As healthcare continues its shift toward value-based care, the Merit-based Incentive Payment System (MIPS) remains a critical component for physician reimbursement. The Centers for Medicare & Medicaid Services (CMS) has released the 2025 Medicare Physician Fee Schedule Final Rule, bringing several significant updates to the Quality Payment Program (QPP). Understanding these changes is essential for healthcare providers seeking to maximize reimbursements while adapting to evolving regulatory requirements.

Stability Within Change

While MIPS continues to evolve, the 2025 program maintains certain foundational elements that provide stability for clinicians. Most notably, the four performance categories remain unchanged in their weighting:

• Quality (30%): Evaluates patient care quality through specialty-specific measures
• Cost (30%): Assesses cost efficiency based on claims data
• Promoting Interoperability (25%): Measures the use of certified EHR technology
• Improvement Activities (15%): Focuses on initiatives that enhance patient engagement

The performance threshold—the minimum score needed to avoid penalties—also remains at 75 points through 2027, providing consistency as practices adapt to other program changes. Similarly, the data completeness threshold for the Quality category holds steady at 75% through 2028.

“The maintenance of these thresholds offers valuable continuity for healthcare providers,” notes a healthcare compliance specialist. “It allows practices to focus on adapting to measure-specific changes without having to chase a moving target for baseline compliance.”

Quality Category: Evolution in Measurement

The Quality category sees significant updates for 2025, with seven new measures introduced and ten measures removed. The new additions emphasize diagnostics and public health priorities, including radiation dose evaluation in CT scans, COVID-19 vaccination tracking, and germline testing for ovarian cancer patients.

For specialty-specific practices, these changes vary in impact. Hospital Medicine physicians, for instance, will see minimal disruption, with their core set of four measures remaining unchanged:

• Heart failure: ACE Inhibitor/ARB/ARNI Therapy for LVSD
• Heart Failure: Beta Blocker Therapy for LVSD
• Advance Care Plan
• Documentation of Current Medications

Radiologists receive a notable scoring advantage in 2025. Previously, “topped out” quality measures that belong to measure sets with mostly topped-out measures will now be eligible for 10 achievement points rather than being capped at seven points. This adjustment addresses a long-standing concern in specialties where high performance had paradoxically limited scoring potential.

Cost Category: Recalibrated for Higher Scores

The Cost category undergoes significant methodology changes in 2025, continuing adjustments that began in 2024. CMS has recalibrated the scoring approach by benchmarking clinician performance against median cost thresholds rather than percentile rankings. Under this new methodology, the national median cost receives a score of 7.5 points, with participants scored based on their deviation from this median.

These adjustments are expected to result in higher cost scores for many participants, with CMS anticipating an additional 3.89 points in the Cost performance category for clinicians with at least one Cost measure.

Additionally, CMS has expanded the available cost measures, adding six new episode-based measures focused on chronic conditions:

• Respiratory Infection Hospitalization
• Chronic Kidney Disease
• End-Stage Renal Disease
• Kidney Transplant Management
• Prostate Cancer
• Rheumatoid Arthritis

Simplifying Improvement Activities

Perhaps the most welcome change for many clinicians is the simplification of the Improvement Activities (IA) category. CMS has eliminated the previous high/medium weighting system, making all activities worth equal points. This accompanies a reduction in the minimum activity requirements:

• MVP participants: One activity required
• Small practices: One activity required (previously two medium or one high)
• Large practices: Two activities required (previously four medium or two high)

This streamlining particularly benefits small practices and solo practitioners, who have historically faced disproportionate challenges with MIPS compliance. The reduced requirements allow these clinicians to focus on meaningful quality improvement rather than administrative reporting.

The Path Forward with MVPs

CMS continues its push toward MIPS Value Pathways (MVPs) as the future of the program. For 2025, six new MVPs have been introduced: Ophthalmology, Dermatology, Gastroenterology, Pulmonology, Urology, and Surgical Care. This expansion reflects CMS’s intention to eventually sunset traditional MIPS in favor of these specialty-focused reporting structures.

“The transition to MVPs represents a significant shift in how clinicians will engage with quality reporting,” explains a quality improvement director. “While traditional MIPS offers flexibility, MVPs create a more cohesive approach to measuring value in specific clinical contexts.”

For practices using modern EHR systems, MVP reporting can be streamlined through certified technology. NewCura’s solutions, for instance, include built-in support for quality measure tracking and submission, helping clinicians navigate the transition toward MVPs while maintaining compliance with current requirements.

Small Practice Considerations

The 2025 MIPS program presents both challenges and opportunities for small practices. On one hand, CMS projections indicate that 45.65% of solo practitioners and 20.93% of small practices may face penalties, compared to just 15.47% of all MIPS participants. The average median score for solo practitioners (75.00) sits precariously at the performance threshold, highlighting their vulnerability.

On the other hand, CMS has introduced several provisions to support these smaller entities:

• Reduced IA requirements (just one activity needed)
• Special status reweighting when appropriate
• Technical assistance programs
• New reweighting request option when third-party intermediaries fail to submit data

These accommodations acknowledge the unique challenges small practices face while preserving their participation in value-based care initiatives.

Physician Fee Schedule Impact

Beyond the MIPS program changes, clinicians should note the 2.83% decrease in the Medicare conversion factor, now set at $32.3465. This reduction resulted from the expiration of a temporary update at the end of 2024 and will affect payment calculations across services.

The financial impact will vary based on practice characteristics, including procedural volumes, site of service, and charge mix. Healthcare organizations should incorporate these adjustments into their financial planning for 2027, when the 2025 MIPS performance will affect reimbursements.

Planning for Success in 2025

Successfully navigating MIPS in 2025 requires strategic preparation. Healthcare organizations should consider these steps:

1. Evaluate Measure Applicability: Review the updated measure sets to identify those most relevant to your practice and patient population.
2. Assess Technology Readiness: Ensure your EHR system supports the required quality measures and can efficiently report data. NewCura’s solutions provide comprehensive support for MIPS reporting requirements, enabling seamless data capture and submission.
3. Consider MVP Adoption: Explore whether transitioning to an MVP makes sense for your specialty and practice structure, particularly as CMS moves toward making these mandatory.
4. Optimize Cost Performance: Review your cost measure reports to identify opportunities for improvement, as this category now offers enhanced scoring potential.
5. Streamline IA Reporting: Take advantage of the simplified activity requirements while selecting impactful initiatives that genuinely enhance patient care.
6. Leverage Available Support: Small practices should utilize CMS technical assistance resources and consider partnership with experienced reporting entities.

Looking Beyond Compliance

While MIPS compliance is essential for avoiding penalties, forward-thinking organizations recognize that quality reporting offers benefits beyond reimbursement. Data collected for MIPS can inform internal quality improvement initiatives, support value-based care contracts, and demonstrate excellence to patients and payers.

“We encourage groups to think beyond MIPS,” notes a quality improvement consultant. “The same data can be leveraged with facilities and payers, supporting value-based care contracts, credentialing, and licensing. Strong quality improvement programs also enhance professional satisfaction and appeal to potential hires.”

By approaching MIPS strategically rather than merely as a compliance exercise, healthcare organizations can transform regulatory requirements into opportunities for meaningful clinical and operational advancement. With the right preparation and technology support, the 2025 MIPS program can serve as a catalyst for improved patient outcomes and practice performance.

For healthcare providers seeking to optimize their MIPS strategy, comprehensive solutions like those offered by NewCura can simplify reporting while maximizing performance. As value-based care continues to evolve, proactive adaptation to these regulatory changes will be key to both financial success and clinical excellence.