MIPS 2025 FAQs

APM = (Advanced) Alternative Payment Model. A payment approach that gives additional incentive payments to professionals under ACO models, or those that bear more than the nominal amount of financial risk. Most dermatologists will not be eligible for this track. There are two types of APMs under MACRA: Advanced APMs, which exempt participating providers from MIPS and offer a 5% payment bonus, and MIPS APMs, which require some MIPS participation, but may result in a bonus payment from certain components of the MIPS performance score.

EP or EC = Eligible Professional / Eligible Clinician. Health professionals who are required to participate in either MIPS or an APM. Physicians (MD or DO), nurse practitioners (NP), physician assistants (PA), clinical nurse specialists, certified registered nurse anesthetists, and groups who bill under Medicare Part B. The preferred term under MACRA is EC.

EUC = A provision under MIPS that allows clinicians to be automatically reweighted to 0% in all performance categories if they are impacted by extreme and uncontrollable circumstances, such as natural disasters, public health emergencies, or other unforeseen events. This ensures they will not be penalized for failing to report MIPS data during those circumstances. Clinicians in affected areas will receive a neutral payment adjustment for the performance year.

MACRA = The Medicare Access and CHIP Reauthorization Act of 2015. MACRA is the 2015 law that replaced the flawed "SGR" or sustainable growth rate. It created the new incentive/penalty structure for Medicare Part B reimbursement beginning with 2017 payment. MACRA has two tracks: MIPS or APMs.

MIPS = The Merit-Based Incentive Payment System. One of the pathways providers may take under MACRA. Most dermatologists will be on the MIPS pathway. Providers earn positive or negative payment adjustments based on data submitted to CMS.

MVPs = MIPS Value Pathways. MVPs are the newest MIPS reporting option that you can use to meet your MIPS reporting requirements. Each MVP consists of a set of measures and activities specific to a particular specialty or medical condition. For 2025, the new MVP available for dermatologists is "Dermatological Care.” Learn more by visiting the QPP page on MVPs.

QCDR = Qualified Clinical Data Registry. A CMS-approved reporting mechanism that collects medical/clinical data for the purpose of quality reporting to federal pay-for-reporting programs. While originally created for PQRS, they are now used to support the MACRA Quality Payment Program (QPP). QCDRs can cover quality measures across multiple payers and are not limited to Medicare beneficiaries. They also include the ability to report non-MIPS (specialty-specific) measures. Learn more about DataDerm, the Academy's QCDR.

QPP = The Quality Payment Program, the CMS program that implements MACRA.

QR = Qualified Registry. A CMS-approved reporting mechanism that collects medical/clinical data for the purpose of reporting MIPS quality measures. QRs do not support non-MIPS measures. QRs may not offer specialists enough relevant measures to choose from, and they may not be best for long-term participation in the QPP.

You must participate in MIPS (unless otherwise exempt) if, in both 12-month segments of the MIPS Determination Period, you:

• Bill more than $90,000 for Part B covered professional services, and

• See more than 200 Part B patients, and

• Provide 200 or more covered professional services to Part B patients, and

• This is not your first year as a Medicare participating provider.

No, you are not automatically exempt but the MIPS program does offer several small practice bonuses/accommodations. Therefore, you are required to participate if you do not meet the low-volume threshold criteria. For more information on reporting accommodations for small practices and other special statuses, visit the QPP website.

No, if you meet the eligibility criteria, you must participate in MIPS. However, if you do not report any data or fail to meet the minimum requirements, you could be penalized with a negative payment adjustment.

No, MIPS is administered by CMS but includes all eligible encounters from all payers, not just Medicare encounters. However, if you are if you are a small practice reporting via claims or the CMS Web Interface, only Medicare Part B patients are included.

MIPS affects only Medicare Part B reimbursement. It does not directly impact reimbursements for other insurers or non-Medicare patients. However, participating in MIPS and improving your quality measures may improve overall practice efficiency, potentially benefiting all patient populations.

To only avoid the penalty (9%) you must score at least 75 points.

Eligible clinicians and practices are encouraged to adopt an EHR as minimum requirements continue to become stringent for the MIPS program.

See the complete reporting options table (PDF).

If you score below 75 points, you’ll face a penalty, which could result in up to a 9% reduction in your Medicare reimbursement rates for the 2027 payment year.

Achieving between 75.01-100 points will result in a positive payment adjustment based on a sliding scale as determined by CMS.

Eligible clinicians and practices are encouraged to adopt an EHR as minimum requirements continue to become stringent for the MIPS program.

See the complete reporting options table (PDF).

MIPS payment adjustments are based on your final score. The payment adjustments for a given year are determined using a sliding scale—clinicians who score below the performance threshold will receive negative adjustments, while those above the threshold will earn positive adjustments. CMS publishes the final adjustment factors for each performance year.

Each clinician’s MIPS score is individual; however, group practices can choose to report data at the group level. If reporting at the group level, the group’s performance will be used to calculate the individual clinicians' scores. Keep in mind that even if the group reports, individual clinicians may still face penalties or rewards based on their individual performance.

While it is not required to have an EHR to participate in MIPS, it has become increasingly difficult to avoid the penalty or achieve an incentive without an EHR. If you do not have a certified EHR, you should either implement one or be approved for an EHR exemption. Visit the Academy's EHR Resource Center and DataDerm to learn more to learn more about EHRs.

Yes, if you're in a small practice (15 or fewer clinicians), you can report MIPS data via Medicare Part B claims. However, be sure to meet the data completeness requirements (75% of eligible patients) to avoid penalties and ensure full credit.

If you miss the MIPS reporting deadline, you will not be able to submit data for that performance year. CMS will assign you a 0% score for each category you didn’t report on, which could lead to a negative payment adjustment for the following payment year. It's crucial to track deadlines and submit your data on time to avoid penalties.

Once the reporting period has ended and data has been submitted, you cannot make changes to your submission. However, if you discover an error before the final submission deadline, you can correct it through the MIPS portal or by submitting a resubmission. Be sure to review your data carefully before submission.

Yes, CMS provides an Extreme and Uncontrollable Circumstances (EUC) exception for those affected by disasters or emergencies. Clinicians in affected areas can apply for reweighting of performance categories, resulting in a neutral payment adjustment. For 2025, the EUC policy applies to California wildfire-affected counties.

If an eligible clinician participates in MIPS, their MIPS score is tied to their individual performance, not their practice. This means that if they leave their current practice and join a new one, the MIPS score earned during their previous practice will still impact their Medicare reimbursement rates for the following payment years.

For example, if a clinician earns a score in 2025 that affects their 2026 and 2027 reimbursements, that score will follow them to their new employer. The payment adjustment (positive, neutral, or negative) based on that score will apply to their Medicare reimbursements at their new place of employment.

Use the MIPS Step-by-Step Guide to walk you through reporting for MIPS 2025.