty measures available under Traditional MIPS:

Coronary Artery Disease (CAD): Beta-Blocker Therapy – Prior Myocardial Infarction (MI) or Left Ventricular Systolic Dysfunction (LVEF ≤ 40%) (Quality ID: 007) ⁷¹
Heart Failure (HF): Beta-Blocker Therapy for Left Ventricular Systolic Dysfunction (LVSD) (Quality ID: 008) ⁷¹
Coronary Artery Disease (CAD): Angiotensin-Converting Enzyme (ACE) Inhibitor or Angiotensin Receptor Blocker (ARB) Therapy – Diabetes or Left Ventricular Systolic Dysfunction (LVEF ≤ 40%) (Quality ID: 118) ⁷¹
Statin Therapy for the Prevention and Treatment of Cardiovascular Disease (Quality ID: 438) ⁷⁹
The American College of Cardiology’s (ACC) NCDR registries also play a role in providing quality data and measures.⁸²
Common Traditional MIPS Improvement Activities for Cardiology:

A new IA for 2025 is particularly relevant: “Save a Million Hearts: Standardization of Approach to Screening and Treatment for Cardiovascular Disease Risk” (Activity ID: IA_PM_25).¹¹
Participation in QCDR clinical data registries for performance feedback (related to IA_PSPA_7).⁷⁶
Anticoagulant Management Improvements (Activity ID: IA_PM_2).³⁴

| Snapshot: Key MIPS Considerations for Cardiology (2025) | |

| :— | :— |

| Relevant MVP(s) & ID(s): | Advancing Care for Heart Disease (G0055) 64 |

| Example Quality Measures (G0055): | QID 005 (HF: ACEI/ARB/ARNI), QID 006 (CAD: Antiplatelet Therapy), QID 047 (Advance Care Plan) 71 |

| Example Improvement Activities (G0055): | IA_BE_6 (Assess Patient Experience), IA_CC_2 (Timely Communication of Test Results) (from G0055 list) |

| Key Reporting Tip/Resource: | Leverage data from ACC NCDR registries if participating.82 Consider the new “Save a Million Hearts” IA.11 Focus on outcome measures related to cardiovascular care. The MIPS Cost category is significant. |

Spotlight on Orthopedics MIPS

Orthopedic practices often focus on procedural care, musculoskeletal conditions, and rehabilitation. MIPS offers specific MVPs and measures relevant to this specialty.

Relevant MIPS Value Pathways (MVPs) for 2025:
Improving Care for Lower Extremity Joint Repair MVP (ID: G0058): This MVP is tailored for orthopedic surgery, focusing on the treatment and management of patients with osteoarthritis and those undergoing lower extremity surgical repair, such as fractures and total joint replacements.⁶⁴
Example Quality Measures from G0058 ⁷⁴:

Quality ID: 024 – Communication with the Physician or Other Clinician Managing On-Going Care Post-Fracture for Men and Women Aged 50 Years and Older
Quality ID: 128 – Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan
Quality ID: 350 – Total Knee or Hip Replacement: Shared Decision-Making: Trial of Conservative (Non-surgical) Therapy

Example Improvement Activities from G0058 ⁷⁴:

Activity ID: IA_AHE_3 – Promote Use of Patient-Reported Outcome Tools
Activity ID: IA_BE_6 – Regularly Assess Patient Experience of Care and Follow Up on Findings

Rehabilitative Support for Musculoskeletal Care MVP (ID: M1370): This MVP may be relevant for orthopedic practices with a strong focus on rehabilitation services, or for associated PT/OT providers.⁶⁶
Surgical Care MVP (ID: M1425): As a broader surgery-focused MVP, this might also encompass certain orthopedic procedures and could be an option depending on the practice’s case mix.⁶⁶
Common Traditional MIPS Quality Measures for Orthopedics (if not using an MVP):
Orthopedic surgeons can select from various measures, including those from the American Academy of Orthopaedic Surgeons (AAOS) QCDR.41

Communication with the Physician or Other Clinician Managing On-Going Care Post-Fracture for Men and Women Aged 50 Years and Older (Quality ID: 024) ⁷⁷
Advance Care Plan (Quality ID: 047) ⁷⁷ (often applicable for surgical patients)
Documentation of Current Medications in the Medical Record (Quality ID: 130) ⁷⁷
Falls: Plan of Care (Quality ID: 155) ⁷⁷ (especially for geriatric orthopedics)
Risk-standardized Complication Rate (RSCR) Following Elective Primary Total Hip Arthroplasty (THA) and/or Total Knee Arthroplasty (TKA) for MIPS (Administrative Claims Measure, if applicable).⁴¹
Common Traditional MIPS Improvement Activities for Orthopedics:

Promote Use of Patient-Reported Outcome Tools (e.g., for functional status post-surgery) (Activity ID: IA_AHE_3).⁷⁴
Participation in a QCDR that promotes use of patient engagement tools (related to IA_BE_4 or IA_PSPA_7).
Use of evidence-based decision aids to support shared decision-making for elective procedures (Activity ID: IA_BE_12).⁶⁹

| Snapshot: Key MIPS Considerations for Orthopedics (2025) | |

| :— | :— |

| Relevant MVP(s) & ID(s): | Improving Care for Lower Extremity Joint Repair (G0058) 74, Rehabilitative Support for Musculoskeletal Care (M1370) 66, Surgical Care (M1425) 76 |

| Example Quality Measures (G0058): | QID 024 (Post-Fracture Communication), QID 128 (BMI Screening), QID 350 (THA/TKA: Shared Decision-Making) 74 |

| Example Improvement Activities (G0058): | IA_AHE_3 (Promote Use of PRO Tools), IA_BE_6 (Assess Patient Experience) 74 |

| Key Reporting Tip/Resource: | Utilize AAOS QCDR measures if applicable.41 Patient-reported outcomes are increasingly important. Focus on measures related to surgical outcomes, complications, and functional improvement. The MIPS Cost category for joint replacements is key. |

Spotlight on Ophthalmology MIPS

Ophthalmology practices have a unique set of procedures and conditions they manage, and MIPS is evolving to better reflect this specialty, notably with a new MVP for 2025.

Relevant MIPS Value Pathways (MVPs) for 2025:
Complete Ophthalmologic Care MVP (ID: M1420): This is a significant new MVP for 2025, designed specifically for ophthalmology and optometry. It aims to assess meaningful outcomes in areas like cataract surgery, glaucoma management, and retinal detachment care.¹⁷
Example Quality Measures from M1420 ⁷⁰:

Quality ID: 012 – Primary Open-Angle Glaucoma (POAG): Optic Nerve Evaluation
Quality ID: 191 – Cataracts: 20/40 or Better Visual Acuity within 90 Days Following Cataract Surgery
Quality ID: IRIS2 – Glaucoma – Intraocular Pressure Reduction (This is an example of a QCDR measure that can be part of an MVP)

Example Improvement Activities from M1420 (selected from the MVP’s specific list on QPP website, cross-referencing general IA lists ¹⁰):

IA_BE_4: Engagement of patients through implementation of improvements in patient portal
IA_PSPA_1: Participation in formal private payer data exchange initiatives that improve patient safety

Common Traditional MIPS Quality Measures for Ophthalmology (if not using an MVP):
The American Academy of Ophthalmology’s (AAO) IRIS® Registry (Intelligent Research in Sight) is a major QCDR for ophthalmology and offers many specialty-specific measures.70

Primary Open-Angle Glaucoma (POAG): Optic Nerve Evaluation (Quality ID: 012) ⁷⁰
Diabetes: Eye Exam (Quality ID: 117) ⁷⁰
Primary Open-Angle Glaucoma (POAG): Reduction of Intraocular Pressure (IOP) by 20% OR Documentation of a Plan of Care (Quality ID: 141) ⁷⁰
Cataracts: 20/40 or Better Visual Acuity within 90 Days Following Cataract Surgery (Quality ID: 191) ⁷⁰
Many IRIS® Registry QCDR measures (e.g., IRIS13 – Diabetic Macular Edema – Loss of Visual Acuity, IRIS54 – Complications After Cataract Surgery).⁷⁰
Common Traditional MIPS Improvement Activities for Ophthalmology:
Ophthalmology practices, particularly small ones, benefit from the general IA flexibilities (attesting to one activity).36 Activities could include:

Use of evidence-based decision aids to support shared decision-making (e.g., for cataract surgery options). (Activity ID: IA_BE_12) ⁶⁹
Regularly assess patient experience of care and follow up on findings (Activity ID: IA_BE_6).⁶⁹

| Snapshot: Key MIPS Considerations for Ophthalmology (2025) | |

| :— | :— |

| Relevant MVP(s) & ID(s): | Complete Ophthalmologic Care (M1420) (New for 2025) 36 |

| Example Quality Measures (M1420): | QID 012 (POAG: Optic Nerve Eval), QID 191 (Cataracts: 20/40 VA), IRIS2 (Glaucoma: IOP Reduction) 70 |

| Example Improvement Activities (M1420): | IA_BE_4 (Patient Portal Engagement), IA_PSPA_1 (Payer Data Exchange for Safety) (from M1420 list) |

| Key Reporting Tip/Resource: | The new Complete Ophthalmologic Care MVP (M1420) is a game-changer; explore it thoroughly.36 The IRIS® Registry (AAO QCDR) is a critical resource for Quality measures.70 Small practices should note PI automatic reweighting for the MVP, unless they opt to report.36 |

Spotlight on General Surgery MIPS

General surgeons manage a diverse range of conditions and procedures, and their MIPS reporting needs to reflect this. The introduction of a Surgical Care MVP is a key development.

Relevant MIPS Value Pathways (MVPs) for 2025:
Surgical Care MVP (ID: M1425): This new MVP for 2025 is broadly applicable to various surgical specialties, including general surgery. It focuses on the overarching clinical theme of surgery.¹⁷
Example Quality Measures from M1425 ⁷⁶:

Quality ID: 047 – Advance Care Plan
Quality ID: 355 – Unplanned Reoperation within the 30 Day Postoperative Period
Quality ID: 357 – Surgical Site Infection (SSI)

Example Improvement Activities from M1425 ⁷⁶:

Activity ID: IA_MVP – Practice-Wide Quality Improvement in MIPS Value Pathways
Activity ID: IA_PSPA_7 – Use of QCDR data for ongoing practice assessment and improvements

Common Traditional MIPS Quality Measures for General Surgery (if not using an MVP):
CMS provides a General Surgery specialty measure set that surgeons can use as a guide.28

Advance Care Plan (Quality ID: 047) ²⁸
Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention (Quality ID: 226) ²⁸ (important for surgical risk)
Anastomotic Leak Intervention (Quality ID: 354) ⁷⁶
Unplanned Reoperation within the 30 Day Postoperative Period (Quality ID: 355) ⁷⁶
Surgical Site Infection (SSI) (Quality ID: 357) ⁷⁶
Patient-Centered Surgical Risk Assessment and Communication (Quality ID: 358) ⁷⁶
Common Traditional MIPS Improvement Activities for General Surgery:

The new “Practice-Wide Quality Improvement in MIPS Value Pathways” activity (IA_MVP) is an option if reporting an MVP, or similar practice-wide QI initiatives.⁷⁶
Participation in a QCDR and using that data for improvement (Activity ID: IA_PSPA_7).⁷⁶
Implementation of enhanced recovery after surgery (ERAS) protocols (could fall under various IA subcategories like Patient Safety or Care Coordination).

| Snapshot: Key MIPS Considerations for General Surgery (2025) | |

| :— | :— |

| Relevant MVP(s) & ID(s): | Surgical Care (M1425) (New for 2025) 33 |

| Example Quality Measures (M1425): | QID 047 (Advance Care Plan), QID 355 (Unplanned Reoperation), QID 357 (SSI) 76 |

| Example Improvement Activities (M1425): | IA_MVP (Practice-Wide QI in MVPs), IA_PSPA_7 (Use of QCDR Data) 76 |

| Key Reporting Tip/Resource: | The new Surgical Care MVP (M1425) is a primary option to explore.33 Focus on measures related to surgical outcomes, patient safety (e.g., SSI, reoperations), and pre/post-operative care. The American College of Surgeons (ACS) provides resources and may have relevant QCDRs. |

For all specialties, it is paramount to consult the official CMS QPP website (qpp.cms.gov) for the most current, detailed, and authoritative information on MVP requirements, measure specifications, and activity descriptions for the specific performance year. Professional society resources (like those from the ACC, AAOS, AAO, ACS, AAFP) are also invaluable for specialty-specific guidance.

MIPS Logistics: Participation Rules, Submission Dates, and Deadlines You Absolutely Can’t Miss!

Successfully navigating the Merit-based Incentive Payment System (MIPS) requires more than just understanding the performance categories; it demands a firm grasp of the logistical rules of engagement. This includes knowing how your practice can participate, being acutely aware of the various performance periods, and, most critically, adhering to all submission dates and deadlines. Missing a deadline in the MIPS program can have significant financial consequences.

Navigating MIPS Participation: Individual, Group, Virtual Group, and Subgroup Options

CMS offers several ways for eligible clinicians and practices to participate in MIPS, allowing for some flexibility based on practice size and structure.²¹ The choice of participation option can impact how data is collected, aggregated, and how scores are ultimately applied.

Individual Participation:
This is the most straightforward option. A single clinician, identified by their unique Taxpayer Identification Number (TIN) and National Provider Identifier (NPI) combination, collects and submits their own individual performance data for the MIPS categories.2 The clinician will then receive a payment adjustment based on their individual final MIPS score, unless they are also part of a group or APM Entity that achieves a higher score, in which case CMS typically applies the more favorable outcome.2
Group Participation:
A practice, identified by its TIN, can choose to participate as a group. In this scenario, the practice submits aggregated performance data on behalf of all the clinicians who bill under that TIN.2 A key aspect of group participation is that any MIPS eligible clinicians within the practice who might not be eligible to participate as individuals (e.g., they fall below the low-volume threshold individually but the group as a whole exceeds it) will be included in the group’s MIPS reporting and will receive the group’s payment adjustment.2 Generally, all clinicians in the group, whether eligible individually or only as part of the group, will receive a payment adjustment based on the group’s single final MIPS score.2 If a practice chooses group reporting, it must typically report as a group across all the MIPS performance categories it reports on.5
Virtual Group Participation:
This option allows smaller practices to band together. A virtual group is a combination of two or more TINs that formally elect to form a virtual group for a specific performance year.21 The composition of a virtual group can be:

Solo practitioners who are MIPS eligible.
Groups consisting of 10 or fewer clinicians (where the group includes at least one MIPS eligible clinician).
A combination of both of the above.²⁹ Participation as a virtual group requires an election submitted to and approved by CMS. This election period typically runs from October 1 to December 31 of the calendar year prior to the performance year (e.g., elections for the 2025 performance year occur October 1 – December 31, 2024).²⁹ For the 2025 performance year, virtual groups can only report using the Traditional MIPS framework; they cannot report via MIPS Value Pathways (MVPs) or the APM Performance Pathway (APP).²⁹ When a group (TIN) joins a virtual group, all clinicians within that group become part of the virtual group. Performance is assessed and scored at the virtual group level across all four MIPS categories. All MIPS eligible clinicians within the virtual group will receive a payment adjustment based on the virtual group’s final score.²⁹ An important note for virtual groups: if the total number of clinicians in the entire virtual group is 15 or fewer, the virtual group qualifies for small practice status and can use Medicare Part B claims for reporting Quality measures.²⁹

Subgroup Participation (New for 2023, MVP-Specific):
This is a newer participation option available only for reporting MIPS Value Pathways (MVPs).21 A subgroup is defined as a subset of clinicians within a larger group (identified by a single TIN). A subgroup must consist of at least two clinicians, and at least one of them must be individually MIPS eligible.21 Subgroup participation requires advance registration with CMS as part of the MVP registration process.21 Looking ahead, CMS has indicated that beginning with the 2026 performance year, multispecialty groups will be required to form subgroups if they wish to report MVPs.5 Subgroups cannot report Traditional MIPS or the APP.21
APM Entity Participation:
Clinicians who are MIPS eligible (either as individuals or as part of a group) and are also participants in a MIPS APM (Alternative Payment Model) can participate in MIPS as an APM Entity.21 An APM Entity can report Traditional MIPS, the APM Performance Pathway (APP), or an MVP.21

The choice of participation level is significant because it dictates how data is aggregated and how performance is assessed. The complexity arises when clinicians might be part of multiple participation structures (e.g., an individual who is also part of a group that reports, or a group that is part of a virtual group). CMS has a hierarchy for determining the final score and payment adjustment in such cases. Generally, if a clinician (identified by a unique TIN/NPI) has more than one MIPS final score, CMS will assign the highest available score and its associated payment adjustment.² However, if a clinician participates as part of a virtual group, the virtual group’s final score and payment adjustment will typically apply, even if other scores from individual or group participation exist.²¹ This complexity underscores the importance of understanding all affiliations and how they might impact MIPS outcomes.

Mark Your Calendars! Key MIPS Submission Dates and Deadlines

Adherence to deadlines is absolutely critical in MIPS. Missing a key date can mean the difference between a positive payment adjustment and a significant penalty. While some dates can occasionally be adjusted by CMS (as seen with the 2024 data submission deadline extension due to the Change Healthcare cyberattack and IV fluid shortages ²²), practices should always plan based on the standard, anticipated timelines.

Performance Period: This is the timeframe during which clinicians must collect data and perform activities for MIPS.

General Performance Period: For any given MIPS performance year, the overall period is January 1 through December 31.²
Quality Category: Requires data collection for the full 12-month calendar year (January 1 – December 31).⁵
Cost Category: Also assessed over the full 12-month calendar year using administrative claims data.¹³
Improvement Activities Category: Requires performance of chosen activities for a minimum continuous 90-day period during the calendar year, unless an activity’s description specifies otherwise.⁴ The last possible day to start a 90-day IA period for the 2025 performance year is October 3, 2025.¹⁰
Promoting Interoperability Category: For the 2024 and 2025 performance years, this requires data collection for a minimum continuous 180-day period within the calendar year.³ The last possible day to start a 180-day PI performance period for 2025 is July 5, 2025.⁴³
Data Submission Window: This is the period after the performance year ends when clinicians and groups submit their collected data to CMS.

Typically, the submission window opens on January 2 and closes on March 31 of the year immediately following the performance year.¹¹ For example, for the 2025 performance year, data submission would occur between January 2, 2026, and March 31, 2026.
Important Note: For the 2024 performance year, due to the Change Healthcare cyberattack and national IV fluid shortages, CMS extended the data submission deadline to April 14, 2025, at 8 p.m. ET.²² While such extensions are rare and due to extraordinary circumstances, it highlights the need to stay updated via the QPP website.
Opt-In Election Deadline (for Opt-In Eligible Clinicians/Groups):
Clinicians or groups who are eligible to opt-in to MIPS and wish to do so must typically complete their opt-in election by the data submission deadline, which is usually March 31 of the year following the performance year.²² For the 2024 performance year, with the extended submission, this was also extended to April 14, 2025.²²
Virtual Group Election Period:
Practices wishing to form or join a virtual group for an upcoming performance year must make their election to CMS during a specific window in the year prior to that performance year. For the 2025 performance year, this election period is October 1, 2024, through December 31, 2024, at 11:59 p.m. ET.²⁹
MIPS Value Pathway (MVP) Registration:

Clinicians, groups, or subgroups wishing to report an MVP for the 2025 performance year must register with CMS between April 1, 2025, and December 1, 2025, at 8 p.m. ET.³⁵
If reporting the CAHPS for MIPS Survey as part of an MVP (or Traditional MIPS), separate registration for the survey is required, typically between April 1 and June 30 of the performance year.³⁰ If the CAHPS for MIPS Survey is associated with an MVP, the MVP registration must also be completed by June 30 to align.⁴³
Exception Application Windows (Extreme and Uncontrollable Circumstances – EUC; Promoting Interoperability Hardship):

CMS provides application windows for clinicians or groups facing circumstances that prevent them from meeting MIPS requirements.
For the 2025 performance year, the EUC Exception and PI Hardship Exception application windows are generally expected to be open from Spring/Summer 2025 through December 31, 2025, by 8 p.m. ET.⁴³
It’s crucial to monitor the QPP website for exact opening and closing dates, as these can be subject to specific announcements (e.g., the 2024 EUC application was reopened until April 14, 2025, for issues related to the IV fluid shortage ²²).

The varied timing for different performance categories (90 days for IA, 180 days for PI, 12 months for Quality/Cost) and the distinct deadlines for elections, registrations, and submissions mean that MIPS requires year-round attention and careful calendar management. Practices cannot afford to wait until the end of the performance year to start thinking about these critical dates.

Understanding MIPS Performance Periods and Payment Year Adjustments

A fundamental concept in MIPS is the lag between performance and payment adjustment. The data you collect and submit for a given performance year does not affect your Medicare payments immediately. Instead, MIPS payment adjustments are typically applied two calendar years after the performance year concludes.²

Example:

Performance Year: January 1, 2025 – December 31, 2025
Data Submission Period: January 2, 2026 – March 31, 2026 (approximately)
Performance Feedback: Typically available Summer/Fall 2026
Payment Adjustment Year: January 1, 2027 – December 31, 2027

This “Year 1 performance impacts Year 3 payments” structure means that the efforts (or lack thereof) made today have financial consequences down the line. It also means that when clinics receive their performance feedback and information about their upcoming payment adjustment, they are already well into the next MIPS performance year.

Data Submission Methods: How to Get Your Information to CMS

Once data is collected, it needs to be submitted to CMS through the QPP website (qpp.cms.gov). The primary methods include:

Sign In and Attest: Manually entering data for PI and IA categories.⁹
Sign In and Upload: Uploading files (e.g., QRDA III for Quality eCQMs, CSV files) for Quality, PI, or IA data.⁹
Direct Submission via API: Through a third-party intermediary like an EHR vendor, QCDR, or Qualified Registry.⁹
Medicare Part B Claims: For Quality measures, only for small practices or qualifying virtual groups.¹⁴ Data is submitted throughout the year as claims are processed.

Practices can often use a combination of these methods depending on the categories they are reporting and the tools they have available.

MIPS Performance Feedback and the Targeted Review Process

After the data submission window closes, CMS processes the data and provides MIPS eligible clinicians and groups with performance feedback. This feedback typically includes:

Your final MIPS score.
Your performance in each of the reported categories.
Information about your upcoming payment adjustment.¹³

This feedback is usually released in the summer or fall of the year following the performance year (e.g., Summer/Fall 2026 for the 2025 performance year).¹³

If a clinician or group believes there was an error in the calculation of their MIPS final score or payment adjustment factor, they can request a Targeted Review.¹³ The Targeted Review window typically opens shortly after the performance feedback and payment adjustment information is released and remains open for a limited period (often around 30-60 days).¹³ It is crucial to carefully review your performance feedback as soon as it becomes available and to submit a Targeted Review request promptly if you identify any discrepancies, as CMS notes that Targeted Review decisions are final.¹⁵ This feedback loop—receiving scores, understanding the payment impact, and having an opportunity for review—is an essential part of the MIPS cycle and provides valuable information for improving performance in future years.

Table 7: MIPS 2025 Key Dates & Deadlines Snapshot (Illustrative & Subject to CMS Finalization)

Date/Period	Event	Notes
Oct 1, 2024 – Dec 31, 2024	Virtual Group Election Period for 2025 Performance Year ²⁹	For practices wishing to form/join a virtual group for PY2025.
Dec 2024 (approx.)	Initial 2025 MIPS Eligibility Available ¹³	Check QPP Participation Status Tool.
Jan 1, 2025 – Dec 31, 2025	2025 MIPS Performance Period ¹³	Data collection for Quality, Cost, PI, IA.
Apr 1, 2025 – Jun 30, 2025	CAHPS for MIPS Survey Registration ³⁰	If reporting this Quality measure (Traditional or MVP).
Apr 1, 2025 – Dec 1, 2025	MIPS Value Pathway (MVP) Registration ³⁵	For reporting an MVP for PY2025.
Spring/Summer 2025 – Dec 31, 2025 (approx.)	Exception Applications Window (EUC, PI Hardship) ⁴³	Monitor QPP website for exact dates.
July 5, 2025	Last Day to Start 180-day PI Performance Period ⁴³	For PY2025 Promoting Interoperability.
Oct 3, 2025	Last Day to Start 90-day IA Performance Period ¹⁰	For PY2025 Improvement Activities.
Dec 2025 (approx.)	Final 2025 MIPS Eligibility Available ¹³	Verify status on QPP Participation Status Tool.
Jan 2, 2026 – Mar 31, 2026 (approx.)	Data Submission Window for 2025 Performance Year ¹¹	Submit PY2025 data to CMS. Opt-in election also due.
Summer/Fall 2026 (approx.)	2025 MIPS Final Scores & Payment Adjustment Info Released ¹³	Performance feedback available.
Following Score Release	Targeted Review Window Opens ¹³	Typically 30-60 days to request review of PY2025 scores.
Jan 1, 2027 – Dec 31, 2027	Payment Adjustments for 2025 Performance Year Applied ¹³	Medicare Part B payments adjusted based on PY2025 MIPS score.

This table is illustrative. Always refer to the official CMS QPP website for the most current and definitive dates and deadlines for any given MIPS performance and payment year.

The MIPS Bottom Line: Financial Impacts & Real-World Examples

While the Merit-based Incentive Payment System (MIPS) is designed to promote quality care, efficiency, and interoperability, its most immediate and tangible impact on medical clinics often comes down to dollars and cents. Understanding how MIPS scores translate into payment adjustments, the concept of budget neutrality, and the potential financial swings is crucial for any practice participating in the program.

How MIPS Scores Translate to Dollars: The Payment Adjustment Formula

As previously discussed, a clinician’s or group’s performance across the four MIPS categories (Quality, Cost, Promoting Interoperability, and Improvement Activities) culminates in a final MIPS score ranging from 0 to 100 points.² This score is then compared to a performance threshold set by CMS for that specific performance year.

For the 2025 performance year (affecting 2027 payments), the performance threshold is 75 points.¹¹
Clinicians or groups scoring below the performance threshold (i.e., 0.00 – 74.99 points for PY2025) will receive a negative payment adjustment. The maximum negative adjustment for recent years, including the 2025 payment year (based on 2023 performance), is -9%.¹⁵ The penalty is applied on a linear sliding scale, meaning the further below the threshold a score is, the larger the penalty, up to the maximum.¹⁵
Clinicians or groups scoring exactly at the performance threshold (e.g., 75.00 points for PY2025) will receive a neutral payment adjustment (0%).¹³
Clinicians or groups scoring above the performance threshold (e.g., 75.01 – 100.00 points for PY2025) are eligible for a positive payment adjustment.¹³ The magnitude of this positive adjustment is also on a sliding scale (higher scores get a larger positive adjustment factor) but is subject to a scaling factor due to budget neutrality, which is a critical concept discussed next.

It’s worth noting that for performance years up to 2022 (affecting payments through 2024), there was an additional positive payment adjustment for “exceptional performance” for those scoring at or above a higher threshold (e.g., 89 points for PY2022).¹⁵ However, the 2022 performance year / 2024 payment year was the last year for this specific additional MIPS payment adjustment for exceptional performance.¹⁵ Future positive adjustments are based on the standard positive payment adjustment mechanism, subject to budget neutrality.

The certainty of the penalty for underperformance versus the variability of the bonus for high performance is a key takeaway. While a -9% penalty is a fixed maximum risk for those required to participate and who score very poorly or not at all, the maximum positive incentive is not guaranteed at +9% due to how MIPS is funded.

Budget Neutrality and the Scaling Factor: Why Bonuses Aren’t Always 1:1

A crucial aspect of the MIPS payment adjustment system is budget neutrality. This means that, by law, the MIPS program itself cannot increase or decrease overall Medicare spending. The total amount of money available for positive payment adjustments (bonuses) is funded by the total amount of money collected from negative payment adjustments (penalties).¹⁵

Because of this budget neutrality requirement, CMS applies a scaling factor to the positive payment adjustments.¹⁵

If the total amount of penalties collected is less than what would be needed to fund a full, symmetric positive adjustment (e.g., if many clinicians score well and avoid penalties), the scaling factor will be less than 1. This means the positive adjustments are reduced proportionally to ensure the program remains budget neutral.⁸⁸
Historically, in the early years of MIPS, a large majority of eligible clinicians successfully avoided penalties, and many achieved scores qualifying for positive adjustments. This resulted in relatively modest positive payment adjustments, even for high performers, because the pool of penalty money was small.⁸⁹ For example, maximum positive adjustments were around +1.79% to +2.34% for performance years 2019-2021.⁸⁹

However, the situation can change:

For the 2022 performance year (affecting 2024 payments), the performance threshold was raised significantly to 75 points (up from 60 in 2021).⁸⁹ This led to more clinicians receiving penalties, increasing the funding pool. Consequently, the maximum positive payment adjustment for a perfect score in PY2022 reached +8.25% for 2024 payments, far higher than in previous years.⁸⁹
For the 2023 performance year (affecting 2025 payments), the maximum positive payment adjustment for top performers is +2.15%.⁸⁸ This lower figure was influenced by factors including the Change Healthcare cyberattack, which led to many clinicians being approved for Extreme and Uncontrollable Circumstances (EUC) exemptions, resulting in neutral adjustments and thus fewer penalties to fund bonuses.⁸⁸

This variability demonstrates that while the potential for a positive adjustment up to +9% exists, the actual positive adjustment received by high-performing clinicians is highly dependent on the overall distribution of scores across all MIPS participants nationwide and the total amount of penalties collected in a given year. The penalty side, however, is more fixed: failure to meet the threshold will result in a negative adjustment up to -9%.

Example Clinic Scenarios: Dollars Gained, Dollars Lost

To illustrate the potential financial impact of MIPS, let’s consider a few hypothetical scenarios. These are simplified and do not account for all variables, but they highlight the range of outcomes. Assume a maximum +/- 9% adjustment for these examples.

Scenario 1: “The Ostrich” – Small Primary Care Practice (Non-Participation)

Annual Medicare Part B Revenue: $200,000
MIPS Status: Meets all three low-volume threshold criteria and is required to participate.
Action Taken: Ignores MIPS, submits no data.
Resulting MIPS Score: 0 points.
Payment Adjustment: -9% penalty.
Financial Impact: $200,000 * -0.09 = -$18,000 loss in Medicare revenue for the payment year.
Scenario 2: “The Struggler” – Medium-Sized Specialty Clinic

Annual Medicare Part B Revenue: $1,000,000
MIPS Status: Required to participate.
Action Taken: Attempts to participate but struggles with data collection and reporting.
Resulting MIPS Score: 60 points (below the 75-point threshold for PY2025).
Payment Adjustment: A negative adjustment, for instance, -4% (on the sliding scale).
Financial Impact: $1,000,000 * -0.04 = -$40,000 loss in Medicare revenue.
Scenario 3: “The Achiever” – Large Multi-Specialty Group

Annual Medicare Part B Revenue: $5,000,000
MIPS Status: Required to participate.
Action Taken: Invests in MIPS compliance, focuses on relevant quality measures and improvement activities, uses CEHRT effectively.
Resulting MIPS Score: 90 points (above the 75-point threshold).
Payment Adjustment: A positive adjustment. Let’s assume for this year, due to budget neutrality and scaling, a 90-point score yields a +3.5% adjustment.
Financial Impact: $5,000,000 * +0.035 = +$175,000 gain in Medicare revenue.

More concrete examples can be drawn from analyses:

An orthopedic provider with $900,000 in annual revenue, where 30% ($270,000) comes from Medicare, faces a potential loss of $24,300 per provider if they incur the maximum 9% penalty. For a practice with 20 such providers, this could amount to nearly $500,000 in lost annual revenue.²³
A practice with $10 million in total annual revenue, with 30% ($3 million) from Medicare, could lose $270,000 annually if they do nothing and receive the maximum 9% penalty.²³

These examples starkly illustrate that the financial stakes in MIPS are considerable. The cost of compliance, which one study found to be around $12,800 annually and requiring over 200 hours per physician ²⁴, must also be factored in. For some practices, particularly smaller ones, if the potential positive adjustment is modest due to budget neutrality, the primary financial driver for MIPS participation might become penalty avoidance rather than chasing a small bonus. However, a significant penalty can dwarf these compliance costs.

The Bigger Picture: MIPS Impact on Overall Clinic Revenue and Stability

The impact of MIPS extends beyond the direct payment adjustments.

Cost of Compliance: As mentioned, there are internal and external costs associated with data collection, reporting, using registries or consultants, and staff time dedicated to MIPS.²³ These costs need to be weighed against the potential penalties or incentives.
Operational Efficiency: Strategically approaching MIPS can be a catalyst for broader improvements in clinic operations. Focusing on MIPS measures related to care coordination, patient safety, or efficient use of technology can lead to streamlined workflows and better resource utilization, which can have financial benefits beyond the MIPS adjustment itself.
Reputation and Patient Trust: While not directly monetized by MIPS itself, performance information from programs like MIPS can become publicly available (e.g., on Care Compare). Consistently good performance can enhance a clinic’s reputation among patients and peers.
Alignment with Value-Based Care: MIPS is a key component of Medicare’s shift towards value-based care. Successfully participating and performing well in MIPS positions a clinic to better adapt to other current and future value-based payment models from both Medicare and private payers.

The financial implications of MIPS are clearly significant. While the prospect of large bonuses might be tempered by the realities of budget neutrality, the threat of substantial penalties for non-participation or poor performance is very real. This makes a proactive and informed approach to MIPS not just a matter of compliance, but a critical component of a medical clinic’s financial health and long-term stability in an evolving healthcare payment landscape. The program is not just about reporting data; it’s about fundamentally re-evaluating and improving the way care is delivered, with financial consequences tied to that performance.

Table 8: MIPS Final Score vs. Payment Adjustment (Illustrative for PY 2023 / Payment Year 2025)

Final MIPS Score (PY2023)	Payment Adjustment in PY2025	Notes
0.00 – 18.75 points	-9% (Maximum Negative Adjustment)	Significant penalty for non-reporting or very low performance.
18.76 – 74.99 points	Between -9% and 0% (Negative Adjustment)	Applied on a linear sliding scale; closer to 74.99 means a smaller penalty.
75.00 points	0% (Neutral Adjustment)	This is the performance threshold.
75.01 – 88.99 points	Positive Adjustment (e.g., >0% up to a certain level)	Subject to budget neutrality scaling factor. Not eligible for the (now discontinued) additional exceptional performance bonus.
89.00 – 100.00 points	Higher Positive Adjustment (e.g., up to +2.15% for PY2023)	Subject to budget neutrality scaling factor. PY2022 was the last year for an additional exceptional performance bonus layer.

Source: Adapted from.¹⁵ Note that the positive adjustment percentages are highly variable year-to-year due to budget neutrality. The -9% maximum negative adjustment is a consistent figure for mandatory participants who do not meet requirements.

Conclusion: Navigating MIPS with Confidence and Strategic Foresight

The Merit-based Incentive Payment System (MIPS) is undeniably a complex and multifaceted program. It represents a significant component of Medicare’s ongoing shift from fee-for-service reimbursement to value-based care, fundamentally altering how medical clinics are compensated for the services they provide to Medicare beneficiaries. Throughout this guide, the aim has been to demystify MIPS, transforming it from a source of apprehension into a manageable, and even strategic, aspect of practice management.

The journey through MIPS requires diligence, but it is not an insurmountable challenge. Key takeaways for medical clinics include:

Understanding is Power: A thorough grasp of MIPS eligibility criteria, participation options (individual, group, virtual group, or MVP subgroup), and the four performance categories—Quality, Promoting Interoperability, Improvement Activities, and Cost—is the essential first step. Knowing whether your clinic is required to participate, eligible to opt-in, or exempt is crucial for strategic planning.
Small Practices Have Superpowers: CMS has recognized the unique challenges faced by smaller practices (15 or fewer clinicians) and has embedded significant flexibilities into the MIPS program for them. These include the ability to report Quality data via claims, a reduced requirement for Improvement Activities, automatic reweighting of the Promoting Interoperability category, and valuable bonus points in the Quality category. Small practices should actively leverage these advantages.
MIPS Value Pathways (MVPs) Are the Future: The development and expansion of MVPs signal a clear direction from CMS. These pathways, tailored to specialties or clinical conditions, aim to reduce reporting burden and increase clinical relevance. Clinics, particularly specialty practices, should begin exploring relevant MVPs now, as Traditional MIPS is expected to be phased out in the coming years. Early adoption can smooth the transition.
Artificial Intelligence (AI) is an Emerging Ally: AI tools offer promising solutions for streamlining MIPS data abstraction, enhancing clinical decision support for quality measure performance, predicting cost implications, and improving overall clinic efficiency. While not a silver bullet, AI can significantly reduce administrative burdens associated with MIPS.
Proactive Management and Team Engagement are Non-Negotiable: MIPS success is not achieved through last-minute efforts. It requires year-round attention, continuous monitoring of performance data, proactive planning for measure selection and activity implementation, and the engagement of the entire clinical and administrative team.
Deadlines and Details Matter Profoundly: The MIPS program operates on strict timelines for performance periods, registrations (especially for MVPs and virtual groups), data submission, and exception applications. Meticulous calendar management and attention to detail are critical to avoid missed opportunities or penalties.
The Financial Stakes Are Real and Significant: With potential negative payment adjustments reaching as high as -9% of Medicare Part B revenue for non-participation or poor performance, MIPS has a direct and substantial impact on a clinic’s bottom line. While positive adjustments are subject to budget neutrality and may be more modest, avoiding penalties is a powerful motivator for robust participation.

Ultimately, MIPS should be viewed as more than just a compliance requirement. It is a framework that, if approached strategically, can align with a clinic’s intrinsic goals of delivering high-quality patient care, improving operational efficiency, and fostering a culture of continuous improvement. The program is a marathon, not a sprint, requiring ongoing learning and adaptation as rules and measures evolve.

By embracing the knowledge and strategies outlined in this guide, medical clinics can move beyond simply trying to survive MIPS and instead position themselves to navigate it with confidence, strategic foresight, and a clear understanding of how to turn its challenges into opportunities for both financial stability and enhanced patient care. The MIPS adventure may have its complexities, but with the right map and a proactive spirit, your clinic can indeed thrive.

Learn more about MIPS by visiting the CMS Website.