QPP 2025 Updates & Information
QPP 2025 Updates
If you haven’t noticed, CMS continues to refine the Quality Payment Program (QPP), with the ongoing goal to enhance quality, reduce costs, and reduce administrative barriers and burdens for clinicians. Providers should review these changes in detail and assess their impact on practice operations and reporting strategies. Most recently, CMS finalized several updates for the 2025 performance year, impacting providers participating in the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). These changes, effective for the 2025 performance period and influencing the 2027 MIPS payment year, aim to refine quality reporting, cost measurement, and interoperability standards.
Performance Threshold and Data Completeness
- Performance Threshold: The performance threshold remains at 75 points for the 2025 performance period. This benchmark determines whether clinicians receive positive, neutral, or negative payment adjustments in 2027.
- Data Completeness: The 75% data completeness requirement continues throughout the 2028 performance period. Providers must report at least 75% of eligible cases for each measure to ensure accurate performance assessment.
MIPS Value Pathways (MVPs)
- New MVPs: Six new MVPs are introduced for 2025, focusing on specialties such as ophthalmology, dermatology, gastroenterology, pulmonology, urology, and surgical care. These pathways aim to streamline reporting by aligning measures with specific clinical areas.
- MVP Consolidation: Two neurology-focused MVPs have been merged into a single neurological MVP to reduce redundancy and simplify reporting.
APP Plus Quality Measure Set
- Introduction of APP Plus: CMS has finalized the APP Plus quality measure set, an optional set for MIPS APM participants, except for Medicare Shared Savings Program (Shared Savings Program) Accountable Care Organizations (ACOs). The existing APP quality measure set remains available for these participants.
- Mandatory Reporting for ACOs: Starting in the 2025 performance year, Shared Savings ACOs are required to report the APP Plus quality measure set. The existing APP set will no longer be available for these ACOs.
- Measure Composition: The APP Plus set comprises 11 measures, including six from the existing APP set and five additional measures from the Adult Universal Foundation measure set. These additional measures will be incrementally incorporated over time.
- Collection Types: For the 2025 and 2026 performance periods, Shared Savings Program ACOs can use eCQMs, Medicare CQMs, or MIPS CQMs to report APP Plus measures. However, starting in 2027, MIPS CQMs will no longer be an option for these ACOs.
Quality and Cost Measure Updates
- Quality Measures: Seven new quality measures have been added, ten have been removed, and 66 existing measures have undergone substantive changes. These updates aim to enhance the relevance and accuracy of quality reporting.
- Cost Measures: Six new episode-based cost measures have been finalized, and two existing measures have been revised. These measures assess the cost of care for specific clinical episodes, promoting cost efficiency.
- Scoring Methodology: CMS is revising the cost measure scoring methodology to better assess clinician cost performance. Additionally, the seven-point cap for scoring certain topped-out quality measures in specialty sets with limited measures is being removed.
Promoting Interoperability and Improvement Activities
- Data Submission Criteria: Beginning with the 2024 performance period, CMS has established minimum criteria for data submissions in the quality, improvement activities, and Promoting Interoperability performance categories. Submissions must meet these criteria to be eligible for scoring.
- Multiple Data Submissions: CMS is changing its policy on multiple data submissions for the Promoting Interoperability category. Starting in the 2024 performance period, if multiple submissions are received, CMS will score the most recent submission that meets the minimum criteria.
- Improvement Activities: CMS is removing improvement activity weighting and streamlining reporting requirements for this performance category to reduce administrative burden.
For more comprehensive information, please refer to the official CMS resources: