The Centers for Medicare and Medicaid Services (CMS) recently released the 2025 Medicare Physician Fee Schedule final rule (Final Rule), which includes policies for the Quality Payment Program (QPP). This article summarizes key changes to the traditional Merit-based Incentive Payment System (MIPS) program for the 2025 performance period.
As a refresher, traditional MIPS is composed of four performance categories: Quality, Cost, Promoting Interoperability (PI), and Improvement Activities (IA). A practitioner’s score for each of these categories determines one’s total MIPS score for 2025 and the corresponding payment adjustment (positive, neutral, negative) in 2027.
2025 MIPS pros and cons
At a glance, the following list outlines the key pros and cons in the final rule:
- Pros
- Performance threshold and data completeness requirements did not increase.
- Cost category scoring has been recalculated to improve overall scores beginning in 2024.
- Fewer IAs are required.
- Scoring of incomplete submissions for Quality, IA and PI will cease.
- Clinicians will not be penalized if they delegate submission to a third-party intermediary that doesn’t submit data by the deadline.
- Cons
- Maximum penalty remains at 9% and reporting remains burdensome.
- CMS estimates that small practices – particularly solo practitioners – will receive the most penalties.
CMS projected payment adjustments
CMS estimates that the median final MIPS score will be 86.42, with 78% of eligible clinicians receiving a positive payment adjustment. However, solo practitioners and small practices may continue 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 (2-15) | 86.02 | 20.93% |
MIPS policies 2024 vs. 2025
The following chart provides a high-level overview of changes to key MIPS policies in the 2025 Final Rule.
| POLICY | CY 2024 Policies | CY 2025 Policies |
|---|---|---|
| Category Weights for Traditional MIPS: Individuals, Groups, and Virtual Groups | 30% for the Quality performance category
30% for the Cost performance category 15% for the IA performance category 25% for the PI performance category |
No change. |
| Performance Threshold: Minimum Points to Avoid a Penalty | 75 points. | No change. |
| Data Completeness | 75% | No change through the 2028 performance period. |
| Quality, IA and PI Category Incomplete Submissions | In 2024, CMS accepted incomplete submissions for these categories and assigned them a zero score. This adversely impacts clinicians and can override requested reweighting of Quality, IA and PI Performance Categories. | IA: A submission with only a date and practice ID will not be scored; must include one “yes” response to be scored. PI: Under the Final Rule, a submission with only a date and practice ID will not be scored. It will not override reweighting of the PI category. Quality: Submission for the quality performance category must include numerator and denominator information for at least one quality measure to be scored. |
| IA Performance Category: Number of Improvement Activities | Most clinicians must submit two to four IAs to receive the maximum IA score of 40 points. | CMS reduced the number of activities:
|
| Cost Scoring Methodology | Measures in the cost performance category were scored against a benchmark determined based on average performance of all MIPS eligible clinicians during that same performance period. | The median cost for a measure will be set at a score derived from the performance threshold established for that payment year. This will result in overall higher cost scores starting with the 2024 performance period. |
| Performance Category Reweighting due to third-party submission issues | Previously, CMS did not allow MIPS eligible clinicians to request reweighting for the quality, IA, and/or PI performance categories when data are unable to be submitted because the clinician delegated submission to their third-party intermediary and the third party didn’t submit the data by the applicable deadlines. | Under the Final Rule, a clinician may request reweighting for the quality, IA, and/or PI performance categories when the designated third-party intermediary didn’t submit the data by the applicable deadlines. A clinician may request reweighting beginning with the 2024 performance period. |
| PI Performance Category: Data Submission | Allows submissions in the PI performance category without completed responses for all the required objectives, measures, and attestations | Beginning with the 2024 performance period, a data submission for the PI performance category must include all the following elements to be scored:
|
| PI Performance Category: Multiple Data Submission | Previously, when CMS received multiple data submissions with conflicting data for the PI category, the agency assigned a PI score of zero. | Beginning with the 2024 performance period, CMS will calculate a score for each data submission received and assign the highest of the scores. |
| New Measure in 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 | |
| Maximum penalty to Medicare payments. | 9% | No change. |
| CMS Estimated Median Final MIPS Score | 83.40, with 78% eligible clinicians receiving a neutral or positive payment adjustment | 86.42, with 78% eligible clinicians receiving a positive payment adjustment |
| Quality Data Completeness Threshold | 75% | No change. |
The College is aware of the immense burden of MIPS on practicing allergists and is diligently working with the AMA to advocate for solutions. More information can be found at:
