Merit-based Incentive Payment System (MIPS)

On November 1, 2024, CMS released the CY 2025 PFS and QPP final rule.

• For ACEP’s summary of the final rule, please click here.
• For CMS fact sheets highlighting final MIPS policies, please click here. 
• For a summary of ACEP’s response to the proposed rule, please click here.
• For ACEP’s complete response to the proposed rule, please click here.

There are 2 exception applications available to clinicians:

• The MIPS Extreme and Uncontrollable Circumstances (EUC) Exception application allows you to request reweighting for any or all performance categories if you encounter an extreme and uncontrollable circumstance that's outside of your control.
  • You can apply for this exception whether reporting traditional MIPS, an MVP, or the APM Performance Pathway (APP).
• The MIPS Promoting Interoperability Performance Category Hardship Exception application allows you to request reweighting specifically for the Promoting Interoperability performance category if you qualify for certain reasons relating to inability to use EHR sufficiently.
  • This application is not available to APM entities.

The exception applications are open until 8pm ET on December 31, 2025. 

Most emergency physicians participate in the first track of the QPP: MIPS. MIPS includes four performance categories: Quality, Cost, Improvement Activities, and Promoting Interoperability (formerly Meaningful Use). Performance on these four categories (which are weighted) roll up into an overall score that translates to an upward, downward, or neutral payment adjustment that providers receive two years after the performance period (for example, performance in 2025 will impact Medicare payments in 2027).

Most emergency physicians will need to participate in MIPS to avoid a penalty and perhaps get a bonus. You can report as an individual or as part of a group. For the 2025 performance year, the potential payment adjustments range between -9 and +2.15%.

CMS has heard feedback, including from ACEP, that MIPS reporting should be streamlined and more meaningful to clinicians. Starting in 2023, CMS has been implementing the MIPS Value Pathways (MVPs), an approach that allows clinicians to report on a uniform set of measures on a particular episode or condition in order to get MIPS credit.

ACEP developed and proposed an emergency medicine-focused MVP, the “Adopting Best Practices and Promoting Patient Safety within Emergency Medicine MVP.” For more information on MVPs, click here.

If you see a minimum number of Medicare patients, have a small amount of Medicare charges, or provide a small number of services to Medicare beneficiaries, you may be excluded. You'll need your National Provider Identifier (NPI) number to determine your eligibility.

Find out whether you must report in MIPS

ACEP continually advocates on behalf of emergency physicians to reduce provider burden and help our members succeed in the program. Every year, CMS updates program requirements through federal regulatory rulemaking and ACEP actively comments on these regulations. 

ACEP also provides our members with helpful tools to report in MIPS. Thousands of emergency physicians are now using CEDR to meet the Quality Reporting requirements and participating in E-QUAL to meet the Improvement Activities requirements.

To meet this requirement, most emergency physicians will have to report on six measures over a 12-month period. The Quality category will count for 30% of your total score in 2025. One great way to meet the Quality requirement is by reporting through a qualified clinical data registry (QCDR). ACEP has developed its own QCDR, called the Clinical Emergency Data Registry (CEDR). Another option available to emergency physicians for meeting the Quality category is the “facility-based scoring option.” See below for more details.

Find out more about CEDR

Cost will represent 30% of your total score in 2025. If these measures do not apply to you or your practice, you will not receive a cost score and your quality score will count for 60% of your total score. Another option available to emergency physicians for meeting the Cost category is the “facility-based scoring option.” 

ACEP members helped develop the Emergency Medicine measure, an episode-based cost measure. The Emergency Medicine measure evaluates a clinician’s risk-adjusted costto Medicare for patients who have an ED visit during the performance period. The measure score is the clinician’s risk-adjusted cost for the episode group averaged across all episodes attributed to the clinician. This measure includes costs of Part A and B services during each episode from the start of the ED visit that opens, or “triggers,” the episode through 14 days after the trigger, excluding a defined list of services for each ED visit type that are unrelated to the ED care.

This category rewards participation in activities that improve clinical practice. There is a list of activities that are classified as either medium or high-weighted based on their value to patient care. To earn full credit in this category, participants must submit one of the following combinations of activities (each activity must be performed for 90 days or more during 2025):

• Two high-weighted activities
• One high-weighted activity and two medium-weighted activities
• Four or more medium-weighted activities

A great way to meet the requirements of this performance category is by participating in ACEP’s Emergency Quality Network (E-QUAL) Initiative.

This category includes measures and objectives related to the use of electronic health records (EHRs). Most emergency physicians are exempt from this category (formally known as the “Meaningful Use” program) because they are “hospital-based” clinicians who use their hospital’s EHR. CMS exempts groups from the Promoting Interoperability category of MIPS as long as 75% of individuals in the group meet the definition of “hospital-based.”

One scoring option available to emergency physicians starting is called the facility-based scoring option for the Quality and Cost categories of MIPS.

With this scoring option, clinicians who deliver 75% or more of their Medicare Part B services in an inpatient hospital, on-campus outpatient hospital, or emergency room setting will automatically receive the quality and cost performance score for their hospital through the Hospital Value-based Purchasing (HVBP) Program. Most emergency physicians qualify for this option. Clinicians who qualify for the option can still report quality measures through another submission mechanism (such as a QCDR) and receive a “traditional” MIPS score for quality. If they do so, CMS will automatically take the highest of the HVBP score and the traditional MIPS score.

MVPs have slightly different reporting rules than traditional MIPS.

• Quality Performance Category: MVP Participants will select 4 quality measures (rather than 6 under traditional MIPS).
• Improvement Activities Performance Category: MVP Participants will select 2 medium-weighted improvement activities OR one high-weighted improvement activity OR IA_PCMH (participation in a patient-centered medical home).
• Cost Performance Category: MVP Participants will be scored on the cost measures included in the selected MVP.
• Foundational Layer: MVP Participants will select one population health measure to be calculated on. The results will be added to the quality score.
• Promoting Interoperability Performance Category: MVP Participants will report on the same Promoting Interoperability measures required under traditional MIPS (most emergency physicians are exempt from this category).

For more information on the emergency medicine MVP, the “Adopting Best Practices and Promoting Patient Safety within Emergency Medicine MVP,” please click here.