By Erin Houck
Senior Director, Client Success
On Wednesday, July 10, 2024, the Centers for Medicare & Medicaid Services (CMS) released the 2025 Medicare physician fee schedule (PFS) proposed rule scheduled to be published on July 31, 2024. The Proposed Rule includes proposals for the Quality Payment Program (QPP), the Merit-based Incentive Program (MIPS), and Advanced Alternative Payment Models (APMs).
2025 Quality Payment Program (QPP) Proposed Policy Highlights
- Continue the development and maintenance of MIPS Value Pathways (MVPs)
- Creating APM Performance Pathways (APP) Plus quality measure set
- Update the MIPS measures/activities inventories and scoring methodologies
- Maintain stability within the MIPS program through the established performance threshold and data completeness criteria
Key QPP Policy Highlights
- Maintaining the current performance threshold policies, leaving the performance threshold set at 75 points for the 2025 performance period.
- Keeping the 75% data completeness criteria through the 2028 performance period for all applicable collection types.
- Base performance category weights remain the same (30% Cost, 30% Quality, 25% Promoting Interoperability, and 15% Improvement Activities).
- MIPS scoring methodology changes proposed for the Quality, Cost, and Improvement Activity performance categories.
Emergency Medicine MIPS Value Pathway (MVP)
The CMS proposed rule suggests changes to the Emergency Medicine MVP which was developed by ACEP and was first available for reporting in the 2023 performance year. ACEP has stated that they will formally comment to CMS on the proposed changes by Sept 9, 2024.
In this year’s rule, CMS is proposing to remove Quality Measure 254 from the MVP.
CMS is also proposing to add 1 improvement activity (IA_ERP_6: COVID-19 Vaccine Achievement for Practice Staff), remove 1 improvement activity (CC_2 Implementation of improvements that contribute to more timely communication of test results), and remove the weights associated with the improvement activities requiring completion of just one improvement activity in 2025.
CMS also proposes changing the population health measure (PHM) process within MVPs. Rather than requiring the Participant to choose which PHM they want to be scored on, CMS will use the highest score of all available population health measures. If no population health measure has a benchmark or meets the case minimum requirement, then the population health measure is excluded from the MVP Participant’s total measure achievement points and total available measure achievement points.
MIPS Performance Category Proposed Changes
Quality Performance Category
CMS is proposing a total of 11 measures for removal from the MIPS quality measure set, 14 additions, and substantive changes to 66 traditional CQM measures. These changes would yield a total of 196 clinical quality measures (CQMs) for performance year 2025 many of which are not applicable/available to Emergency Medicine.
The key proposed changes specific to Emergency Medicine include:
- Removal of Measure Q254: Ultrasound Determination of Pregnancy Location for Pregnant Patients with Abdominal Pain
- Addition of Q181 Elder Maltreatment to the Emergency Medicine Measure Set
Additionally, CMS is proposing to modify scoring for topped-out measures in specialty measure sets with limited inventory and a high proportion of topped-out measures by applying a new flat benchmark methodology. This new benchmark method would only apply to a subset of topped-out measures and the commonly used Emergency Medicine QPP measures were not included and therefore, as presently written, does not represent a positive change for Emergency Medicine for 2025.
Improvement Activities Performance Category
CMS is proposing two changes to the traditional MIPS improvement activities reporting and scoring policies for the CY 2025 performance period/2027 MIPS payment year:
- To eliminate the weighting of activities
- To reduce the number of activities to which clinicians are required to attest to achieve a score in the improvement activities performance category.
- Clinicians, groups, and virtual groups with the small practice, rural, non-patient facing, or health professional shortage area special status must attest to 1 activity.
- All other clinicians, groups, and virtual groups must attest to 2 activities.
Newly Proposed Improvement Activities
- IA_PM_XX: Implementation of Protocols and Provision of Resources to Increase Lung Cancer Screening Uptake
- IA_PM_XX: Save a Million Hearts: Standardization of Approach to Screening and Treatment for Cardiovascular Disease Risk
Improvement Activities of Note Proposed for Removal which may impact some Emergency Medicine physicians and QHPs:
- IA_EPA_1: Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real-Time Access to Patient’s Medical Record
- IA_CC_1: Implementation of use of specialist reports back to referring clinician or group to close referral loop
- IA_CC_2: Implementation of improvements that contribute to more timely communication of test results
Cost Performance Category
CMS is proposing to adopt a new cost measure exclusion policy beginning with the CY 2025 performance period/2027 MIPS payment year.
In addition, CMS is proposing to modify its methodology for scoring measures for the cost performance category beginning with the 2024 performance year. This revision of the cost measure scoring methodology will assess clinician cost of care more appropriately in relation to national averages.
The proposed cost scoring methodology would use a new distribution for cost scoring in which the median cost for a measure would be set at a score derived from the performance threshold established for that MIPS payment year. For example, for the CY 2024 performance period/2026 MIPS payment year, the median would be set at 7.5, the performance threshold equivalent. The cutoffs for benchmark point ranges would then be calculated based on standard deviations from the median.
Impact: This proposal will not punish clinicians with costs near the 50th percentile. CMS anticipates 3.89 additional Cost performance category points for clinicians with at least one cost measure.
Promoting Interoperability Category
No substantial changes to the PI performance category with maintained automatic reweighting for certain special statuses (small practices, ASC-based, hospital-based, and non-patient facing). Most Emergency Medicine groups/physicians/QHPs are exempt from mandatory PI reporting but voluntary reporting is an option and Ventra suggests EM groups can benefit from PI reporting which reduces the weight of quality in the overall MIPS score and can benefit those with less than perfect quality scores.
Next Steps
CMS is currently collecting comments on the Proposed Rule. Once the comment period closes, CMS will evaluate all the comments and finalize the rule. The 2025 PFS Final Rule will be published in mid-November, including all the changes and updates.
As always, Ventra will keep you up to date on this and all issues impacting medical groups as they become available. Ventra will provide updates when the final rule is published including a webinar in early December. This webinar will provide a comprehensive overview of the 2025 PFS Final Rule, highlighting the fundamental changes and their implications for emergency medicine groups and individuals participating in the MIPS program.
Remember, Ventra is here to help you understand and navigate these changes. We’re committed to providing the support and guidance you need to make the best decisions for your group. Please don’t hesitate to reach out to Ventra’s MIPS Team with any questions you may have.
Erin Houck
Senior Director, Client Success Email Erin
Lance Mueller
Director of Healthcare Quality Email Lance
Greg Wertz
Manager of Regulatory Affairs
ADVOCATE RCM – A Division of Ventra Health
Email Greg
Webinar | Dec 10 at 3 PM CT
2025 MIPS Overview
What to Expect and Practical Tips for Success
Save Your SpotMore Information:
Learn more about the QPP proposals by reviewing the following 2025 QPP Proposed Rule Resources:
- CMS Press Release -HHS Proposes Physician Payment Rule to Drive Whole-Person Care and Improve Health Quality for All Individuals with Medicare
- 2025 Quality Payment Program Proposed Rule Fact Sheet and Policy Comparison Table –Provides an overview of QPP proposals and RFIs included in the CY 2025 Medicare Physician Fee Schedule (PFS) Proposed Rule and a comparison table contrasting existing policies with proposals.
- 2025 Proposed and Modified MVPs Guide – Highlights newly proposed MVPs and modifications to previously finalized MVPs, beginning with the 2025 performance year.
