Quality: Traditional MIPS Requirements

Quality: 2025 Performance Year Requirements

Score Weight

30% OF FINAL SCORE

This percentage can change due to: 

• Special statuses,
• Exception applications, or 
• Alternative Payment Model (APM) Entity participation.

Quality Measures

You must collect and submit measure data for the 12-month performance period (January 1 - December 31, 2025).

There are 5 collection types for MIPS quality measures:

• Electronic Clinical Quality Measures
   (eCQMs);
• MIPS Clinical Quality Measures (CQMs);
• Qualified Clinical Data Registry (QCDR) Measures;
• Medicare Part B Claims Measures; 
• Administrative Claims; and
• The Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey.

General reporting requirements are as follows:

• You’ll need to submit collected data for at least 6 quality measures (including one outcome measure or high priority measure in the absence of an applicable outcome measure), or a complete specialty measure set.
• For the 2025 performance period, you’ll need to report performance data for at least 75% of the denominator-eligible cases for each quality measure (data completeness), which will continue through the 2028 performance period. 
• You can submit measures from different collection types to fulfill the requirement to report data for at least 6 quality measures.

We’ll automatically calculate and score 4 administrative claims measures for individuals, groups, virtual groups, and APM Entities when such measures are applicable and if the individuals, groups, virtual groups, or APM Entities meet the requirements to be scored on the measure. The following are the 4 administrative claims measures automatically calculated and scored.

• Hospital-Wide, 30-Day, All-Cause Unplanned Readmission (HWR) Rate for the Merit-based Incentive Payment System (MIPS) Eligible Clinician Groups. (This measure is only applicable to groups and virtual groups).
• Risk-Standardized Complication Rate (RSCR) Following Elective Primary Total Hip Arthroplasty (THA) and/or Total Knee Arthroplasty (TKA) for Merit-based Incentive Payment System (MIPS).
• Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions.
• Risk-Standardized Acute Cardiovascular-Related Hospital Admission Rates for Patients with Heart Failure under the Merit-based Incentive Payment System (MIPS).

Specialty Measure Sets

If you choose to submit data for a specialty measure set, you must submit data on at least 6 quality measures within that set. If the specialty measure set contains fewer than 6 quality measures, you must submit data for each quality measure in the set.

CAHPS for MIPS Survey Measure

If a group, virtual group, or APM Entity participating in traditional MIPS registers for the CAHPS for MIPS Survey and meets the sampling requirements to administer the CAHPS for MIPS Survey, this measure may count as 1 of the 6 minimum required quality measures and may be used to meet the high priority measure quality requirement. Registration for the CAHPS for MIPS Survey is between April 1, 2025, and June 30, 2025.

For the 2025 performance period, registered groups, virtual groups, and APM Entities are required to contract with a CAHPS for MIPS Survey vendor to administer the survey in English and Spanish, using the survey templates provided by CMS.

We also recommend that groups, virtual groups, and APM Entities administer the other translations of the CAHPS for MIPS Survey provided by CMS (Cantonese, Korean, Mandarin, Portuguese, Russian, and Vietnamese) based on the language needs of their patients.

Note: Groups, virtual groups, and APM Entities will receive instructions from CMS on how to authorize a CMS-approved vendor after the registration period closes. CMS will produce your patient sample and send it to the vendor you authorize. Once you authorize a survey vendor, we’ll proceed with data collection, and you’ll be accountable for the costs associated with administering the survey.

After the close of the CAHPS registration period, some organizations electing to report the CAHPS for MIPS Survey may be identified by CMS as ineligible to report CAHPS due to insufficient patient sample size.

Data Submission

There are 3 submission types you can use for quality measures. The submission types are:

• Medicare Part B Claims (small practices only);
• Sign In to the QPP Website and Upload; and
• Direct Submission via QPP Submission 
  Application Programming Interface
  (API)

Determine which submission type is best for you based on how you intend to submit data (as a MIPS eligible clinician, group, virtual group, or APM Entity).

As a MIPS eligible clinician, you have the following options available to you:

As a representative of a group, virtual group, or APM Entity, you have the following options available to your group, virtual group, or APM Entity:

As a 

third party intermediary

, you have the following options available to you:

Data Aggregation

If you transition from one or more

If you're submitting eCQMs using multiple EHR systems, the submitting EHR system must be certified to align with the Office of the National Coordinator for Health IT’s (ONC’s) regulations by the time eCQM data is generated for submission.

Scoring Quality Measures

We determine measure achievement points by comparing performance on a measure to a measure benchmark.

If a measure can be reliably scored against a benchmark, it means:

• A benchmark is available;
• Case minimum criteria has been met (measure had a submission of at least 20 cases (for most measures)); and
• Data completeness criteria has been met (performance data reported for at least 75% of the denominator-eligible patients/cases).

Bonus Points

Bonus points are only available for small practices. Six bonus points will continue to be added to the quality performance category score for clinicians in small practices who submit at least one measure, either individually or as a group, virtual group, or APM Entity. This bonus isn’t added to clinicians, groups, or virtual groups who are scored under facility-based scoring.

New: Beginning in the 2025 performance period, we’re applying a complex organization adjustment to account for the organizational complexities facing APM Entities (including Shared Savings Program Accountable Care Organizations (ACOs)) and virtual groups when reporting eCQMs. We’ll add one measure achievement point for each submitted eCQM for an APM Entity or virtual group that meets data completeness and case minimum requirements. The adjustment may not exceed 10% of the total available measure achievement points in the quality performance category.

Quality Improvement Scoring

Individual MIPS eligible clinicians, groups, virtual groups, and APM Entities may earn up to 10 additional percentage points based on their improvement in the quality performance category from the previous year.

Facility-based Scoring

Facility-based scoring may be applied to facility-based clinicians, groups, and virtual groups. APM Entities aren’t eligible to receive facility-based status.

Facility-based scoring will be used for your quality and cost performance category scores when all the following conditions are met:

• You’re identified as facility-based;
• You’re attributed to a facility with a Fiscal Year (FY) 2026 Hospital Value-Based Purchasing (VBP) Program score (we won’t know this until the end of the 2025 performance period); and 
• The facility-based scoring methodology using your Hospital VBP Program score results in a higher final score than your final score calculated without the application of facility-based measurement.

Additional Resources