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Source: Centers for Medicare & Medicaid Services

The Centers for Medicare & Medicaid Services (CMS) recently issued its Calendar Year (CY) 2025 Medicare Physician Fee Schedule (PFS) Proposed Rule, which includes proposed policies for the Quality Payment Program (QPP).

The Notice of Proposed Rulemaking (NPRM) includes proposals for the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs), as well as several Requests for Information (RFIs).

Specifically, CMS is proposing policies that:

  • Continue the development and maintenance of MVPs
  • Establish the APM Performance Pathway (APP) Plus quality measure set
  • Update the MIPS measure/activity inventories and scoring methodologies.

Finally, CMS is proposing a small number of policies intended to maintain stability within the MIPS program through the established performance threshold and data completeness criteria.

2025 Policy Highlights

Key QPP policies that CMS is proposing in the 2025 PFS Proposed Rule include:

  • Introducing six new MVPs for the 2025 performance period that are related to ophthalmology, dermatology, gastroenterology, pulmonology, urology, and surgical care.
  • Creating APP Plus, an additional quality measure set under the APP, which would include the six measures currently in the APP quality measure set and incrementally incorporate the remaining five Adult Universal Foundation quality measures for a total of 11 measures by the 2028 performance period/2030 payment year.
  • Maintaining the current performance threshold policies, leaving the performance threshold set at 75 points for the 2025 performance period.
  • Keeping the 75% data completeness criteria through the 2028 performance period.

Submit a Formal Comment by Monday, September 9

You must officially submit your comments in one of the following ways:

  • Electronically, through Regulations.gov
  • Regular mail
  • Express or overnight mail.

Comments are due no later than 5 p.m. ET on Monday, September 9.

For More Information

Learn more about the QPP proposals by reviewing the following 2025 QPP Proposed Rule Resources:

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