CMS recently released its Calendar Year 2025 Medicare Physician Fee Schedule Final Rule, bringing important changes for healthcare providers participating in the Quality Payment Program (QPP). This update affects the Merit-based Incentive Payment System (MIPS), the Medicare Shared Savings Program (MSSP), and Alternative Payment Models (APMs). Here’s what you need to know:

1. Merit-based Incentive Payment System (MIPS) Updates

• The Performance Threshold: For the 2025 performance year CMS has kept the minimum performance threshold for MIPS at 75 points, consistent with the threshold in 2024. This threshold represents the Composite Performance Score that eligible clinicians need to achieve to avoid a negative payment adjustment. Maintaining this threshold at 75 points continues the policy set in previous years, allowing providers a stable target to meet or exceed to avoid penalties.
• Data Completeness Criteria: In addition to maintaining the minimum performance threshold of 75 points, CMS has also finalized their decision to keep the 75% data completeness criteria through the 2028 performance year.
• Weighting Adjustments: In 2025, MIPS performance category weights will remain as follows:

Although the category weights remain unchanged, it is important to note that the 2025 Final Rule includes some specific adjustments in each MIPS performance category:

• Quality will emphasize outcome-based measures, with added flexibility for specialty-specific measures.
• CMS is to implement new Cost scoring methodologies that will align with specific cost-efficiency goals, especially for high-cost services, through the addition of 6 episode-based measures. It will also include new benchmarking methodologies intended to better incentivize or penalize clinicians who show below or above national average spending.
• With Promoting Interoperability, CMS is further prioritizing data-sharing practices, mandating enhanced requirements for health information exchange.
• Improvement Activities include an expanded list of activities that include specific health equity initiatives.

2. Medicare Shared Savings Program (MSSP) Changes

• Incentives for Primary Care: CMS has introduced enhanced incentives for primary care services within the MSSP, making it more financially attractive for providers to join or remain in this program. This step aims to boost care coordination, drive down costs, and improve patient outcomes across Medicare.
• Alignment with Health Equity Goals: CMS is now rewarding ACOs that address health disparities, encouraging participating providers to implement practices that promote equitable healthcare access and outcomes for all Medicare beneficiaries.

3. Advancements for Alternative Payment Models (APMs)

• Expanding Model Options: For providers looking to reduce their reliance on fee-for-service models, CMS is expanding the available APM tracks to increase flexibility and opportunities for success. CMS is also setting new benchmarks and incentives for advanced APM participation, allowing more providers to benefit from this value-based approach.
• Focused Support for High-Value Care: The rule further emphasizes high-value, patient-focused care through initiatives that support providers moving towards full-risk APMs. This shift benefits those who achieve significant quality and cost improvements, positioning them for favorable payment adjustments.

Implications for Providers The Final Rule reflects CMS’s commitment to a high-quality, outcome-oriented healthcare system. Providers across the QPP spectrum—whether in MIPS, MSSP, or APMs—can expect an environment where performance on key patient-centered metrics will directly influence their Medicare reimbursements. The emphasis on accountability, quality, and efficiency highlights the importance of data-driven care strategies that elevate patient outcomes while managing costs.

These updates represent both a challenge and an opportunity. Providers who prioritize patient-centered, efficient, and high-quality care will find themselves better positioned within the evolving QPP landscape. For full details on these changes, see the Final Rule here or review the CMS Final Rule Key Facts here.