Understanding QPP is in 2025 The 2025 Final Rule for the Merit-based Incentive Payment System (MIPS) shows that while many elements remain stable, there are several significant changes that practices should be aware of.

To start, the Performance Threshold remains at 75 points through the 2025 Performance Year, and the Data Completeness Threshold stays at 75% (with CMS confirming it will remain at this level through 2028). This stability provides predictability for practices planning their quality reporting strategy.

The Cost category has seen positive scoring adjustments. The curve has been skewed upward to align with average Cost scores, making it less likely that this historically challenging category will drag down your overall MIPS performance. Many practices have struggled with predicting Cost scores or implementing effective changes to improve performance, so this adjustment should help alleviate some of that burden.

Improvement Activities have been simplified for 2025. Traditional MIPS participants now only need to report two activities, while small practices, non-patient facing practices, and those doing MIPS Value Pathways (MVPs) need to report just one activity. This streamlining makes the category more approachable and less time-intensive for many practices.

A noteworthy addition is the new Extreme and Uncontrollable Circumstances (EUC) application category specifically for vendor issues. After submission, practices can now file an EUC hardship application if they've experienced problems with their vendors that affected their submission. This provides an important safety net for practices that encounter technical difficulties beyond their control.

The Annual MIPS Reporting Rhythm: A 15-Month Journey Success in MIPS isn't achieved through last-minute efforts. The reporting process follows a 15-month calendar that can be divided into five distinct quarters, each with specific goals and milestones.

Quarter One (January-March): Planning and Review The first quarter lays the foundation for your entire reporting year. This is the time to:

• Review new Quality measures and Improvement Activities released by CMS
• Identify any measures that have been retired
• Evaluate whether there are new measures that better align with your practice
• Consider group versus individual reporting strategies
• Plan for technical challenges such as EHR transitions
• Schedule a kickoff call with your registry consultant

For Promoting Interoperability, remember that the reporting period is now 180 days, making early planning crucial for addressing requirements like Clinical Registry participation and EHR certification maintenance.

The Cost category often feels like a black box for many practices. Working with an experienced registry early in the year allows time to implement containment and mitigation strategies that can positively impact your score. CMS has begun producing patient-level reports that can provide valuable insights into your Cost performance.

Quarter Two (April-June): Implementation and Validation The second quarter focuses on implementation and data validation:

• Submitting billing data and Promoting Interoperability information
• Assessing your current MIPS performance
• Identifying trends, vulnerabilities, and concerns
• Ensuring all expected billing data is being received
• Confirming technical infrastructure is properly set up

This is also the ideal time to prepare for potential audits. Working with your registry to understand documentation requirements can help improve workflows and reduce burden if an audit occurs.

Quarter Two serves as your testing phase, allowing you to validate the decisions made in Quarter One and make adjustments if needed. If you decided to try a new measure, this is when you determine if it's truly a good fit for your practice.

Quarter Three (July-September): Feedback Reports and Proposed Rule Review While you should be regularly submitting data and monitoring performance, Quarter Three brings two important CMS activities:

• CMS releases feedback reports from the previous year's submissions
• The Proposed Rule for the coming year is published

The feedback reports provide valuable insights into how CMS scored your performance in the previous year, particularly in the Cost category. This information can help identify vulnerabilities in your current submission that can be mitigated.

The Proposed Rule comment period is a crucial opportunity for practices to have their voices heard. CMS is required by law to review and respond to all comments received during the 60-day comment period. This is your chance to influence how the program evolves to better meet the needs of your practice.

Quarter Four (October-December): End-of-Year Decisions The fourth quarter is decision time:

• Determining whether to apply for Extreme and Uncontrollable Circumstances hardships
• Finalizing which Quality measures to submit (many practices track ten measures throughout the year before selecting their best six)
• Deciding between Traditional MIPS and MVP submissions if you've been pursuing both paths

Quarter Four is about tying up loose ends and making final decisions to prepare for submission.

Quarter Five (January-March of Following Year): Submission and Restart The final quarter of the cycle is when your submission is completed and you begin planning for the next reporting year. Ideally, all decisions have been made, and you're simply waiting for final data before submitting to CMS.

Maximizing Value from MIPS Value Pathways (MVPs) The 2025 Final Rule demonstrates CMS's continued commitment to the MVPs program, with six new pathways added for a total of 21 MVPs. According to CMS estimates, about 80% of MIPS-eligible clinicians now have eligibility for at least one MVP.

CMS has also simplified MVPs by removing the requirement to choose between population health measures. Instead, they will calculate your population health measures and apply the best score to your submission, reducing administrative burden and making MVPs more accessible.

Why Consider an MVP Before It's Required? MVPs offer several advantages over Traditional MIPS:

• Only four Quality measures are required (versus six in Traditional MIPS)
• Exposure to the Cost category is limited to specific measures relevant to the MVP
• Only one Improvement Activity is required (versus two in Traditional MIPS)

These simplifications can significantly reduce reporting burden while potentially improving your score.

The Future of MVPs and Important Milestone Looking ahead, CMS anticipates that Traditional MIPS will eventually end, with MVPs becoming the standard for participation. A key milestone to prepare for: in Performance Year 2026, subgroup reporting will be mandatory for multi-specialty practices that report an MVP. While there's still no requirement to do an MVP submission, practices should begin planning for this transition now.

Questions remain about how CMS will define multi-specialty practices for subgroup purposes and what options will be available for providers without applicable MVPs. These operational details are still being defined by CMS, highlighting the importance of providing feedback during Proposed Rule comment periods.

APM Performance Pathway (APP) for Medicare Shared Savings Program ACOs For Medicare Shared Savings Program (MSSP) ACOs, several significant changes are on the horizon. CMS had initially proposed to sunset MIPS CQM reporting in 2025 but has postponed this for at least two years, providing continued flexibility for APP submissions.

The Final Rule introduced the APP Plus measure set, which will gradually add measures over the coming years:

• 2025: Breast cancer screening measure added
• 2026: Colorectal cancer screening measure to be added
• 2027: Substance use disorder measure to be added
• 2028: Screening for social drivers of health to be added

APP Reporting Timeline While the steps for APP reporting mirror those of MIPS (goal identification, data collection, validation, and performance optimization), the timeline is more extended due to the increased volume and complexity. For optimal results, ACOs should plan on a two-year timeline, with data validation often requiring more time than anticipated, especially for larger ACOs with numerous participating practices.

Keys to Success Across All Quality Reporting Programs Whether you're reporting for MIPS, MVPs, or APP, certain characteristics consistently predict success:

1. Early Engagement: Starting the process early in the year dramatically increases your chances of achieving the highest possible score.
2. Continuous Involvement: Successful participants stay engaged with their reporting throughout the year, regularly reviewing data and working with their registry consultants.
3. Proactive Planning: Anticipating challenges and planning for them, particularly regarding data collection and validation, prevents last-minute scrambling.
4. Adaptability: Being willing to try new measures or approaches rather than simply repeating what was done in previous years often leads to better results.
5. Regular Communication: Maintaining open lines of communication with your registry consultant allows for timely problem-solving and optimization.

Getting Started at Any Point While starting early provides the best opportunity for optimization, it's never too late to begin. Experienced registries have strategies to help practices that join mid-year catch up and still achieve successful submissions. The important thing is to start when you can, then position yourself to begin the next reporting year on solid footing.

With the right approach and support, practices can not only meet CMS requirements but also derive meaningful value from the quality reporting process. By understanding the rhythm of QPP reporting, staying engaged throughout the year, and leveraging the expertise of experienced consultants, you can transform quality reporting from a burden into an opportunity for improvement and financial success.