With MIPS 2024 officially behind us, it’s time to turn the page and prepare for what’s ahead in MIPS 2025. Like the first signs of spring, this new performance year brings important updates: new quality measures, revised benchmarks, additional MVPs, and updated reporting requirements for the Improvement Activities category. While some familiar elements remain, much of the program is evolving. In this post, we break down what these changes mean for:
EHRs to better equip MIPS-eligible clinicians using their services
Hospitals and Provider Organizations to adapt as MVPs and APMs reshape the reporting landscape
Let’s dig into what’s new and how you can stay ahead this performance year.
Some Things Stay the Same: MIPS Performance Threshold and Data Completeness
Before we go deep into all that's new, it’s worth noting what hasn’t changed. Despite many updates for 2025, the MIPS performance threshold holds steady at 75 points, just as in previous years. Likewise, data completeness requirements remain at 75% across all collection types, a standard that will continue through the 2028 performance year.
While it may feel reassuring to have a few constants, meeting these benchmarks is no easy task. With the rest of the program evolving rapidly around them, maintaining compliance and scoring well will demand more precision, strategy, and support than ever before.
Quality Category: Raising the Bar for 2025
While some aspects of MIPS 2025 remain familiar, the Quality category has seen some of the most significant shifts, especially around data submission, MVP options, and specialty considerations. Staying ahead here will be critical.
Quality Data Submission Criteria: More Scrutiny, Higher Stakes
CMS is turning up the pressure for quality data submissions. Here’s what you need to know:
New and second-year Quality Measures must include at least one numerator and denominator data point to be considered valid. Partial data will no longer cut it.
Incomplete submissions will face stricter penalties. Missing key fields like practice ID, date, activity ID, measure ID, or CMS EHR Certification ID? Your submission will not be scored.
Multiple submissions from different organizations for the same clinician or group? CMS will score each and apply the highest score. This is a critical shift for specialties like radiology, ophthalmology, and hospital-based providers, where working across multiple locations is common.
Within a single organization, the most recent submission for a collection type will overwrite earlier ones. (eCQMs only overwrite eCQMs, MIPS-CQMs overwrite MIPS-CQMs, and Claims measures can only be submitted once.)
Why this Matters
Measure selection is now a strategic decision that can make or break your quality score, especially for multi-specialty practices. With the Quality category tied to a full-year reporting period, organizations must identify their measures early and monitor performance proactively. If you haven’t started already, now is the time.
Pro Tips for Quality Data Submission Changes
Lock in quality measures by Q2 to allow time for adjustments.
Audit data feeds now. Missing fields like Practice ID can void submissions.
Track clinician affiliations to prevent submission conflicts across locations.
MIPS Value Pathways (MVPs): CMS Signals a Clearer Direction
CMS is continuing to expand and emphasize MVPs as the future of MIPS reporting. Although MVP participation remains voluntary for now, the groundwork is being laid for an eventual transition away from Traditional MIPS.
What’s New for MVPs in 2025:
Six new MVPs have been introduced, bringing the total to 21 MVPs available for the 2025 performance year:
Complete Ophthalmologic Care MVP
Dermatological Care MVP
Gastroenterology Care MVP
Optimal Care for Patients with Urological Conditions MVP
Pulmonology Care MVP
Surgical Care MVP
(We'll link to our 10-step MVP guide here.)
Specialty Spotlight: Neurology
CMS has merged the Optimal Care for Patients with Episodic Neurological Conditions MVP and Supportive Care for Neurodegenerative Conditions MVP into a single streamlined pathway: Quality Care for Patients with Neurological Conditions MVP. This broader framework simplifies reporting for Neurology practices, offering a more comprehensive selection of Quality Measures and Improvement Activities under one umbrella.
Pro Tips for MVP Strategy
Review MVP options early to prepare for future reporting and transitions.
Neurology practices: Take advantage of the merged pathway for better flexibility and scoring.
A New Twist: Population Health Measure Calculation
Starting in 2025, clinicians participating via MVPs no longer need to select a population health measure at registration manually. Instead, CMS will automatically evaluate all eligible population health measures and apply the highest-scoring one to a clinician’s final Quality score. (Yes, another small, but strategic advantage for MVP adopters.)
Updated Quality Measure Inventory: New, Gone, and Modified
CMS continues refining the Quality Measure inventory to better align with specialty care and evolving clinical standards:
7 new measures have been added
10 measures have been retired
66 measures have been substantively modified
3 Measures Restricted to MVP Use Only
Three popular Quality measures have been restricted to MVP use only. In 2025, these measures will no longer be available for the traditional MIPS submissions:
Breast Cancer Screening – Measure 112 / CMS 125v13
Colorectal Cancer Screening – Measure 113 / CMS 125v13
Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-up Plan – Measure 128 / CMS 69v13
If your current strategy relies on these measures under traditional MIPS, you’ll need to rethink your approach now. Waiting any longer could mean losing points and lower scores.
Pro Tips for Measure Selection and Monitoring
Plan for MVP-only measures now if your strategy relies on Breast Cancer, Colorectal, or BMI screenings.
Track performance quarterly to catch issues early and stay on course for full-year reporting.
Quality Category: The Key to Maintaining a Competitive Edge
The updates to the Quality category are more than just administrative. They represent a real shift toward higher expectations and tighter margins for success. Planning early, selecting the right measures, and adjusting your strategy for MVPs where appropriate will be critical steps in staying competitive.
Improvement Activities Category: A Simpler, Yet Tighter Landscape
Change is in the air for the Improvement Activities category in 2025. While things may appear simpler at first glance, the pressure to plan early and align across groups has never been greater.
No More Activity Weighting: Streamlined, but Demanding
Starting 2025, CMS is eliminating activity weightings for the Improvement Activities category. This is intended to simplify scoring and reduce the number of activities clinicians must attest to earn full credit. However, the margin for error is now razor-thin. Here’s how it breaks down:
Traditional MIPS Reporting
Small practices, rural clinicians, non-patient-facing clinicians, and those in Health Professional Shortage Areas (HPSA) must attest to one activity.
All other clinicians and groups must attest to two activities.
MVP Reporting
All MVP participants only need to attest to one activity to meet the requirement.
Sounds easier, right? Here's the catch:
If reporting as a group, every clinician must be aligned and report the same activities. Waiting until the final quarter to scramble for eligible activities will no longer cut it.
Pro Tips for Improvement Activities
Align group activities by July to avoid a last-minute scramble for selecting the best 90 consecutive days for reporting.
Use tools like MyMipsScore to track and lock in activities early for smoother reporting.
New, Modified, and Removed Improvement Activities
Along with the updated reporting structure, CMS has also fine-tuned the Improvement Activities inventory:
2 new activities have been added
1 existing activity has been modified
4 activities have been removed
Critical Update
One of the most popular Improvement Activities, 24/7 Access to Clinicians with Patient Records, has been officially removed. For many organizations, this was an easy win. Its removal means practices must rethink their Improvement Activity strategy for 2025 and find alternatives that meet both eligibility and operational feasibility.
Pro Tip: Double-check your Improvement Activity lineup. If your 2024 plan relied on 24/7 Access to Clinicians, you’ll need a replacement ready. Waiting could jeopardize your full credit for the category.
Bottom Line
While CMS’s goal is to simplify the Improvement Activities category, the burden shifts to better planning and coordination. The load is lighter for small practices and MVP participants. However, early measure selection, clinician education, and system tracking are essential for larger groups to ensure success in 2025 and beyond.
Promoting Interoperability Category: Subtle Tweaks, Serious Implications
At first glance, the Promoting Interoperability (PI) category appears relatively stable for 2025. However, underneath the surface, several significant changes could trip up unprepared clinicians and organizations. Precision in reporting will matter more than ever.
New Cybersecurity Measure Introduced
CMS is raising the bar for digital system security. A new cybersecurity measure has been added to enhance system resilience and strengthen patient data protection. Staying compliant will now involve not just interoperability but also security excellence.
Updated Automatic Reweighting Policies
Clinical social workers will no longer receive automatic reweighting in 2025. Moving forward, automatic reweighting will only apply to:
ASC-based clinicians
Hospital-based clinicians
Non-patient-facing clinicians
Small practices
Clinicians who relied on automatic reweighting in the past must re-evaluate their PI strategy to ensure compliance.
Mandatory Data Submission Criteria Tightened
Submissions must now include:
Complete performance data
Required attestations
A valid CMS EHR Certification ID
Submissions missing any of these elements will be invalidated and scored as incomplete. No exceptions.
New Flexible Submission Rule
CMS will now accept and retain all submissions, automatically counting the highest score as the final result. This offers organizations more flexibility: you can submit earlier and make necessary corrections. CMS will honor your best attempt by the submission deadline.
Pro Tip: Utilize the Flexibility. With CMS now accepting multiple submissions and applying the highest score, organizations should treat the submission process as iterative, not a one-shot event. Submitting early leaves room for corrections without risking penalties.
Bottom Line
Even though PI looks relatively unchanged on the surface, underestimating the new requirements would be a critical mistake. Cybersecurity compliance, tighter data validation, and evolving reweighting rules mean organizations must stay sharp, secure, and proactive.
Cost Performance Category: New Measures, New Challenges
The Cost Performance category might not require manual reporting, but that doesn’t mean it’s hands-off. In fact, for 2025, CMS is sharpening its focus, and organizations that ignore these changes risk hidden score penalties.
Six New Cost Measures Introduced
CMS has added six new episode-based cost measures for the 2025 performance year, specifically targeting under-reported areas. This expansion aims to provide a more comprehensive view of healthcare spending and outcomes across different specialties.
Here are the 6 new 2025 Cost Measures to be aware of:
Respiratory Infection Hospitalization (Acute Inpatient)
Chronic Kidney Disease (Chronic Condition)
End-Stage Renal Disease (Chronic Condition)
Kidney Transplant Management (Chronic Condition)
Prostate Cancer (Chronic Condition)
Rheumatoid Arthritis (Chronic Condition)
Important Policy Update: Cost Measure Exclusions
CMS has also revised the cost measure exclusion policy. If significant changes or data errors affect a measure during the performance period, that measure can now be excluded from scoring. This offers a layer of protection, but only if you're closely tracking how your services align with CMS methodologies.
No Reporting, but Monitoring is Critical
While it’s true that CMS calculates the Cost score automatically from submitted Medicare claims (no direct clinician reporting required), that doesn't mean organizations can afford to be passive.
Understanding the cost rubrics behind each measure and actively managing Medicare-billed costs associated with these conditions and procedures is essential to protect your overall MIPS score.
Pro Tip: Monitor and Review
Know your cost measures inside and out. Review the clinical activities tied to each new cost measure now, especially if your providers handle the acute and chronic conditions monitored by CMS. Small cost overruns can add up quickly and impact your final score.
Bottom Line
The Cost category in 2025 demands greater financial stewardship, even if you’re not submitting data manually. The organizations that proactively align clinical care with cost-efficient practices will position themselves to maintain or improve their MIPS performance scores.
Wrapping Up: Preparing for MIPS 2025 Success
By staying ahead of these changes, clinicians, practices, and organizations can better navigate the evolving MIPS landscape and optimize their performance scores for future reimbursement adjustments.
The 2025 performance year is not just a continuation of old patterns; it's a clear signal that MIPS is becoming more complex, more specialized, and less forgiving. Success will depend on early preparation, smarter measure selection, closer monitoring, and strategic adaptation to the new frameworks like MVPs.
Action Checklist: Setting Yourself Up for MIPS 2025 Success
Here’s your action plan for a smoother, more successful 2025:
✅ Start early. Finalize Quality Measures, Improvement Activities, and MVP strategy by mid-year to stay on track for year-long and 90-day reporting windows.
✅ Audit your data pipelines. Confirm all critical submission fields (Practice ID, Measure ID, EHR Certification ID) are accurately captured.
✅ Submit early. Take advantage of CMS’s new flexibility. Submit as soon as you’re ready, and refine if needed.
✅ Benchmark performance quarterly. Don’t wait until year-end. Monitor progress each quarter to catch and correct underperformance early.
✅ Evaluate MVP options. Even if you stick with traditional MIPS, understanding the 21 available MVPs will prepare you for the upcoming transition.
✅ Replace retired measures and activities. Identify new alternatives for the measures and activities CMS has removed or restricted to the MVP pathways.
✅ Prepare for cybersecurity compliance. Incorporate the new cybersecurity measure into your Promoting Interoperability reporting strategies.
✅ Track your Medicare costs. Understand and monitor claims activity tied to the new Cost measures. Avoid surprises on your final Cost category score.
✅ Align group activities. Ensure all clinicians in a group agree on the same Improvement Activities well before the 90-day minimum window.
✅ Lean on experts and proven tools. With margins for error shrinking, proven solutions like MyMipsScore, and expert guidance can make the difference between penalties and incentives.
Ready to Maximize Your MIPS Success?
Navigating MIPS 2025 doesn’t have to be overwhelming. Darena’s MyMipsScore is designed to guide you through the MIPS program, maximize measure selection, analysis, and reporting options, and ensure a smooth, efficient journey from start to finish.
With over nine years of experience simplifying MIPS reporting for EHRs across specialties and healthcare organizations of all sizes, we bring unmatched expertise to the table.
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Offload the burden of certifying and maintaining ONC certification criteria (c)(1-4) by partnering with Darena Solutions. Through MyMipsScore, you can offer your customers seamless access to:
Certified electronic clinical quality measure (eCQM) reporting
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🔷For Hospitals and Physician Practices
If you’re returning to MIPS after time away under the Extreme Uncontrollable Circumstances (EUC) exception, or if you are unsure how to avoid penalties in this new landscape, we’re here to help.
Maximize your MIPS performance, simplify compliance, and ensure your team is ready to meet the evolving demands of Quality, Cost, Promoting Interoperability, and Improvement Activities categories. Our tailored approach ensures you get the right strategy, right measures, and right support every step of the way.