The goal of Congress when the Medicare Quality Payment Program (QPP) was established was to incentivize health care practitioners to provide high-quality care by adjusting Medicare payments based on the practitioner’s performance metrics. Whether this program meets those goals is a matter of debate. Nonetheless, this is the system currently in place.
Under the traditional Merit-based Incentive Payment System (MIPS), allergists report data across four performance categories: Quality, Cost, Promoting Interoperability, and Improvement Activities. CMS has signaled it intends to replace the traditional MIPS program with a new reporting program for physicians – MIPS Value Pathways (MVP). With the advent of the MVP program, allergists face new choices in how they report measures in the QPP: Traditional MIPS or applicable MVPs. This article provides an overview of current MVP reporting options and considerations for allergists. For more details on 2025 MIPS policies, view our recent MIPS article.
MIPS Value Pathways
Reporting an MVP is currently voluntary – although CMS has stated that it will eventually become mandatory. According to CMS, this transition is intended to simplify reporting and to connect activities and measures from the four MIPS performance categories that are relevant to a specialty, medical condition, or a particular population. Below are the reporting requirements associated with MVPs:
- Quality: MVP participants must select and submit four quality measures from a limited number of measures in the MVP. At least one must be an outcome measure (or a high priority measure if an outcome is not available or applicable). Small practices (fewer than 16 clinicians) are not required to report four quality measures, provided that the small practice reports each Medicare Part B claim measure. Small practices will receive six bonus points as long as one measure is submitted.
- Improvement Activities: All MVP participants, including small practices, must attest to one improvement activity from the MVP.
- Cost: CMS calculates performance using administrative claims data. There are different cost measures geared to individual specialties.
- Promoting Interoperability: MVP participants must submit the same Promoting Interoperability measures required under traditional MIPS, unless you qualify for reweighting.
- Population Health Measures: CMS will calculate these measures through administrative claims and they will be scored as part of the quality performance category.
For more information regarding MVPs in general, please refer to the QPP website.
For the 2025 performance period, there are only 21 MVPs available for reporting. At this time, there is no allergy-specific MVP. The College has unsuccessfully petitioned for an allergy MVP and we are continuing our efforts. However, there are two available MVPs that may be options for some allergy practices:
- Pulmonology Care MVP
- Quality Care for the Treatment of Ear, Nose, and Throat Disorders MVP
There are clear disadvantages to reporting via these two MVPs for an allergy practice. For the 2025 performance period, the traditional MIPS program continues to provide allergy practices with more quality measure options and flexibilities in reporting compared to the MVP program. However, reporting via the ENT MVP may make sense for a subset of allergy practices that can make the ENT quality measures work. Below is a summary of the pros and cons of reporting via traditional MIPS compared to the Pulmonology Care MVP and the Quality Care for the Treatment of ENT Disorders MVP.
2025 MIPS Reporting Options for Allergists
| Pros | Cons | |
|---|---|---|
| Traditional MIPS |
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| Pulmonology Care MVP |
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| ENT Disorders MVP |
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Below is a high-level overview of the Pulmonology Care MVP and the Quality Care for the Treatment of Ear, Nose, and Throat Disorders MVP. If you do choose to report via an MVP, you must register in advance; the registration window is April 1 – Dec. 1, 2025.
Pulmonology Care MVP
The Pulmonology Care MVP focuses on pulmonology conditions including COPD, asthma, sleep apnea, and general pulmonology. However, CMS has acknowledged concerns that this MVP is not a viable reporting option for allergists. Although the MVP includes 10 quality measures, only three quality measures (bolded below) are regularly utilized by allergists:
- Q398: Optimal Asthma Control (OUTCOME MEASURE) (Collection Type: MIPS CQM Specifications)
- Q226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention (Collection Type: Medicare Part B Claims Specifications, eCQM Specifications, MIPS CQM Specifications)
- Q128: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan (Collection Type: Medicare Part B Claims Specifications, eCQM Specifications, MIPS CQM Specifications)
- Q052: Chronic Obstructive Pulmonary Disease (COPD): Spirometry Evaluation for Long-Acting Inhaled Bronchodilator Therapy (Collection Type: MIPS CQM Specifications)
- Q047: Advance Care Plan (HIGH PRIORITY MEASURE) (Collection Type: Medicare Part B Claims, MIPS CQM Specifications)
- Q503: Gains in Patient Activation Measure: (PAM®) Scores at 12 Months (OUTCOME MEASURE) (Collection Type: MIPS CQM Specifications)
- Q487: Screening for Social Drivers of Health (HIGH PRIORITY MEASURE) (Collection Type: MIPS CQM Specifications)
- ACEP25: Tobacco Use: Screening and Cessation Intervention for Patients with Asthma and COPD (Collection Type: QCDR)
- Q277: Sleep Apnea: Severity Assessment at Initial Diagnosis (Collection Type: MIPS CQM Specifications)
- Q279: Sleep Apnea: Assessment of Adherence to Obstructive Sleep Apnea (OSA) Therapy (Collection Type: MIPS CQM Specifications)
This MVP is not a viable reporting option for most allergists. In addition, the cost measure associated with this MVP is the asthma/COPD cost measure, which may have an adverse effect on allergists’ scores.
Quality Care for the Treatment of Ear, Nose, and Throat Disorders MVP
This MVP focuses on treatment for ear, nose, and throat disorders, including conditions such as chronic rhinosinusitis, age-related hearing loss, and otitis media. Of the 10 quality measures in this MVP, only four measures are regularly reported by allergists:
- Q128: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan (Collection Type: Medicare Part B Claims Specifications, eCQM Specifications, MIPS CQM Specifications)
- Q226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention (Collection Type: Medicare Part B Claims Specifications, eCQM Specifications, MIPS CQM Specifications)
- Q331: Adult Sinusitis: Antibiotic Prescribed for Acute Viral Sinusitis (Overuse) (HIGH PRIORITY MEASURE) (Collection Type: MIPS CQM Specifications)
- Q332: Adult Sinusitis: Appropriate Choice of Antibiotic: Amoxicillin with or Without Clavulanate Prescribe for Patients with Acute Bacterial Sinusitis (HIGH PRIORITY MEASURE) (Collection Type: MIPS CQM Specifications)
- Q277: Sleep Apnea: Severity Assessment at Initial Diagnosis (Collection Type: MIPS CQM Specifications)
- Q487: Screening for Social Drivers of Health: (HIGH PRIORITY MEASURE) (Collection Type: MIPS CQM Specifications)
- AA020: Tympanostomy Tubes: Comprehensive Audiometric Evaluation (Collection Type: QCDR)
- AA021: Otitis Media with Effusion: Comprehensive Audiometric Evaluation for Chronic OME > or = 3 months (Collection Type: QCDR)
- Q355: Unplanned Reoperation within the 30-Day Postoperative Period (HIGH PRIORITY MEASURE) (OUTCOME MEASURE) (Collection Type: MIPS CQM Specifications)
- Q357: Surgical Site Infection (SSI) (HIGH PRIORITY MEASURE) (OUTCOME MEASURE) (Collection Type: MIPS CQM Specifications)
This MVP does not provide much flexibility for reporting. For cost measurement, the MVP does not include the asthma/COPD cost measure. Instead, allergists would be scored under the Medicare Spending Per Beneficiary (MSPB) cost measure. This could be favorable for some allergy practices which were adversely impacted by the asthma/COPD cost measure in the 2023 performance year.
The ACAAI has expressed to CMS that existing MVPs are not optimal reporting options for allergists. We will continue to urge CMS to adopt a separate MVP for the practice of allergy.
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
