The Centers for Medicare & Medicaid Services (CMS) recently released the finalized Calendar Year (CY) 2025 Medicare Physician Fee Schedule (PFS) Rule, which outlines crucial updates and policy shifts for the Quality Payment Program (QPP) beginning with the 2025 performance year. Set to be published in the Federal Register on December 9, 2024, these changes aim to refine existing policies, incorporate new measures, and streamline reporting processes. Here, we break down the main updates and what they mean for healthcare providers navigating the QPP landscape.
Key Policy Changes for 2025
1. Merit-based Incentive Payment System (MIPS) Revisions
CMS has introduced several modifications for MIPS in 2025, affecting performance categories and scoring methodologies:
New and Updated Quality Measures: CMS has added seven new quality measures, significantly altered 66 existing measures, and removed 10 outdated ones. This reshaping aims to align with evolving clinical practices and enhance the relevance of quality measures.
Cost Measure Scoring Adjustments: The scoring methodology for cost measures has been revised, allowing for more nuanced assessments and ensuring that cost accountability reflects true resource utilization.
Elimination of the 7-Point Cap: The policy of capping certain "topped out" quality measures at seven points, particularly those in specialty sets with limited measures, has been removed. This change is intended to provide more flexibility and fairness in scoring high-performing specialties.
Episode-based Cost Measures: CMS added six new episode-based cost measures and modified two existing ones. These measures are designed to evaluate the costs associated with specific procedures or conditions, promoting value-based care.
Data Submission Policies: Updated guidelines now govern how CMS will handle multiple data submissions for the Promoting Interoperability performance category, enhancing clarity and consistency.
Streamlined Improvement Activities: CMS has removed the weighting for improvement activities and simplified reporting requirements to reduce the burden on providers.
Minimum Criteria for Scoring: New criteria have been established for qualifying data submissions in the quality, improvement activities, and Promoting Interoperability categories to ensure they meet minimum requirements for scoring.
2. Performance Threshold Stability
To foster stability and predictability in the MIPS program, CMS has maintained the current performance threshold at 75 points for the 2025 period. This decision reflects a commitment to continuity, allowing providers to adjust to other significant changes without facing additional uncertainty.
CMS has also extended the 75% data completeness requirement through the 2028 performance period, emphasizing the importance of comprehensive data submission in accurately assessing performance.
Enhancements in MVPs (MIPS Value Pathways)
1. Introduction of New MVPs
In line with CMS’s broader push toward specialization and targeted care, six new MVPs have been introduced for 2025. These MVPs focus on fields such as ophthalmology, dermatology, gastroenterology, pulmonology, urology, and surgical care. This expansion supports the goal of creating more relevant and precise reporting frameworks for different specialties.
2. MVP Consolidation
Another noteworthy change is the consolidation of neurology-focused MVPs. CMS merged two previously finalized neurological MVPs into a single pathway, simplifying the reporting structure and potentially reducing administrative burdens for neurologists.
APP Plus Quality Measure Set
CMS has also finalized an enhancement to the Alternative Payment Model Performance Pathway (APP) known as the APP Plus quality measure set. This set will consist of 11 measures, which include six from the current APP set (five of which are part of the Adult Universal Foundation) and five additional measures from the broader Adult Universal Foundation measure set.
The incorporation of these measures will be gradual, allowing providers time to adjust and integrate the expanded metrics into their workflows. This incremental approach acknowledges the complexity of changing reporting practices and aims to make the transition smoother for healthcare professionals.
Broader Implications for Providers
The finalized changes reflect CMS's continued commitment to refining the QPP to balance comprehensive reporting with manageable requirements. These updates aim to support value-based care while simplifying processes and ensuring equitable performance assessments across specialties.
1. Shifts in Quality Measurement
The introduction of new quality measures and substantive changes to existing ones highlight the need for providers to stay informed and agile. As clinical standards evolve, so too must the metrics that assess the quality of care. Providers will need to familiarize themselves with these changes to optimize their performance scores and maintain compliance.
2. Enhanced Focus on Cost Accountability
Revisions to the cost measure scoring methodology and the addition of new episode-based cost measures demonstrate an increased focus on cost-effective care. These measures will likely encourage providers to examine their care delivery practices and identify areas where efficiencies can be achieved without compromising patient outcomes.
3. Adjustments in Promoting Interoperability and Data Submission
With updates to the handling of multiple data submissions, providers must review their data submission protocols to align with the new rules. Accurate and timely submissions are crucial for securing positive scores in the Promoting Interoperability category.
4. The Value of MVPs
For providers specializing in the newly included fields, the addition of targeted MVPs represents an opportunity to report more relevant data and potentially achieve higher scores by aligning reporting with their specialty practices. The simplified neurology pathway, in particular, may streamline reporting for neurologists and reduce duplicative efforts.
The 2025 policy updates for the QPP emphasize CMS’s efforts to maintain stability while enhancing the relevance and accuracy of the program. By retaining the 75-point performance threshold and the data completeness requirement, CMS ensures that providers have a consistent benchmark against which to measure their efforts. Meanwhile, the introduction of new measures, adjustments to cost evaluations, and the incremental rollout of the APP Plus quality measure set signal CMS’s commitment to evolving the QPP in ways that promote comprehensive, value-driven care.
Providers should proactively review these changes, consider their implications on practice management, and participate in informative sessions such as the November webinar to stay ahead. The goal is not only compliance but also leveraging these updates to enhance care delivery and achieve optimal performance scores in the long term.
For more detailed information on these changes, reviewing CMS’s fact sheets and guides on the 2025 Final Rule is recommended. This preparation will enable providers to effectively navigate the updated landscape and maximize their participation in the QPP.
