Unlock the intricacies of the 2025 CMS final ruling on the Quality Payment Program with insights from Aaron Higgins of Strategic Healthcare Partners. Get ahead of the curve with the crucial performance threshold of 75 points needed to dodge penalties and the revamped scoring system allowing up to 10 points for full compliance on topped-out measures. As the MIPS program evolves into the more streamlined and specialty-specific MIPS Value Pathways, discover how this shift can benefit your practice with the introduction of new MVPs and modifications, especially in cancer and heart disease care. Through our conversation, you'll gain clarity on the 75% data completeness requirements extending through 2028, the addition of seven new quality measures, and the removal of ten measures, providing a comprehensive view of the changes that await healthcare professionals.
Don't miss out on delving deeper into our podcast archives at shpllc.com/podcast, and join the ongoing conversation by connecting with us on Facebook and LinkedIn. We invite your questions and comments to further enrich our discussions and explore the ever-evolving landscape of healthcare together.
QPP 2025 Final Rule Fact Sheet:
https://qpp-cm-prod-content.s3.amazonaws.com/uploads/3057/2025-QPP-Policies-Final-Rule-Fact-Sheet.pdf
MIPS Value Pathways (MVP) 2025:
https://qpp-cm-prod-content.s3.amazonaws.com/uploads/3058/2025-Finalized-MIPS-Value-Pathways-Guide.pdf
Full 2025 QPP Final Rule:
https://www.federalregister.gov/public-inspection/2024-25382/medicare-and-medicaid-programs-calendar-year-2025-payment-policies-under-the-physician-fee-schedule
Visit our website
Like us on Facebook
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Follow on Linkedin
Send an email contact@shpllc.com
Production © Strategic Healthcare Partners, LLC.
All rights reserved.
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Transcript
Episode Transcript
Available transcripts are automatically generated. Complete accuracy is not guaranteed.
Jason (00:00):
Hello, it's Jason Crosby with SHP.
Welcome to another episode ofBeyond the Stethoscope Vital
Conversations with SHP.
Today we have a quickconversation with our very own
Aaron Higgins, who's going torecap some of the highlights
from the recent 2025 finalruling that just came out
Opportunity wording.
There being quick conversation.
If you know Aaron, he can kindof go on and on, but he's going
(00:23):
to give it a shot.
How are you doing, aaron?
Aaron (00:25):
I'm pretty good, and I resemble that remark, jason,
most certainly.
Yeah, so every year at the endof the year, everybody gets
excited because something bigand fat will drop into our laps
every, every Thanksgiving, andthat is not Santa Claus, it's
(00:50):
the QPP final rule.
Well, it's bundled into all ofthe CMS final rules for the year
Starting the next calendaryears of 2025.
Every year there's alwayschanges to MIPS, to the quality
payment program overall, andkind of one of the bigger shifts
that we've seen the last coupleof years is that CMS has really
(01:11):
just started to call it all QPP, because they do all these
other changes, not just MIPS.
But every year we've done somekind of big podcast or show and
tell about the changes.
Well, this year we're going totry it a little bit different.
So, yes, challenge accepted,jason.
I'm going to try to keep thisvery short and just the
(01:32):
highlights, and in our shownotes we will link to all the
sources for this so you can godive deeper if you need to.
Okay, so I think the biggestthing that folks need to be
aware of is that CMS is reallysticking to that performance
threshold.
So that performance thresholdmeans you need to score 75
(01:56):
points or greater to avoidpenalty.
If you score exactly 75 points,you get zero.
So you don't get a penalty.
You don't get any sort ofreward.
75 points is still the goal Toaid in that, because some people
are still struggling,particularly with some specialty
types, really finding goodmeasures.
They are changing the waymeasures get topped out.
(02:18):
So previously, measures thatwere topped out because
everybody was doing it were onlyearning you three points in the
quality category and that madeit really challenging.
You would have to submit awhole lot more measures to get
to your full quality.
So now it's scaled.
The details of that scaling isin the document that we're going
(02:40):
to link to in the show notes.
It's kind of complicated.
You have to go and look at it.
You can now earn up to 10points but you have to earn 100%
on those measures.
So if you do participate in atopped out measure, you can get
more points.
That's good.
It's going to help you withyour hitting your overall
performance threshold of 75points.
Overall Data completeness alsoisn't changing there.
(03:03):
What data completeness means isthe percentage of patients seen
, and you recorded their data,regardless of what type of
patient it is, and they havethat set at 75%.
They are maintaining thatthrough 2028.
They had talked about 100% andthey've scaled that back down to
75%.
Managed care contracting doesnot have to be a hassle, and
(03:27):
they've scaled that back down to75%.
Managed care contracting doesnot have to be a hassle.
At Strategic HealthcarePartners, we specialize in
negotiating and managingcontracts with payers, ensuring
you receive your fairreimbursement for the services
you provide.
Don't get shortchanged.
Let SHP handle the toughnegotiations so you can focus on
your patients.
Learn more at shplccom.
Jason (03:51):
Another topic that continuously comes up every year
with us are MVPs right?
So what new ones are coming outfor the 25 performance period?
And then what changes have beenmade to existing MVPs?
Aaron, yeah.
Aaron (04:06):
So the MVPs, the MIPS value pathways is the way the
whole MIPS program is evolving.
By 2028, so three years fromnow everybody will be moving
from what's called traditionalMIPS over to the MVPs.
To facilitate that, cms isrolling out new MVPs.
(04:26):
Now, mvps all slightly differfrom each other, but they're
essentially four qualitymeasures that you have to do
promoting interoperability, whatthey are calling a population
health measure, and then thecost measures that are
associated with your specialty.
The nice thing about the MVPsis that it takes away the huge
smorgasbord of options that canbe overwhelming to a practice.
(04:50):
They're also scaledappropriately for a practice of
different sizes so 15 or fewerclinicians, so small practices
and that sort of thing.
So they are introducing somenew MVPs.
Again, all of this will belinked in the show notes.
They're also making somemodification to the existing
MVPs, such as advancing cancercare and advancing care for
(05:12):
heart disease.
They've gone back and they'veretooled some of those metrics
within.
So if you've done an MVP in thepast or are interested in doing
that, getting away from thetraditional MIPS line I highly
recommend taking a look at theMVPs for 2025.
You have until late 2025 todecide between the two of them.
But even then there's a littlecatch.
(05:34):
They are now allowing you tosubmit both traditional MIPS and
MVPs in your transition year,and then they will give you your
score based off of which oneperforms better.
So if you want to go to allthat extra effort, you can.
Unless you're a large practice,I don't see a lot of benefit
for it To piggyback adding andrevising of measures.
Jason (05:55):
Tell us what new quality measures have been added and
those that have been removed for25, and then what changes have
been made to existing ones aswell.
Aaron (06:04):
Yeah.
So we have seven new qualitymeasures.
They are all mostly focusedaround chemotherapy.
Unless you're in thechemotherapy world, the cancer
world, these measures aren'tprobably going to apply to you.
They have removed 10 measuresAgain.
All these are going to be inthe show notes.
This is a quick conversation,I'm not going to dive into them.
And they have made asubstantive change to 66 of them
(06:28):
.
So, just like every year, ifyou've already picked your
measures, you're reallycomfortable with these.
You're doing well at them.
Go back and make sure theyhaven't been changed.
Sometimes they've substantivelychanged some very popular
measures and people who aredoing well one year are doing
terrible the next.
Looking at some of these changes, they're for the better and
(06:49):
should help you perform betterin those measures and kind of
pivoting on the measures isimprovement activities.
Now, the changes they've madeto improvement activities.
They've introduced two new ones, they've modified one and then
they have removed a total offour.
Now those four that they haveremoved are actually very
(07:11):
popular.
In fact, one of them isextremely popular and that is
the availability of your EHR24-7-365.
The reason why CMS removed it isbecause, a everybody was doing
it and B it was too easy.
Essentially, if you have remoteaccess to your EHR and let's be
(07:31):
honest, who doesn't these daysyou could qualify for saying you
did this improvement activity.
Cms knows this and so they'veremoved it.
So if you were banking on thisimprovement activity, I'm sorry
you're going to have to changeit up for next year.
But another thing too, with theimprovement activity is just to
kind of pivot.
They've done away with themedium and high weighting.
(07:51):
Now if you are a small practiceso 15 or fewer clinicians you
only have to pick oneimprovement activity.
If you are not a small practice, you have to pick two.
Now there's some other criteriatoo that allow you to pick one.
If you qualify for that, take alook again in the show notes.
Jason (08:13):
All right, shifting gears , reporting of the electronic
clinical measures.
How will the new complexorganization adjustment affect
the APM entities, virtual groupsand such?
Aaron (08:26):
Well, first off, cms knows that complex patients are
more expensive.
They also have seen a trendamongst ACOs and other advanced
payment models shedding theirspecialty groups because their
specialty groups were draggingdown the average score.
Cms doesn't like that.
(08:46):
They see a problem with it, sothey are adjusting the scoring.
(09:13):
Talk to your APM, see how willthe changes to scoring affect
their decisions going forward.
But this will be for the 2027year.
So even though the performanceyear is 25, there's not any
benefits seen until 2027.
So that still may make someAPMs want to shed some of their
(09:36):
specialties out of that, andwe've seen that, jason.
We've seen some bigger ACOsdropping specialties altogether
and CMS is trying to stem thetide of that.
Jason (09:48):
Yeah, that makes sense.
You know, when QPP firststarted out, cost was that sort
of gray area folks weren't sureabout.
So what changes have been madeto the cost measure scoring
methodology for the 24 period?
Aaron (10:02):
Well, it is still a mystery wrapped in an enigma.
The cost category is receivingsome changes.
Again, cms is revising theirmethodologies, adjusting the
formulas a little bit, making ita little easier for practices
to achieve, because they knowit's one of those things that's
completely out of the practicescontrol 95% of the time.
(10:23):
So they are making someadjustments there based off of
feedback that they've receivedas well as the performance that
they've done in the past.
So they're also introducingsome new measures over there.
So hopefully that will make iteasier for practices to achieve
the cost measures.
Jason (10:42):
You know what.
We've kind of run up on time.
We call this a quickconversation for a reason.
Aaron, you did a fantastic job.
I got to say I'm impressed.
That's probably the mostcondensed conversation we have
ever had, but impressive butawesome info, as usual.
And to our listeners.
As Aaron said at the beginning,we'll put a bunch of
(11:02):
information in the show notes.
You'll find everything you needthere and you know how to find
us.
If you need any QPP info, don'tcontact me, contact aaron.
You'll find all our info onshplccom.
Aaron, thanks for the uh quickconversation.
Hey, you too.
We'll talk to you later.
Aaron (11:21):
All right, bye-bye this has been an episode of beyond
the Stethoscope VitalConversations with SHP.
Your hosts today have been me,aaron Higgins.
Jason (11:37):
And me, jason Crosby.
This is a production ofStrategic Healthcare Partners.
Our executive producers areMike Scribner and John Crew, our
editor is Nyla Wiebe and oursocial media manager is Jeremy
Miller, with Boost by Design,transcription by a robot and
tweaked by me, a human, jason.
Aaron (11:56):
Crosby, you can visit our podcast archive on our website
shplccom slash podcast, andthere you can learn more about
the services and productsoffered by SHP.
Jason (12:09):
You can also find us on social media, including Facebook
and LinkedIn, where you cansend us questions and even leave
comments about this episode.
Aaron (12:20):
Thank you.
Hello, it's Jason Crosby with SHP.
Welcome to another episode ofBeyond the Stethoscope Vital
Conversations with SHP.
Today we have a quickconversation with our very own
Aaron Higgins, who's going torecap some of the highlights
from the recent 2025 finalruling that just came out
Opportunity wording.
There being quick conversation.
If you know Aaron, he can kindof go on and on, but he's going
(00:23):
to give it a shot.
How are you doing, aaron?
Aaron (00:25):
I'm pretty good, and I resemble that remark, jason,
most certainly.
Yeah, so every year at the endof the year, everybody gets
excited because something bigand fat will drop into our laps
every, every Thanksgiving, andthat is not Santa Claus, it's
(00:50):
the QPP final rule.
Well, it's bundled into all ofthe CMS final rules for the year
Starting the next calendaryears of 2025.
Every year there's alwayschanges to MIPS, to the quality
payment program overall, andkind of one of the bigger shifts
that we've seen the last coupleof years is that CMS has really
(01:11):
just started to call it all QPP, because they do all these
other changes, not just MIPS.
But every year we've done somekind of big podcast or show and
tell about the changes.
Well, this year we're going totry it a little bit different.
So, yes, challenge accepted,jason.
I'm going to try to keep thisvery short and just the
(01:32):
highlights, and in our shownotes we will link to all the
sources for this so you can godive deeper if you need to.
Okay, so I think the biggestthing that folks need to be
aware of is that CMS is reallysticking to that performance
threshold.
So that performance thresholdmeans you need to score 75
(01:56):
points or greater to avoidpenalty.
If you score exactly 75 points,you get zero.
So you don't get a penalty.
You don't get any sort ofreward.
75 points is still the goal Toaid in that, because some people
are still struggling,particularly with some specialty
types, really finding goodmeasures.
They are changing the waymeasures get topped out.
(02:18):
So previously, measures thatwere topped out because
everybody was doing it were onlyearning you three points in the
quality category and that madeit really challenging.
You would have to submit awhole lot more measures to get
to your full quality.
So now it's scaled.
The details of that scaling isin the document that we're going
(02:40):
to link to in the show notes.
It's kind of complicated.
You have to go and look at it.
You can now earn up to 10points but you have to earn 100%
on those measures.
So if you do participate in atopped out measure, you can get
more points.
That's good.
It's going to help you withyour hitting your overall
performance threshold of 75points.
Overall Data completeness alsoisn't changing there.
(03:03):
What data completeness means isthe percentage of patients seen
, and you recorded their data,regardless of what type of
patient it is, and they havethat set at 75%.
They are maintaining thatthrough 2028.
They had talked about 100% andthey've scaled that back down to
75%.
Managed care contracting doesnot have to be a hassle, and
(03:27):
they've scaled that back down to75%.
Managed care contracting doesnot have to be a hassle.
At Strategic HealthcarePartners, we specialize in
negotiating and managingcontracts with payers, ensuring
you receive your fairreimbursement for the services
you provide.
Don't get shortchanged.
Let SHP handle the toughnegotiations so you can focus on
your patients.
Learn more at shplccom.
Jason (03:51):
Another topic that continuously comes up every year
with us are MVPs right?
So what new ones are coming outfor the 25 performance period?
And then what changes have beenmade to existing MVPs?
Aaron, yeah.
Aaron (04:06):
So the MVPs, the MIPS value pathways is the way the
whole MIPS program is evolving.
By 2028, so three years fromnow everybody will be moving
from what's called traditionalMIPS over to the MVPs.
To facilitate that, cms isrolling out new MVPs.
(04:26):
Now, mvps all slightly differfrom each other, but they're
essentially four qualitymeasures that you have to do
promoting interoperability, whatthey are calling a population
health measure, and then thecost measures that are
associated with your specialty.
The nice thing about the MVPsis that it takes away the huge
smorgasbord of options that canbe overwhelming to a practice.
(04:50):
They're also scaledappropriately for a practice of
different sizes so 15 or fewerclinicians, so small practices
and that sort of thing.
So they are introducing somenew MVPs.
Again, all of this will belinked in the show notes.
They're also making somemodification to the existing
MVPs, such as advancing cancercare and advancing care for
(05:12):
heart disease.
They've gone back and they'veretooled some of those metrics
within.
So if you've done an MVP in thepast or are interested in doing
that, getting away from thetraditional MIPS line I highly
recommend taking a look at theMVPs for 2025.
You have until late 2025 todecide between the two of them.
But even then there's a littlecatch.
(05:34):
They are now allowing you tosubmit both traditional MIPS and
MVPs in your transition year,and then they will give you your
score based off of which oneperforms better.
So if you want to go to allthat extra effort, you can.
Unless you're a large practice,I don't see a lot of benefit
for it To piggyback adding andrevising of measures.
Jason (05:55):
Tell us what new quality measures have been added and
those that have been removed for25, and then what changes have
been made to existing ones aswell.
Aaron (06:04):
Yeah.
So we have seven new qualitymeasures.
They are all mostly focusedaround chemotherapy.
Unless you're in thechemotherapy world, the cancer
world, these measures aren'tprobably going to apply to you.
They have removed 10 measuresAgain.
All these are going to be inthe show notes.
This is a quick conversation,I'm not going to dive into them.
And they have made asubstantive change to 66 of them
(06:28):
.
So, just like every year, ifyou've already picked your
measures, you're reallycomfortable with these.
You're doing well at them.
Go back and make sure theyhaven't been changed.
Sometimes they've substantivelychanged some very popular
measures and people who aredoing well one year are doing
terrible the next.
Looking at some of these changes, they're for the better and
(06:49):
should help you perform betterin those measures and kind of
pivoting on the measures isimprovement activities.
Now, the changes they've madeto improvement activities.
They've introduced two new ones, they've modified one and then
they have removed a total offour.
Now those four that they haveremoved are actually very
(07:11):
popular.
In fact, one of them isextremely popular and that is
the availability of your EHR24-7-365.
The reason why CMS removed it isbecause, a everybody was doing
it and B it was too easy.
Essentially, if you have remoteaccess to your EHR and let's be
(07:31):
honest, who doesn't these daysyou could qualify for saying you
did this improvement activity.
Cms knows this and so they'veremoved it.
So if you were banking on thisimprovement activity, I'm sorry
you're going to have to changeit up for next year.
But another thing too, with theimprovement activity is just to
kind of pivot.
They've done away with themedium and high weighting.
(07:51):
Now if you are a small practiceso 15 or fewer clinicians you
only have to pick oneimprovement activity.
If you are not a small practice, you have to pick two.
Now there's some other criteriatoo that allow you to pick one.
If you qualify for that, take alook again in the show notes.
Jason (08:13):
All right, shifting gears , reporting of the electronic
clinical measures.
How will the new complexorganization adjustment affect
the APM entities, virtual groupsand such?
Aaron (08:26):
Well, first off, cms knows that complex patients are
more expensive.
They also have seen a trendamongst ACOs and other advanced
payment models shedding theirspecialty groups because their
specialty groups were draggingdown the average score.
Cms doesn't like that.
(08:46):
They see a problem with it, sothey are adjusting the scoring.
(09:13):
Talk to your APM, see how willthe changes to scoring affect
their decisions going forward.
But this will be for the 2027year.
So even though the performanceyear is 25, there's not any
benefits seen until 2027.
So that still may make someAPMs want to shed some of their
(09:36):
specialties out of that, andwe've seen that, jason.
We've seen some bigger ACOsdropping specialties altogether
and CMS is trying to stem thetide of that.
Jason (09:48):
Yeah, that makes sense.
You know, when QPP firststarted out, cost was that sort
of gray area folks weren't sureabout.
So what changes have been madeto the cost measure scoring
methodology for the 24 period?
Aaron (10:02):
Well, it is still a mystery wrapped in an enigma.
The cost category is receivingsome changes.
Again, cms is revising theirmethodologies, adjusting the
formulas a little bit, making ita little easier for practices
to achieve, because they knowit's one of those things that's
completely out of the practicescontrol 95% of the time.
(10:23):
So they are making someadjustments there based off of
feedback that they've receivedas well as the performance that
they've done in the past.
So they're also introducingsome new measures over there.
So hopefully that will make iteasier for practices to achieve
the cost measures.
Jason (10:42):
You know what.
We've kind of run up on time.
We call this a quickconversation for a reason.
Aaron, you did a fantastic job.
I got to say I'm impressed.
That's probably the mostcondensed conversation we have
ever had, but impressive butawesome info, as usual.
And to our listeners.
As Aaron said at the beginning,we'll put a bunch of
(11:02):
information in the show notes.
You'll find everything you needthere and you know how to find
us.
If you need any QPP info, don'tcontact me, contact aaron.
You'll find all our info onshplccom.
Aaron, thanks for the uh quickconversation.
Hey, you too.
We'll talk to you later.
Aaron (11:21):
All right, bye-bye this has been an episode of beyond
the Stethoscope VitalConversations with SHP.
Your hosts today have been me,aaron Higgins.
Jason (11:37):
And me, jason Crosby.
This is a production ofStrategic Healthcare Partners.
Our executive producers areMike Scribner and John Crew, our
editor is Nyla Wiebe and oursocial media manager is Jeremy
Miller, with Boost by Design,transcription by a robot and
tweaked by me, a human, jason.
Aaron (11:56):
Crosby, you can visit our podcast archive on our website
shplccom slash podcast, andthere you can learn more about
the services and productsoffered by SHP.
Jason (12:09):
You can also find us on social media, including Facebook
and LinkedIn, where you cansend us questions and even leave
comments about this episode.
Aaron (12:20):
Thank you.
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