Frequently Asked Questions

The CMS Merit-based Incentive Payment System (MIPS) is a value-based Medicare reimbursement program under the Quality Payment Program (QPP) that adjusts reimbursement payments based on performance in four categories: Quality, Promoting Interoperability, Improvement Activities, and Cost. Eligible clinicians, including physicians and nurse practitioners, report data annually, and their scores determine whether they receive positive, neutral, or negative payment adjustments. High performers may earn bonuses, while low performers face penalties. MIPS aims to improve care quality, enhance patient outcomes, and control healthcare costs by incentivizing efficient, high-value care.

In 2025, practices will have difficulty earning positive payment adjustments using standard MIPS measures. Standard Qualified Payment Program (QPP) measures are no longer favorable for many specialities and certain measures have been eliminated. It’s still possible to avoid a penalty in 2025, but you will need near-perfect scores to get there. This is why we offer Qualified Data Registry (QCDR) measures to help providers maximize MIPS payment adjustments.

CMS continues to offer an Extreme and Uncontrollable Circumstances Exception in 2025. Extreme and uncontrollable circumstances are defined as rare events entirely outside of your control and the control of the facility in which you practice. These circumstances would: • Cause practices to be unable to collect information necessary to submit for a MIPS performance category; • Cause a practice to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the quality performance category for 3 months), and/or; • Impact normal processes, affecting performance on cost measures and other administrative claims measures. Providers must demonstrate that they have been affected by extreme and uncontrollable circumstances that impact their MIPS performance categories.

It's not too late! Guidance Analytics is still taking on new clients for 2025.

In recent years, CMS granted EUCs to many providers because of COVID-19 and a major ransom/malware attack. Neither one is expected to significantly prevent MIPS submissions in 2025. With a greater proportion of providers submitting this year, we expect a greater volume of negative payment adjustments. This will enable higher positive payment adjustments for providers who perform well on MIPS.