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5 Most Confusing Parts About MIPS - and How to Simplify Them

Patti Simms
Author / Quantician
5 min read
April 23, 2025

For healthcare providers participating in the Merit-Based Incentive Payment System (MIPS), the journey toward compliance and performance-based reimbursement can feel overwhelming. With evolving rules, a complex scoring system, and multiple reporting pathways, MIPS has become a maze of technicalities that many practices struggle to navigate. Whether you're managing reporting for a solo provider or a multi-specialty group, the reality is the same: MIPS is confusing.

Before it becomes too late in the performance year to make changes that matter, it’s worth taking a step back to better understand the common pitfalls — and how to proactively avoid them. In this article, we’ll explore the five most confusing parts of MIPS and offer ways your practice can simplify the process for better outcomes.

What is MIPS, and Why Does It Matter? MIPS is a CMS program designed to tie Medicare reimbursement to quality and value rather than volume. It combines four performance categories — Quality, Cost, Promoting Interoperability, and Improvement Activities — into a single composite score that determines whether a provider earns a positive (up to +9%), neutral, or negative (as much as -9%) payment adjustment, based on their final score. Simply put, your participation in MIPS directly affects how much you get paid by Medicare. With performance thresholds rising every year, the stakes are only getting higher.

Failing to report accurately can lead to steep penalties — but excelling can mean significant financial rewards and improved clinical outcomes. That’s why understanding MIPS isn’t just a compliance requirement — it’s a business imperative. Below are the five common parts of MIPS we hear our clients ask about often.

1. Choosing the Right Measures With hundreds of quality measures to choose from, it's no surprise that practices often find themselves second-guessing their selections. Should you stick with last year’s measures, even if your patient population has shifted? Are there better-performing options that align with your EHR data? Measure selection can have a significant impact on your final score, yet most providers lack the time or tools to analyze every possibility.

Steps you can take:

  • Regularly review the CMS Measure Specifications for your specialty.
  • Compare current performance data with national benchmarks.
  • Evaluate how well each measure aligns with your clinical workflows.

You want to ensure that you’re not just meeting requirements but you’re choosing the most advantageous path forward.

2. Tracking Measures Year-Round Many practices take a reactive approach to MIPS, waiting until the end of the year to pull data. Unfortunately, this often leads to gaps, missed measures, and costly surprises. Real success with MIPS requires a proactive mindset and consistent tracking throughout the year.

To stay proactive, setting quarterly checkpoints to review performance can serve as a consistent way to build time into the year to review, pivot, and stay on-time every step of the performance year. Another step you should consider taking is using EHR alerts or templates to ensure data is captured in real-time and the reporting work does not pile up, causing additional stress and headaches for your team. Lastly, engaging staff in understanding which measures matter and why can act as a gentle reminder of the importance of staying compliant, providing high-quality patient care, and recording encounters in real-time. Instead of a year-end scramble, you get clarity and control every step of the way.

3. Decoding Scoring and Benchmarks Understanding how your practice is scored under MIPS isn’t always intuitive. CMS benchmarks vary by measure, and small percentage changes can result in big swings in your composite score. Worse, these scores impact future Medicare reimbursement rates — which means guessing isn’t an option. You can take the guesswork out of reporting through these steps:

  • Study the annual CMS Final Rule to understand scoring methodology.
  • Monitor your performance against decile-based benchmarks.
  • Explore online tools or webinars that walk through scoring examples.

This transparency empowers your team to make informed decisions rather than operate in the dark.

4. Picking the Right Reporting Method Another challenge? Figuring out how to report your data. CMS allows submissions through various channels, including EHRs, claims, and registries, but not all methods are created equal. Some practices opt for convenience without realizing they're leaving points on the table or exposing themselves to higher audit risk.

When it comes to submitting MIPS data, it's essential to weigh the pros and cons of each submission method — whether that’s cost, ease of use, accuracy, or audit protection. Once you’ve selected your approach, make sure it aligns with all current CMS requirements to avoid compliance issues down the line. If your practice plans to submit internally, consider running a trial submission early in the year. This can help uncover formatting errors or data inconsistencies before they become a problem at the deadline.

5. Keeping Up with Changing Rules Finally, let’s talk about the constant rule changes. Each year, CMS releases a new Final Rule that adjusts how MIPS is scored, which measures are available, and what thresholds must be met. For busy providers, staying current can feel like a full-time job. However, there are ways to make this daunting task a bit more digestible.

By subscribing to CMS newsletters and stakeholder calls you are first to the news and can take actionable steps to adjust internally, stay compliant, and stay ready. Other steps you can take is attending industry webinars that summarize rule changes and setting internal meetings post-rule release to adapt your MIPS strategy.

Key 2025 MIPS Dates to Keep in Mind

  • January 1, 2025: Start of the 2025 Performance Year
  • December 31, 2025: End of the 2025 Performance Year
  • January–March 2026: Submission window for 2025 data
  • July 2026: CMS releases feedback reports based on 2025 data
  • January 2027: Payment adjustments applied based on 2025 performance

Staying ahead of these key milestones ensures you’re not rushing or missing opportunities to improve outcomes.

Final Thoughts MIPS reporting doesn’t have to be overwhelming. By understanding what makes the process so confusing — and putting systems in place to address those pain points — practices can take control of their performance and outcomes. Start with measure selection, track regularly, understand the scoring math, and most importantly, keep your team informed. With the right structure, your practice can thrive, even in a system as complex as MIPS.

Want to save time and stress? While it's entirely possible to manage MIPS in-house with enough diligence and oversight, many practices find themselves stretched too thin - spending limited resources untangling CMS specifications and data files. Working with a trusted partner can help you get it right the first time.

Quantician is a CMS-Qualified Registry that simplifies reporting, improves accuracy, and protects your revenue. Reach out today for a strategy session tailored to your practice.

Patti Simms
Author / Quantician

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