2025 MIPS for Anesthesia

The Centers for Medicare and Medicaid Services (CMS) released the final 2025 Quality Payment Program (QPP) rule. This rule outlines the participation of eligible clinicians and groups in the Merit-based Incentive Payment System (MIPS), Alternative Payment Models, and other QPP features during the 2025 performance year with a 2027 payment year. We will focus on the key updates you must know for successful reporting in 2025.

Physician Fee Schedule

For 2025, the anesthesia conversion factor (CF) is set at $20.3178, marking a 2.20% decrease from the 2024 CF of $20.7739. This decrease resulted from a temporary update that expired at the end of 2024. Anesthesia groups need to consider the potential financial implications of this change and adjust their budgets accordingly.

Merit-based Incentive Payment System (MIPS)

  • In 2025, the MIPS Performance Threshold remains at 75 points.
    • CMS estimates the 2025 median final score to be 86.42, with 77.5% receiving a positive payment adjustment and 15.5% receiving a negative one.
    • Scoring above 75 points results in a slight positive payment adjustment. A score below 75 points results in a negative payment adjustment.
  • The data completeness threshold remains at 75% for the MIPS Quality Performance Category through the CY 2028 performance period.

Improvement Activities

  • Clinicians, groups, and virtual groups with a Special Status must attest to one activity. Most anesthesia groups/clinicians have a special status. Check your 2025 MIPS eligibility to determine any Special Status.

All other clinicians, groups, and virtual groups must attest to two activities.

Cost

Some anesthesia groups/clinicians do get scored for Cost. CMS scores Cost measures based on your submitted claims data – no additional reporting is required. There is no episode-of-care Cost measure for Anesthesia, so most have Cost reweighted to the Quality performance category.

Promoting Interoperability (PI)

Most anesthesia groups/clinicians have PI reweighted to Quality owing to a Special Status like Non-Patient Facing. You may choose to report the PI category as it may improve your overall MIPS Score. Request a “Sample/Test” report for the group from each facility at your reporting level (group/individual). Allow plenty of time to ensure they can build the report if needed.

Quality Performance Category

CMS finalized the 2025 anesthesia quality measure set without any changes from 2024.

  • QID404 Smoking Abstinence
    • QID424 Perioperative Temperature Management,
    • QID430 Prevention of Post-Operative Nausea and Vomiting (PONV) – Combination Therapy,
    • QID463 Prevention of Post-Operative Vomiting (POV) Combination Therapy (Pediatrics),
    • QID477 Multimodal Pain Management 

Topped-Out Quality Measure Benchmarks (New for 2025)

Currently, each quality measure is scored based on performance within the measure. Deciles are assigned a points score, and highly topped-out measures are limited to a 7-point maximum.

CMS is removing the 7-point cap for scoring specific topped-out quality measures in specialty sets with limited measures. Four anesthesia measures are positively affected for 2025: QI424, QI430, QI463, and QI477. CMS will re-evaluate this list annually.

The new scoring methodology will score topped-out measures with limited options on a flat benchmark, resulting in a higher score for groups/clinicians reporting the measures. CMS will determine which measures to include in the flat-benchmarking methodology yearly.

For 2025, a performance rate of 99.0% will earn 9 points compared to below 7 in 2024.

Performance RateAvailable Points
84-85.9%1-1.9
86-87.9% 2- 2.9
88-89.9%3-3.9
90-91.9% 4-4.9
92-93.9%5-5.9
94-95.9%6-6.9
96-97.9%7-7.9
98-99.9%8-8.9
99-99.99%9-9.9
100%10

MIPS Value Pathways (MVPs)

For 2025, the Anesthesia MVP will continue to be available for Anesthesia with the same quality measures. CMS made a couple of changes to the Improvement Activities in the MVP:

  • Added IA_PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B.
  • Removed the IA_EPA_1: Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real-Time Access to Patients’ Medical Record
  • CMS removed the weights associated with the improvement activities in this MVP to be consistent with other policy changes.

You may want to consider reporting via an MVP and Traditional MIPS. Check with your MIPS vendor to ensure they support both options and that there are no additional fees.

Conclusion and Beyond MIPS

The CMS changes to the 2025 MIPS program are generally neutral to positive. The Performance Threshold and Data Completeness remain the same. The standard Anesthesia quality measures receive the flat-benchmarking scoring methodology that has the potential for higher scoring in the Quality performance category, providing an optimistic outlook for Anesthesia groups.

Anesthesia groups and clinicians should consider their 2025 MIPS eligibility and ROI when creating their 2025 Quality/MIPS Report Strategy. For many groups, reporting as a group has a negative ROI: the cost of reporting as a group > expected positive payment adjustment.

However, Ventra encourages groups to think beyond MIPS when it comes to quality outcomes tracking. Data collected for MIPS reporting can also be leveraged with your key stakeholders—facilities and payers. Quality outcomes can be used for value-based care contracts, credentialing/licensing, and stipend negotiations. Groups with strong QI programs are also likely to improve their professional satisfaction and increase their appeal to potential hires. This approach to QI empowers Anesthesia groups to take control of their quality outcomes and build stronger relationships with key stakeholders.

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