Preparing for 2025 MIPS and the new dermatological care MVP
Answers in Practice
By Oliva Barry, Manager, Practice Management, April 1, 2025
Each month, DermWorld tackles issues “in practice” for dermatologists. This month, practice management staff discuss what to expect for MIPS 2025.
MIPS program timeline
In November, CMS released the final rule for the Quality Payment Program (QPP), outlining the requirements for the 2025 Merit-based Incentive Payment Systems (MIPS) program performance year.
Among the updates, CMS introduced a new Dermatological Care MIPS Value Pathway (MVP) for optional reporting during the 2025 reporting period. MVPs were designed to streamline reporting by organizing existing MIPS measures and activities into more focused sets that target specific specialties or medical conditions and offer a slight reduction in reporting burden compared to traditional MIPS. While MVPs will remain optional for 2025, it’s recommended to familiarize yourself with this new participation pathway as CMS has expressed its intent to phase out traditional MIPS and potentially make MVPs mandatory by 2029. For the 2025 performance year, dermatologists might want to consider participating in both traditional MIPS and an MVP since CMS will use the most favorable score to determine your 2027 MIPS payment adjustment.
Whether you choose to stay in traditional MIPS or transition to an MVP, your success will rely on the adoption and meaningful use of certified electronic health record technology (CEHRT), unless exempt. Not only will CEHRT help you meet the Promoting Interoperability category requirements, but it will also streamline the reporting of quality measures and improve your overall MIPS performance.
To simplify your reporting process and ensure you’re meeting all the necessary requirements, consider enrolling in the AAD’s CMS-certified DataDerm™ registry. This tool integrates with your EHR, making it easier to report quality measures, track performance, and optimize your MIPS outcomes. Don’t miss the opportunity to learn how DataDerm can help you stay on track and improve your practice’s performance.
To learn more about this year’s MIPS requirements and the new Dermatological Care MVP, explore the details below.
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Payment adjustment
MIPS payment adjustments are applied to Medicare Part B covered professional services two years following a given MIPS performance year. MIPS-eligible clinicians who fail to participate in 2025 will receive the maximum penalty of 9% in 2027, as legislated by law. Since MIPS is a budget-neutral program, the maximum positive payment adjustment for the highest performers will not be known until total penalties have been determined.
Eligibility criteria
MIPS eligibility is determined based on numerous factors, including:
The date you enrolled as a Medicare provider (if you enrolled in Medicare on or after Jan. 1, 2025, you are not eligible to participate in MIPS for the 2025 performance year); and
Qualifying APM Participant (QP) status (QPs are exempt from MIPS).
Clinicians who are otherwise eligible for MIPS must also exceed the following low-volume threshold during both 12-month segments of the MIPS determination period (unchanged):
Bill more than $90,000 for Medicare Part B covered professional services, and
See more than 200 Medicare Part B patients, and
Provide 200 or more covered professional services to Medicare Part B patients
Eligible clinicians or groups who meet or exceed at least one or two, but not all three, of the low-volume threshold criterion noted above are not required to participate in MIPS. However, they have the option to “opt-in” to MIPS (but not MVPs), in which case they must comply with MIPS reporting requirements and will be subject to a MIPS payment adjustment. Certain clinicians may also be eligible to “voluntarily report,” in which case they would receive limited performance feedback, but no payment adjustment.
More information about MIPS eligibility determinations is available from CMS.
Clinicians may check whether they are required to participate in MIPS on the QPP website. Keep in mind that MIPS eligibility and compliance is specific to each TIN/NPI combination. Clinicians who provide services under multiple TINs should check each TIN/NPI combination for eligibility and reporting requirements as they apply to each practice.
Performance thresholds
The threshold to avoid the penalty has remained the same. The minimum score to avoid the penalty is 75 points. The additional MIPS payment adjustment for exceptional performance ended after the 2023 performance period.
Reporting types
Eligible clinicians will be able to continue to participate in MIPS individually, as groups, as virtual groups, or as part of an APM Entity. Note: For the 2025 performance period, the virtual group election deadline was Dec. 31, 2024.
MIPS and MVP 2025 reporting snapshots
Performance categories
All category weights have remained the same. However, see additional details below for each. Also note, CMS has clarified and codified its multiple submissions rule. If the submission types are different, CMS will use the highest score. If the submission types are the same, CMS will use the most recent submission.
Quality 30%
Data completeness threshold is 75%.
(NEW) Removal of MIPS 137 Melanoma: Continuity of Care — Recall System.
(NEW) Addition of MIPS 509 Melanoma: Tracking and Evaluation of Recurrence.
(NEW) Removal of 7-point topped out scoring cap for select measures, including 397: Melanoma Reporting and 440: Skin Cancer: Biopsy Reporting Time — Pathologist to Clinician. Updated performance benchmarks for 2025 quality measures should be available through the QPP Resource Library.
Improvement activities 15%
Performance period: 90-day continuous performance period between Jan. 1 – Dec. 31, 2025. The last day to start a 90-day performance period is Oct. 3, 2025.
(NEW) Removal of improvement activity weightings to simplify and streamline the reporting requirements for the performance category.
(NEW) Traditional MIPS reporting for IA:
Clinicians, groups, and virtual groups that are part of a small practice, rural, non-patient facing, or health professional shortage area special status must attest to one activity.
All other clinicians, groups, and virtual groups must attest to two activities.
At least 50% of the clinicians billing under a TIN must complete the same improvement activity for at least 90 consecutive days for the group to receive credit; however, individual clinicians in the group are not required to all complete that improvement activity over the same 90-day period.
Promoting interoperability 25%
Performance period: 180-day continuous performance period between Jan. 1 – Dec. 31, 2025. The last day to start a 180-day performance period is July 5, 2025.
To comply with this category, clinicians must report on a set of measures, as well as attest to a series of statements regarding HIT safety, security, and interoperability. Additional information about these requirements is available.
As a reminder, you must use EHR technology that meets federal certification criteria to receive credit in this category. Since CMS makes technical changes to the criteria each year, it is important to confirm annually whether your EHR is on the Certified Health IT Product List (CHPL). The AADA offers the following resource, EHR, that fits your needs and optimizes your practice workflow.
Cost 30%
(NEW) CMS finalized improvements to cost measure specifications and scoring methodologies, which apply starting with the 2024 performance period. These revisions are expected to raise cost scores for most clinicians.
As a reminder, there are no reporting requirements for this category since CMS automatically calculates MIPS cost measures based on administrative claims data. Clinicians and groups are only scored on a cost measure if they are attributed a minimum number of patients. Case minimums are specific to each cost measure.
Performance category reweighing due to third-party intermediary submission failures
Starting with the 2025 performance year, CMS will allow clinicians to request reweighting for the Quality, Improvement Activities, and/or Promoting Interoperability categories if a third-party intermediary to whom the clinician delegated data submission fails to submit data on time.
Small practice accommodations
All small practice (15 or fewer clinicians) accommodations remain the same in 2025:
Exclusive access to quality measures available for reporting via Part B claims
3 points awarded for quality measures that do not meet the 75% data completeness requirement, do not meet the case minimum, or lack a benchmark (non-small practice clinicians receive 0 points on these measures)
6 bonus points added to the numerator of the Quality category
Automatic exemption (no application required) from the Promoting Interoperability performance category. CMS will redistribute the weight of this category to other MIPS performance categories:
When only Promoting Interoperability is reweighted, Quality will be 40%, Cost 30%, and Improvement Activity 30%
When Promoting Interoperability and Cost are both reweighted, Quality will be 50% and Improvement Activity 50%
Note: CMS considers small practices as a special status. See more information on reporting accommodations for small practices and other special status categories.
QPP hardship exceptions
Extreme and uncontrollable circumstances (EUCs)
MIPS eligible clinicians, groups, and virtual groups may submit an application to reweight any or all MIPS performance categories if they’ve been affected by extreme and uncontrollable circumstances that impact these performance categories. To apply, visit the QPP website.
Promoting Interoperability performance category hardship exception
MIPS eligible clinicians, groups, and virtual groups may also submit an application requesting a hardship exception from the Promoting Interoperability category for the following specified reasons:
You have decertified EHR technology (must be decertified under the Office of the National Coordinator for Health Information Technology’s [ONC] Health IT Certification Program).
You have insufficient internet connectivity.
You face extreme and uncontrollable circumstances such as a disaster, practice closure, severe financial distress, or vendor issues.
You lack control over the availability of CEHRT.
Simply lacking the required CEHRT does not qualify you for reweighting. Also note that if you are already automatically exempt from this category (e.g., due to small practice status), you do not need to submit the hardship application. Apply for the Promoting Interoperability Hardship Exception.
Practice management resources
Check out the Academy’s compliance resources.
MIPS value pathways (MVPs)
The new MVP for dermatology is called “Dermatological Care.” MVP participation is optional in the 2025 performance year.
Eligible clinicians report on a reduced number of quality measures (reporting on 4 measures versus 6) and improvement activities (attest to 1 activity regardless of special status). Like traditional MIPS, MVP participants must meet all the requirements of the Promoting Interoperability category (unless exempt) and are automatically scored on claims-derived cost and population health measures if case minimums are met.
Another unique feature of MVPs is the ability to report via subgroups, which are subsets of clinicians from the same TIN and may be useful for clinicians in multispecialty groups. Note that subgroup reporting will become mandatory for multi-specialty practices that opt to participate via MVPs starting in 2026. Subgroup reporting is not permitted in traditional MIPS.
Clinicians can participate in both traditional MIPS and the Dermatological Care MVP, with their score determined by whichever pathway results in a higher performance score. Both traditional MIPS and MVPs can be reported via AAD’s DataDerm.
Note that unlike traditional MIPS, MVP participation requires registration. The registration window for the 2025 performance year is April 1 – Dec. 1, 2025.
For more information on MVPs, visit the QPP website.
Review the MVP requirements and details for the Dermatological Care MVP.
To optimize your performance and ensure compliance for the 2025 MIPS year, participating in both traditional MIPS and the Dermatological Care MVP is a strategic choice. Early involvement in the MVP allows you to adapt to future changes while providing crucial feedback that helps the Academy advocate for dermatology. By utilizing the Academy’s resources, such as the CMS-certified DataDerm registry, you can simplify reporting, improve efficiency, and reduce penalties, while positioning your practice for success as MVPs become the primary reporting pathway.
Find more practice management resources in the Practice Management Center.
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