MIPS 2025 reporting: 3-step guide

The Dermatological Care MIPS Value Pathway (MVP) is a streamlined reporting system designed specifically for dermatologists to meet MIPS requirements. CMS is designing MVPs to allow physicians to report on measures that are more relevant to their specialties in a structured manner. Unlike traditional MIPS, participation in an MVP for the 2025 performance year requires advance registration during the designated MVP Registration Window from April 1-Dec. 1, 2025.

Here’s how dermatologists and their staff can understand and participate in the Dermatological Care MVP.

What is the Dermatological Care MVP?

The Dermatological Care MVP is a specialized MIPS reporting pathway for dermatologists that focuses on dermatology-specific measures, such as skin cancer screenings and biopsy follow-ups. It streamlines reporting, reducing administrative tasks, and ensures reporting on the four MIPS categories: Quality, Cost, Promoting Interoperability (PI), and Improvement Activities (IA), unless exempt.

Am I required to participate in the MVP?

No, participation in the MVP is not currently required. MVPs are an optional reporting method, and clinicians can choose to participate either through MVPs or traditional MIPS. In the future, MVPs may become more central to the reporting process, but for now, participation remains voluntary.

Did the Academy participate in the development of this MVP?

The AADA repeatedly urged CMS not to launch this comprehensive MVP for dermatology, as it uses excessively broad measure sets that lack alignment and fails to provide meaningful feedback to enhance patient care. Despite these concerns, CMS has opted to proceed with a broad MVP for the specialty.

The AADA is committed to helping our members prepare for CMS’s future transition from traditional MIPS to MVPs, though the timing of that transition remains uncertain. The AADA will continue to advocate for reporting flexibility and minimal administrative burdens for dermatology practices. The Academy will also develop resources like this one to help dermatologists decide the right MIPS/MVP reporting strategy for them.

How can I participate in the MVP?

Unlike traditional MIPS, you must register in advance to report an MVP during the designated MVP Registration Window, which is April 1-Dec. 1, 2025 for the 2025 performance year. Learn more about the registration process at the Quality Payment Program (QPP) page on MVP registration.

Eligible clinicians can participate in the MVP individually, as a group, or as a subgroup. Subgroup reporting allows a group (TIN) to break into smaller subgroups for reporting purposes. While optional for 2025, subgroup reporting will be mandatory for multispecialty practices starting in 2026 if they choose to participate in MVPs. Multispecialty practices continuing with traditional MIPS will not be required nor permitted to form subgroups. Subgroup participation requires registration by Dec. 1, 2025.

What are the reporting requirements for the MVP in 2025?

The reporting requirements for MVPs in 2025 are as follows:

1. Quality

• Clinicians must submit 4 quality measures.

• MVP participants may select any 4 measures available within the MVP. CMS will evaluate performance only against clinicians reporting the same measure, whether through an MVP or traditional MIPS.

• At least 1 measure must be an outcome measure, or a high-priority measure if an outcome measure is not applicable.

• Outcome measures may include those calculated by CMS using administrative claims data, if available in the MVP, so long as the associated case minimum is met.

• MVPs include various collection types (Part B claims for small practices, CQMs, Qualified Clinical Data Registry [QCDR] Measures via DataDerm, and eCQMs). Small practices report available Part B measures, while others must report four measures, combining types if needed. CMS aggregates performance into a single quality score.

• QCDR measures in the MVP are only available through DataDerm. As with traditional MIPS, the performance year is the calendar year (Jan. 1-Dec. 31, 2025).

2. Improvement Activities

• Beginning with the 2025 performance year, clinicians, groups, and subgroups must attest to completing 1 improvement activity, if participating in an MVP.

• CMS has simplified the IA requirements by reducing the number of activities required and removing activity weightings.

• Similar to traditional MIPS, the performance period is a minimum of 90 continuous days between Jan. 1-Dec. 31, 2025.

• MVP participants can submit data through a qualified registry (QR) or QCDR such as DataDerm or manually via the secure QPP website.

3. Cost

• CMS will score only the cost measures included in the selected MVP if the clinician meets the case minimum. If a participant does not meet the minimum for any cost measure, the weight of this category will be redistributed to another category.

4. Population Health Measures

• CMS will evaluate MVP participants on 2 population health measures included in every MVP and use whichever measure results in the most favorable score. Similar to cost measures, CMS will evaluate performance on these measures using administrative claims data (i.e., no reporting required) and will only score the participant if they meet the measure’s case minimum. If the participant does not meet the case minimum, these measures will not count toward the final quality score.

• The 2 population health measures for 2025 are:

  • Hospital-Wide, 30-day, All-Cause Unplanned Readmission Rate

  • Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions

5. Promoting Interoperability

• Clinicians must report the same PI measures as under traditional MIPS, unless eligible for reweighting.

• Like traditional MIPS, the performance period for this category is a minimum continuous 180 days between Jan. 1-Dec. 31, 2025.

• MVP participants can submit data through a QR or QCDR such as DataDerm or manually via the secure QPP website.

How are measures scored in MVPs?

CMS determines quality measure achievement points by comparing performance on a quality measure to a measure benchmark. A measure will be scored only if:

• A benchmark exists.

• At least 20 denominator-eligible cases are reported.

• At least 75% of eligible cases are reported (data completeness).

If a reported measure does not meet these criteria, it will earn 0 points (except for small practices, as described below). For small practices, CMS will award 3 points for measures without benchmarks or that do not meet the case minimum.

The Cost, Promoting Interoperability, and Improvement Activities categories are generally measured and scored the same way regardless of whether participating in MVPs or traditional MIPS. However, as noted earlier, CMS will not score an MVP participant on a cost measure that is not listed as part of the MVP; whereas, under traditional MIPS, a clinician or group can be scored on any cost measure for which they meet the case minimum.

An MVP participant also will receive a final score based on the same performance category weights used in traditional MIPS, which are generally:

Non-Small Practices (16 clinicians or more)

• Quality: 30%

• Cost: 30%

• Promoting Interoperability: 25%

• Improvement Activities: 15%

Small Practices (15 clinicians or fewer)

• Quality: 40%

• Cost: 30%

• Promoting Interoperability: 0%

• Improvement Activities: 30%

The same performance category weight redistribution policies also apply across both pathways. For example, if an MVP participant meets the criteria for “hospital-based,” they will be exempt from having to satisfy the PI category.

Learn more about Dermatological Care MVP performance categories.

What are potential benefits of transitioning to MVP reporting early?

• Opportunity to familiarize with MVPs: Reporting MVPs early may help clinicians prepare for potential future changes in MIPS, offering a chance to adjust workflows and gain experience with the new system.

• More connected quality assessment:MVPs are developed with specific specialties or medical conditions in mind, providing a more integrated approach to evaluating care quality.

• Streamlined measures and activities: With a reduced set of measures and activities, MVPs aim to minimize complexity and administrative tasks, which may simplify the reporting process.

• Enhanced performance feedback: The streamlined set of measures enables more targeted performance feedback, allowing for comparisons among clinicians reporting the same MVP.

• Potential to reduce reporting burden: MVPs are designed to align with other CMS programs, such as Center for Medicare and Medicaid Innovation (CMMI) models, with the aim of reducing the overall reporting burden across programs.

• Specialty-specific feedback: MVP participants receive feedback tailored to their specialty, allowing for benchmarking against clinicians reporting the same MVP rather than across all MIPS participants.

What are the differences between traditional MIPS and the Dermatological Care MVP?

Here’s a chart summarizing the key differences between traditional MIPS and MVPs, highlighting the main distinctions in quality reporting, measure selection, and flexibility within the framework.

Can I submit data for both MIPS and MVPs, and will I receive multiple final scores?

Yes, you can submit data for multiple reporting options (e.g., MVP, traditional MIPS, APM), but each data set must be submitted separately. If using the same measure for multiple reporting methods, the data must be submitted twice. CMS will assign one final score per TIN/NPI, using the highest score achieved. For example, if your practice reports both an MVP and traditional MIPS as a group, your final score will be based on the higher of the two scores. As a reminder, MVP participants must register during the performance year in order to participate.

What are the reporting options for MVPs?

There are specific reporting mechanisms available to eligible clinicians, groups, and subgroups, offering flexibility to select the method that works best for their practice. The available reporting options include:

1. Claims-based reporting: This option is only available to small practices and allows clinicians to report through their Medicare Part B claims.

2. Registry reporting: Clinicians can use a Qualified Clinical Data Registry (QCDR), such as DataDerm, to report their measures and activities for MVPs.

3. Electronic Health Record (EHR) reporting: Reporting through an EHR system is another option available, which can streamline the process for those who use certified EHR technology.

4. CMS Web Interface: This is used for group reporting, available to groups with 25 or more eligible clinicians.

For additional details on reporting options and requirements, refer to the QPP Reporting Options page.

Are there small practice flexibilities for MVPs?

Small practices continue to benefit from flexibilities when reporting an MVP, similar to traditional MIPS. These reporting flexibilities include:

• Meeting quality reporting requirements by submitting all Medicare Part B claims measures within your chosen MVP, even if there are fewer than 4 measures.

• Earning 6 bonus points in the Quality performance category by submitting just 1 quality measure, as is the case with traditional MIPS.

• Receiving 3 points for quality measures that lack a benchmark or don’t meet case minimum requirements, again in line with traditional MIPS.

• Automatic re-weighting of the PI performance category when reporting an MVP, just as in traditional MIPS.

However, small practices do not benefit from reduced reporting requirements in the IA performance category when reporting an MVP. Starting in 2025, improvement activities will no longer have assigned weights, and all MVP participants, including small practices, will need to complete at least 1 improvement activity from those available within their chosen MVP, just like large practices.

Here is an example of how an eligible clinician can engage in the dermatologic MVP and earn the 75-point threshold.

* Note that the table above is for illustrative purposes only and assumes the MVP participant received a maximum or near-maximum performance score across all four categories.

Can I earn an incentive by participating in the MVP?

Yes, similar to traditional MIPS, to earn an incentive, you must aim to score above the 75-point threshold. The additional points you earn above 75 will contribute to performance-based incentives. The higher your score above the threshold, the greater your chances of receiving an incentive payment and achieving higher rankings in the program. To maximize your potential for an incentive, focus on reporting all eligible cases, meeting or exceeding the requirements for each measure, and ensuring you fulfill as many measures and activities as possible to increase your total points. However, remember MIPS is a budget-neutral program, meaning incentives depend on penalties collected from underperforming participants. Available incentive funds may vary yearly.

What happens if I fall short of the points required within an MVP, and is the impact different from traditional MIPS?

If you fall short of the required points in an MVP, the consequences are similar to those in traditional MIPS. You may not meet the performance threshold for the reporting period, which could result in a lower overall score. This, in turn, may affect your eligibility for incentive payments and could lead to negative payment adjustments (penalties). While the consequences are generally the same, MVPs differ from traditional MIPS in that they offer a more streamlined set of measures that are focused on specific specialties. This structure may make it easier for clinicians to meet the performance threshold compared to the broader, more complex measure set in traditional MIPS.

Do Extreme and Uncontrollable Circumstances (EUC) and hardship exemptions apply to MVPs?

Yes, EUCs and hardship exemptions do apply to MVPs. Participants in MVPs can request these exemptions in cases where they face significant challenges, such as natural disasters, pandemics, or other uncontrollable events that impact their ability to meet reporting requirements.

The process for requesting these exceptions is the same as for traditional MIPS. Eligible clinicians can apply for reweighting or exemptions through the QPP Exception Application system.

Applications can be submitted during the performance year or as part of the final submission, and if granted, CMS will adjust the reporting and scoring requirements accordingly.

What do I need to do to get started with the Dermatological Care MVP?

To get started with the Dermatological Care MVP, follow these steps:

1. Check eligibility

Confirm you qualify for MIPS by visiting the MIPS Eligibility Tool.

2. Review registration details and deadlines

Review the QPP page about MVP registration. Note that you can only register for an MVP during the registration window, from April 1-Dec. 1, 2025.

After all required MVP registration fields are completed in the Registration Portal, the “MVP Registration Status” will show as complete, and you can modify or delete your registration until Dec. 1, 2025.

3. Register for the MVP

Select the Dermatological Care MVP when registering for MIPS through the QPP Registration Portal.

4. Select measures

Choose 4 quality measures, ensuring at least 1 is an outcome measure.

5. Complete improvement activities

Complete and attest to at least 1 required improvement activity.

6. Choose collection type

Decide on how you want to collect quality data, such as claims-based reporting, a QCDR such as DataDerm, or EHR reporting. Remember, QCDR measures can only be reported through DataDerm.

7. Monitor Performance

Track your progress to make sure you meet the 75-point threshold.

8. Submit Data

Submit your data to CMS by March 31, 2026 for the 2025 performance year.

By completing these steps, you can successfully participate in the Dermatological Care MVP and meet MIPS requirements.

Where can I find additional information?

Learn more about MVPs through the QPP MVP page or through the QPP Resource Library.