MIPS archive

Eligibility criteria

The low volume threshold remains the same as in 2025 and includes three aspects of covered professional services:

• Allowed charges

• Number of Medicare patients who receive services

• Number of services provided

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.

The opt-in policy also remains the same. It allows physicians or groups who meet one or two of the low volume threshold criteria to opt-in to participate in MIPS and receive a final score and payment adjustment.

Payment adjustment

The 2025 performance period payment adjustment remains at 9%, applied to reimbursements in 2027.

Minimum threshold

Minimum points needed to avoid penalty: 75 points (no change).

Maximum threshold

The additional MIPS payment adjustment for exceptional performance ended after the 2023 performance period.

MIPS category breakdowns

Quality: 30% of MIPS score

• No change in category weight.

• 195 quality measures available for 2025.

• Removal of MIPS 137 Melanoma: Continuity of Care—Recall System (NEW).

• Addition of MIPS 509 Melanoma: Tracking and Evaluation of Recurrence (NEW).

• Data completeness remains at 75%.

  • Small practices (15 providers or fewer) receive 3 points for not meeting data completeness.

  • Large practices (16 providers or more) receive 0 points for not meeting data completeness.

• Performance period: Jan. 1 – Dec. 31, 2025.

• Submission methods: claims (for small practices), registry, QCDR such as the Academy’s

  DataDerm, or EHR.

• Multiple submissions rule (NEW): CMS will take the highest score if the submission type is different. CMS will take the most recent submission if the submission type is the same.

Improvement Activities (IA): 15% of MIPS score

• No change in category weight.

• 104 improvement activities for 2025.

• 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.

• Performance period: 90-day continuous performance period between Jan. 1 – Dec. 31, 2025.

• Added two new activities, modified one existing, and removed four existing improvement activities.

• Group participation threshold remains the same (50% participation of clinicians in group)

• Submission methods: CMS or QCDR.

• Multiple submission rule for IA (NEW):CMS will take the highest score if the submission type is different. CMS will take the most recent submission if the submission type is the same.

Promoting Interoperability (PI): 25% of MIPS score

• No change in category weight.

• Performance period: continuous 180-days between Jan. 1 – Dec. 31, 2025.

• Submission methods: registry, QCDR, EHR.

• Data submission must include CMS EHR Certification ID (CEHRT ID) from the Certified Health IT Production List (CHPL) (no change from 2024).

• Multiple Submission rule for PI (NEW): CMS will calculate a score for each submission and assign the highest of the scores.

Cost: 30% of MIPS score

• No change in category weight.

• No action required by the eligible clinician.

• A maximum cost improvement score of 1 percentage point as established in 2023.

Performance category reweighing due to third-party intermediary submission failures

CMS now allows clinicians to request reweighting for Quality, IA, or PI if a third-party intermediary to whom the clinician delegated data submission fails to submit data on time.

Reporting type

Individual: Under an NPI number and TIN where they reassign benefits; report via claims, registry, or EHR.

Group: Two or more clinicians (by NPIs) who have reassigned their billing rights to a single TIN; report via claims, registry, or EHR.

• Small practices, excluding those participating in MIPS as part of a virtual group, must submit data as a group in any performance category to indicate that they wish to be scored as a group for Medicare Part B claims.

Small practice accommodations

Accommodations for small practices include:

• 3 points for measures that do not meet data completeness of 75%.

• Claims-based reporting available.

• 6 bonus points added to numerator of Quality category.

• Automatic redistribution of the PI performance category weight for any small practice that does not submit data for the performance category.

MIPS Value Pathways (MVPs)

MIPS Value Pathways (MVPs) are a new reporting option developed by CMS to streamline how clinicians meet MIPS reporting requirements. MVPs are tailored to specific specialties, such as dermatology. They allow clinicians to focus on relevant performance measures for their practice. CMS hopes this approach will reduce reporting complexity and ensure that performance is assessed based on specialty-specific criteria. The new MVP for dermatology is called “Dermatological Care.”

• MVP participation is optional in the 2025 performance year.

• 6 MVPs are available for voluntary reporting in 2025, including one for dermatology.

• Clinicians report from a limited set of MIPS quality measures, including one outcome or high-priority measure, are scored on a cost measure only if the case minimum is met, and report IA from a limited list, while PI is reported as in traditional MIPS.

• Clinicians also may participate in MVPs via subgroups, where some but not all of the clinicians within a practice report an MVP. Subgroups may be especially useful for clinicians in multispecialty groups.

• Clinicians can participate in both traditional MIPS and the dermatology 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 Clinical Data Registry.

• Learn more by visiting the QPP page on MVPs.

QPP hardship exceptions

Extreme and uncontrollable circumstances (EUCs)

• Aligns EUCs with extraordinary circumstance exceptions (ECE) for automatic application when appropriate. This means CMS will automatically apply hardship exceptions to clinicians impacted by extraordinary circumstances, such as natural disasters or widespread disruptions caused by cyberattacks.

• Application-based EUCs also available as needed.

PI performance category hardship exception

• Automatic redistribution of the PI performance category weight for any small practice that does not submit data for the performance category.

• Applications also available as needed.

Telehealth

• Continues to allow clinicians who render telehealth services from their homes to list their practice address instead of their home address on their Medicare enrollment through Dec. 31, 2025.

• Continues to allow direct supervision by a supervising practitioner through real-time audio and video interaction telecommunications through Dec. 31, 2025, while permanently allowing it for a subset of services.

• Continues to allow teaching physicians to use audio-visual real-time communication technology to be present when the resident furnishes Medicare telehealth services in all residency training locations through the end of 2025; the teaching physician and resident do not have to be co-located.

• Starting Jan. 1, 2025, two-way, real-time audio-only communication will satisfy the requirement for an interactive telecommunications system under specific circumstances when a patient cannot use or does not consent to using video technology. However, the distant site practitioner must still have audio-video capabilities. As part of the 2025 final rule, CMS clarified that no additional documentation is needed.

The telehealth flexibilities for originating site and geographic restrictions, which were introduced during the COVID-19 public health emergency and extended through 2024 by Congress, will end unless Congress acts before the Dec. 31, 2024 deadline.

Additional information

• CMS 2025 final rule fact sheet

• Full text of the 2025 Final Rule

• 2025 quality measure selection tool

Related Academy resources