A Review of the 2025 Proposed Rule for the Anesthesia MIPS Pathway

By Lance Mueller
Director of Healthcare Quality

On July 10th, CMS released the 2025 Physician Fee Schedule (PFS) Proposed Rule. The Proposed Rule includes proposals for the Quality Payment Program (QPP), the Merit-based Incentive Program (MIPS), and Advanced Alternative Payment Models (APMs).

Overall, CMS is proposing policies that:

• Continue the development and maintenance of MIPS Value Pathways (MVPs)
• Establish APM Performance Pathway (APP) Plus quality measures 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

Overall Highlights

• CMS is introducing six new MVPs related to ophthalmology, dermatology, gastroenterology, pulmonology, urology, and surgical care.
• Category weights remain the same (30% Cost, 30% Quality, 25% Promoting Interoperability, and 15% Improvement Activities).
• CMS suggests implementing defined topped-out benchmarks for topped-out measures in specialty sets affected by limited-measure choice.
• CMS has yet to determine when MVPs will replace Traditional MIPS.

Anesthesia Highlights

• The Anesthesiology measure set remains unchanged.
• The Anesthesia MVP continues to evolve, with CMS proposing to remove two IAs from the MVP – IA_CC_2: Implementation of improvements that contribute to more timely communication of test results and IA_EPA_1: Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real-Time Access to Patient’s Medical Record.

How will the proposed changes affect my MIPS Reporting?

The proposed changes are generally positive for Anesthesia groups and individuals participating in the MIPS program. With data completeness and the steady performance threshold, you will clearly understand your standing in 2025 based on your 2024 performance, providing a sense of reassurance and optimism.

The Anesthesia MVP continues to provide an additional method for MIPS reporting. MVP participation requires registering through your QPP account. MVP participants report four quality measures, a slight benefit over traditional MIPS reporting.

Retaining previously topped-out measures ensures anesthesia clinicians have plenty of quality measures to report. CMS would annually determine and publish a list of topped-out measures that would have the 7-point cap removed and be subject to the proposed defined topped-out measure benchmark.

Table #67 in the Proposed Rule includes the following Anesthesia CQMs:

• 424 MIPS CQM Perioperative Temperature Management
• 430 MIPS CQM Prevention of Post-Operative Nausea and Vomiting (PONV) – Combination Therapy
• 463 MIPS CQM Prevention of Post-Operative (POV) – Combination Therapy (Pediatrics)
• 477 MIPS CQM Multimodal Pain Management

Impact: Including these measures significantly benefits anesthesia groups/clinicians, improving their chances of avoiding a negative payment adjustment.

Removing the 7-point scoring cap benefits Anesthesia, as many clinical quality measures are topped out and 7-point limited. Removing the 7-point cap will increase scoring on quality measures, which is beneficial as the Quality Performance Category is 85% of the MIPS score for most.

Example Defined Topped Out Measure Benchmark

Measure Achievement Points	Performance Rate
1 – 1.9	84 – 85.9%
2 – 2.9	86 – 87.9%
3 – 3.9	88 – 89.9%
4 – 4.9	90 – 91.9%
5 – 5.9	92 – 93.9%
6 – 6.9	94 – 95.9%
7 – 7.9	96 – 97.9%
8 – 8.9	98 – 99.9%
10	100%

Impact: Most of the anesthesia quality measures benefit from this updated scoring methodology:

• In 2024, 100% performance is 7 points. The proposed change would award 10 points (+3).
• In 2024, for CQM #463, 98% performance is 2.2 points. In 2025, CMS would award 8 points – a considerable improvement.

Including these measures significantly benefits anesthesia groups/clinicians, improving their chances of avoiding a negative payment adjustment.

How should I prepare my group for 2025 MIPS Reporting?

Later this year

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.

Ventra will quickly evaluate and communicate the final rule to you, 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 anesthesia groups and individuals participating in the MIPS program.

In the next 90 days

You should access your QPP account to view your 2024 MIPS Eligibility for each clinician. CMS provides the Quality Payment Program Access User Guide. Most anesthesia providers don’t meet the MIPS Low-Volume Threshold and are not required to participate in MIPS – they are not MIPS Eligible Clinicians. CMS will make the initial 2025 MIPS Eligibility file available in early December and the final 2024 MIPS Eligibility file. Once you know your clinician’s MIPS Eligibility, you can make informed, data-driven decisions about participating and reporting for the MIPS Program and your ROI.

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.

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.

From ASA:

• CMS Proposes Reduced Physician Payments in 2025; Maintains Anesthesiology Quality Payment Program Features | American Society of Anesthesiologists (ASA) (asahq.org)