On July 10, 2024, the Centers for Medicare and Medicaid Services (CMS) released the 2025 Medicare Physician Fee Schedule proposed rule recommending a number of changes to the Quality Payment Program (QPP), including the traditional Merit-based Incentive Payment System (MIPS) program and the optional MIPS Value Pathways (MVPs). This is the first article in a multi-part series that provides a summary of CMS’s proposed changes to the QPP and how they may affect you.
Traditional MIPS
As a refresher, traditional MIPS is comprised of four performance categories: Quality, Cost, Promoting Interoperability (PI), and Improvement Activities (IA). A provider’s score for each of these categories determines one’s total MIPS score and corresponding payment adjustment.
Performance category weights
For the 2025 performance year, the Quality, Cost, IA, and PI performance category weights will remain the same as in 2024:
- 30% for the Quality performance category
- 30% for the Cost performance category
- 15% for the IA performance category
- 25% for the PI performance category
Performance threshold
Due in part to College advocacy, CMS proposes to maintain the current performance threshold of 75 points in 2025. Clinicians and group practices must receive at least 75 points to avoid a negative payment adjustment for the 2027 payment year.
Data completeness
Thanks in part to College advocacy, CMS proposes to maintain the 75% data completeness criteria through the 2028 performance period.
Data submission for the performance categories
One recurring MIPS problem is that CMS currently accepts incomplete submissions for the Quality, IA and PI categories – and then assigns these incomplete submissions a zero score. This not only adversely impacts the clinician’s score, but it can also override the reweighting of the PI and/or other categories if requested by the clinician. CMS aims to remedy this issue with the proposed 2025 rule.
Qualify performance category
Currently, CMS will consider any quality measure submission received during the MIPS submission period as a valid data submission and will assign a score for it – even if it’s missing key data, and results in a score of zero. In an improvement, CMS is proposing that a submission for the quality performance category must include numerator and denominator information for at least one quality measure to be considered a data submission and scored.
CMS is also proposing to add the following quality measure to the Allergy/Immunology specialty set:
- Adult COVID-19 Vaccination Status: Percentage of patients aged 18 years and older seen for a visit during the performance period that are up to date on their COVID-19 vaccinations as defined by CDC recommendations on current vaccination.
Improvement Activities performance category
CMS is proposing to reduce the number of IAs clinicians are required to complete. Currently, for the 2024 performance year, most clinicians must submit 2 to 4 IAs to receive a maximum IA score of 40 points. Under the Proposed Rule, with respect to traditional MIPS reporting, clinicians and groups with the small practice, rural, or health professional shortage area special status must attest to just one activity. All other clinicians and groups must attest to two activities. In addition, a submission for the IA performance category must include a “yes” response for at least one IA to be considered a data submission and scored.
Promoting Interoperability performance category
Under the Proposed Rule, beginning with the 2024 performance period, CMS is proposing that a data submission for the PI performance category must include all the following elements to be considered a qualifying data submission and scored:
- Performance data, including any claim of an applicable exclusion, for the measures in each objective.
- Required attestation statements.
- CMS CEHRT ID from the Certified Health IT Product List.
- The start date and end date for the applicable performance period.
Like the Quality and IA category proposals, a submission with only a date and practice ID would not be considered a data submission and would no longer be assigned a “null” score. And importantly, it would not override reweighting of the PI category.
Cost Performance category
The College has repeatedly expressed concern to CMS about the potential negative impact of the Cost Performance category on allergists’ final MIPS scores. In response to our concerns and concerns expressed by others, CMS is proposing to modify the methodology for scoring cost measures beginning with the 2024 performance period. CMS proposes to tie the median score to a point value derived from the performance threshold. CMS estimates this proposed methodology would increase the mean cost performance category score (unweighted) from 59 out of 100 to 73 out of 100.
MVPs
CMS has established a new reporting option that will eventually replace the existing MIPS program. This reporting option – MVPs – includes a subset of measures and activities that are related to a particular specialty or medical condition. CMS is proposing a new Pulmonology Care MVP that would be available starting with the 2025 performance period. However, the Pulmonology Care MVP does not offer sufficient reporting options for allergists, and CMS has not yet established an allergy-specific MVP. The College will continue to advocate for the most appropriate reporting options for allergists under the new MVP program.
CMS is seeking feedback on whether to fully transition to MVPs and sunset traditional MIPS by the 2029 performance period.
CMS’ projected 2025 MIPS participation and 2027 payment adjustments
CMS is estimating the median final MIPS score will be 86.42, with 78% of eligible clinicians receiving a positive payment adjustment. This is an increase over 2024 and is due primarily to CMS’ proposal to adjust the cost measure scoring methodology. However, solo practitioners and small practices are still estimated to receive the most penalties:
| Estimated median final score | Estimated % receiving a penalty |
|
|---|---|---|
| All MIPS eligible clinicians | 86.42 | 15.47% |
| All solo practitioners | 75.00 | 45.65% |
| All small practices | 86.02 | 20.93% |
CMS estimates the median positive payment adjustment in the 2027 payment year based on 2025 performance will be 1.31%, while the median penalty will be -1.48%. However, solo practitioners and small practices will fare worse, with median expected penalties of -6.42% and -5.88%, respectively. Unfortunately, more of these physicians are expected to receive the maximum -9% penalty compared to larger practices.
Read more about the 2025 QPP proposed rule.
While many of these changes are incrementally positive, the Advocacy Council remains concerned about the Pulmonology Care MVP and the overall burden of the MIPS program on allergists – particularly solo practitioners and small practices. Rest assured the Advocacy Council will submit comments to CMS.
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
