¶ CMS 2025 Final Rule Highlights
Hello , it's Jason Crosby with SHP . Welcome to another episode of Beyond the Stethoscope Vital Conversations with SHP . Today we have a quick conversation with our very own Aaron Higgins , who's going to recap some of the highlights from the recent 2025 final ruling that just came out Opportunity wording . There being quick conversation .
If you know Aaron , he can kind of go on and on , but he's going to give it a shot . How are you doing , aaron ?
I'm pretty good , and I resemble that remark , jason , most certainly . Yeah , so every year at the end of the year , everybody gets excited because something big and fat will drop into our laps every , every Thanksgiving , and that is not Santa Claus , it's the QPP final rule .
Well , it's bundled into all of the CMS final rules for the year Starting the next calendar years of 2025 .
Every year there's always changes to MIPS , to the quality payment program overall , and kind of one of the bigger shifts that we've seen the last couple of years is that CMS has really just started to call it all QPP , because they do all these other changes , not just MIPS .
But every year we've done some kind of big podcast or show and tell about the changes . Well , this year we're going to try it a little bit different . So , yes , challenge accepted , jason .
I'm going to try to keep this very short and just the highlights , and in our show notes we will link to all the sources for this so you can go dive deeper if you need to . Okay , so I think the biggest thing that folks need to be aware of is that CMS is really sticking to that performance threshold .
So that performance threshold means you need to score 75 points or greater to avoid penalty . If you score exactly 75 points , you get zero . So you don't get a penalty . You don't get any sort of reward . 75 points is still the goal To aid in that , because some people are still struggling , particularly with some specialty types , really finding good measures .
They are changing the way measures get topped out . So previously , measures that were topped out because everybody was doing it were only earning you three points in the quality category and that made it really challenging . You would have to submit a whole lot more measures to get to your full quality . So now it's scaled .
The details of that scaling is in the document that we're going 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 10 points but you have to earn 100% on those measures . So if you do participate in a topped out measure , you can get more points . That's good .
It's going to help you with your hitting your overall performance threshold of 75 points . Overall Data completeness also isn't changing there . What data completeness means is the percentage of patients seen , and you recorded their data , regardless of what type of patient it is , and they have that set at 75% . They are maintaining that through 2028 .
They had talked about 100% and they've scaled that back down to 75% . Managed care contracting does not have to be a hassle , and they've scaled that back down to 75% . Managed care contracting does not have to be a hassle .
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Another topic that continuously comes up every year with us are MVPs right ? So what new ones are coming out for the 25 performance period ? And then what changes have been made to existing MVPs ? Aaron , yeah .
So the MVPs , the MIPS value pathways is the way the whole MIPS program is evolving . By 2028 , so three years from now everybody will be moving from what's called traditional MIPS over to the MVPs . To facilitate that , cms is rolling out new MVPs .
Now , mvps all slightly differ from each other , but they're essentially four quality measures that you have to do promoting interoperability , what they are calling a population health measure , and then the cost measures that are associated with your specialty .
The nice thing about the MVPs is that it takes away the huge smorgasbord of options that can be overwhelming to a practice . They're also scaled appropriately for a practice of different sizes so 15 or fewer clinicians , so small practices and that sort of thing . So they are introducing some new MVPs . Again , all of this will be linked in the show notes .
They're also making some modification to the existing MVPs , such as advancing cancer care and advancing care for heart disease . They've gone back and they've retooled some of those metrics within . So if you've done an MVP in the past or are interested in doing that , getting away from the traditional MIPS line I highly recommend taking a look at the MVPs for 2025 .
You have until late 2025 to decide between the two of them . But even then there's a little catch . They are now allowing you to submit both traditional MIPS and MVPs in your transition year , and then they will give you your score based off of which one performs better . So if you want to go to all that extra effort , you can .
Unless you're a large practice , I don't see a lot of benefit for it To piggyback adding and revising of measures .
Tell us what new quality measures have been added and those that have been removed for 25 , and then what changes have been made to existing ones as well .
Yeah . So we have seven new quality measures . They are all mostly focused around chemotherapy . Unless you're in the chemotherapy world , the cancer world , these measures aren't probably going to apply to you . They have removed 10 measures Again . All these are going to be in the show notes . This is a quick conversation , I'm not going to dive into them .
And they have made a substantive change to 66 of them . So , just like every year , if you've already picked your measures , you're really comfortable with these . You're doing well at them . Go back and make sure they haven't been changed .
Sometimes they've substantively changed some very popular measures and people who are doing well one year are doing terrible the next . Looking at some of these changes , they're for the better and should help you perform better in those measures and kind of pivoting on the measures is improvement activities . Now , the changes they've made to improvement activities .
They've introduced two new ones , they've modified one and then they have removed a total of four . Now those four that they have removed are actually very popular . In fact , one of them is extremely popular and that is the availability of your EHR 24-7-365 . The reason why CMS removed it is because , a everybody was doing it and B it was too easy .
Essentially , if you have remote access to your EHR and let's be honest , who doesn't these days you could qualify for saying you did this improvement activity . Cms knows this and so they've removed it . So if you were banking on this improvement activity , I'm sorry you're going to have to change it up for next year .
But another thing too , with the improvement activity is just to kind of pivot . They've done away with the medium and high weighting . Now if you are a small practice so 15 or fewer clinicians you only have to pick one improvement activity . If you are not a small practice , you have to pick two . Now there's some other criteria too that allow you to pick one .
If you qualify for that , take a look again in the show notes .
All right , shifting gears , reporting of the electronic clinical measures . How will the new complex organization adjustment affect the APM entities , virtual groups and such ?
Well , first off , cms knows that complex patients are more expensive . They also have seen a trend amongst ACOs and other advanced payment models shedding their specialty groups because their specialty groups were dragging down the average score . Cms doesn't like that . They see a problem with it , so they are adjusting the scoring .
Talk to your APM , see how will the changes to scoring affect their decisions going forward . But this will be for the 2027 year . So even though the performance year is 25 , there's not any benefits seen until 2027 . So that still may make some APMs want to shed some of their specialties out of that , and we've seen that , jason .
We've seen some bigger ACOs dropping specialties altogether and CMS is trying to stem the tide of that .
Yeah , that makes sense . You know , when QPP first started out , cost was that sort of gray area folks weren't sure about . So what changes have been made to the cost measure scoring methodology for the 24 period ?
Well , it is still a mystery wrapped in an enigma . The cost category is receiving some changes . Again , cms is revising their methodologies , adjusting the formulas a little bit , making it a little easier for practices to achieve , because they know it's one of those things that's completely out of the practices control 95% of the time .
So they are making some adjustments there based off of feedback that they've received as well as the performance that they've done in the past . So they're also introducing some new measures over there . So hopefully that will make it easier for practices to achieve the cost measures .
You know what . We've kind of run up on time . We call this a quick conversation for a reason . Aaron , you did a fantastic job . I got to say I'm impressed . That's probably the most condensed conversation we have ever had , but impressive but awesome info , as usual . And to our listeners .
As Aaron said at the beginning , we'll put a bunch of information in the show notes . You'll find everything you need there and you know how to find us . If you need any QPP info , don't contact me , contact aaron . You'll find all our info on shplccom . Aaron , thanks for the uh quick conversation . Hey , you too . We'll talk to you later .
¶ Healthcare Podcast Production Credits
All right , bye-bye this has been an episode of beyond the Stethoscope Vital Conversations with SHP . Your hosts today have been me , aaron Higgins .
And me , jason Crosby . This is a production of Strategic Healthcare Partners . Our executive producers are Mike Scribner and John Crew , our editor is Nyla Wiebe and our social media manager is Jeremy Miller , with Boost by Design , transcription by a robot and tweaked by me , a human , jason .
Crosby , you can visit our podcast archive on our website shplccom slash podcast , and there you can learn more about the services and products offered by SHP .
You can also find us on social media , including Facebook and LinkedIn , where you can send us questions and even leave comments about this episode .
Thank you .