Quality Payment Program Small Practices Newsletter: December 2024

qpp The Quality Payment Program (QPP) Small Practices Newsletter is a monthly resource that provides small practices (15 or fewer clinicians) with program updates, upcoming QPP milestones, and resources to support their continued participation and success in QPP. We send this newsletter on the second Tuesday of each month.

Please share this newsletter with your fellow clinicians and practice staff and encourage them to sign up to receive this monthly resource.

At-a-Glance: Required and Recommended Activities for Successful Participation in QPP

Each month, we share required and recommended activities for small practices to support their successful participation in QPP. The activities follow a rolling quarter approach, letting you see activities for the previous month, the current month, and the following month.

qpp2

In This Issue:

Hot Topics: What You Need to Know

Check Your Final 2024 and Initial 2025 MIPS Eligibility Status
NOW AVAILABLE: CY 2025 Medicare PFS Final Rule and Resources
Deadline to Submit a MIPS EUC Exception Application is December 31, 2024
REMINDER: 2025 Virtual Group Election Period Closes December 31, 2024
Prepare for 2024 Performance Year Data Submission
Relevant Resources

Check Your Final 2024 and Initial 2025 MIPS Eligibility Status

Check Your Final 2024 MIPS Eligibility Status

Enter your 10-digit National Provider Identifier (NPI) in the Quality Payment Program (QPP) Participation Status Tool and review your final 2024 eligibility status for the Merit-based Incentive Payment System (MIPS).

We’ve updated your eligibility status based on our review of Medicare Part B claims and Medicare Provider Enrollment, Chain, and Ownership System (PECOS) data from the second segment of the MIPS Eligibility Determination Period (October 1, 2023 – September 30, 2024).

This status is final unless you participate in an Advanced Alternative Payment Model (APM) and your Qualifying APM Participant (QP) status changes as a result of the third APM Snapshot for the 2024 performance year.
Results from the third APM Snapshot will also be available in December 2024 and announced through the QPP listserv.

Review Your Final 2024 Eligibility

Your status may have changed, so we encourage you to use the QPP Participation Status Tool to confirm your final 2024 MIPS eligibility status.

If you were initially eligible for MIPS at a particular practice, your eligibility status could have changed, and you may no longer be eligible at that practice. Check to make sure you’re still eligible.
If you were initially ineligible for MIPS at a particular practice, your eligibility status didn’t change at that practice.
If you joined a new practice (meaning you billed under, or assigned your billing rights to, a new or different Taxpayer Identification Number [TIN]) between October 1, 2023, and September 30, 2024, you need to check your eligibility status at this new practice.
If you’re a clinician who joined a new practice after September 30, 2024, you aren’t eligible for MIPS as an individual based on your association with that new practice (identified by TIN). However, you’ll receive a MIPS payment adjustment if the practice chooses to participate in MIPS as a group.

For More Information

Learn How MIPS Eligibility Is Determined on the QPP website and check out the following resources:

Check Initial 2025 MIPS Eligibility on the QPP Website

Use the QPP Participation Status Tool to check your initial 2025 MIPS eligibility status.

Enter your 10-digit NPI to review your initial MIPS eligibility. If you’re currently eligible, you should prepare to participate in the 2025 performance year. The MIPS Quick Start Guide will be available on the Resource Library in the coming weeks and can assist with your planning.

Find Out Today

Find out today whether you’re currently eligible for (required to participate in) MIPS. Prepare now to try to earn a positive payment adjustment in 2027 for your 2025 performance.

Next Updates to 2025 MIPS Eligibility

We’ll update the QPP Participation Status Tool in December 2025 with final eligibility for the 2025 MIPS performance year.

We’ll also update the QPP Participation Status Tool to reflect clinicians’ QP status 3 times during the performance year. We anticipate these updates to be available in July, October, and December 2025.

NOW AVAILABLE: CY 2025 Medicare PFS Final Rule and Resources

The Centers for Medicare & Medicaid Services (CMS) has issued its Calendar Year (CY) 2025 Medicare Physician Fee Schedule (PFS) Final Rule, which includes policies for the Quality Payment Program (QPP) for the 2025 performance year and beyond.

There are no significant policy changes exclusively for small practices for the 2025 performance year.

Highlights include:

A performance threshold of 75 points for the 2025 performance year (no change). You’ll avoid a negative payment adjustment in the 2027 payment year if your 2025 final score is 75 points or higher.
The addition of 7 new quality measures, substantive changes to 66 quality measures, and the removal of 10 quality measures.
The removal of the 7-point cap for scoring certain topped-out quality measures in specialty sets with limited measures.
Changes to our cost measure scoring methodology.
The addition of 6 new episode-based cost measures and modifications to 2 existing episode-based cost measures.
The removal of improvement activity weighting and streamlining the reporting requirements for the performance category.

Learn more about the Final Rule and QPP policy changes by reviewing the following resources:

2025 QPP Policies Final Rule Fact Sheet (PDF, 2.1MB) — Provides an overview of the CY 2025 PFS Final Rule and includes a table that compares current policies to finalized policies and frequently asked questions.
2025 Finalized MIPS Value Pathways Guide (PDF, 2.5MB) — Details the newly finalized MIPS Value Pathways (MVPs) and the modifications to previously finalized MVPs for implementation in the 2025 performance year.

Deadline to Submit a MIPS EUC Exception Application is December 31, 2024

The deadline to submit a MIPS EUC Exception application for the 2024 performance year is 8 p.m. ET on December 31, 2024. If you believe you’ve been affected by an extreme and uncontrollable circumstance, you can apply (whether you’re reporting via traditional MIPS, MVPs, or the APM Performance Pathway [APP]).

For more information on instances where the automatic MIPS EUC policy is applied, review the 2024 MIPS Automatic EUC Policy Fact Sheet (PDF, 399KB).

REMINDER: 2025 Virtual Group Election Period Closes December 31, 2024

The 2025 virtual group election period is still open. Solo practitioners and groups with 10 or fewer clinicians interested in this traditional MIPS participation option can submit or modify their election for the 2025 performance period via email at MIPS_VirtualGroups@cms.hhs.gov.

The following elements must be included in an election:

Acknowledgment that a formal written agreement has been established between each Taxpayer Identification Number (TIN) within the virtual group
The name and contact information for the official virtual group representative
The name and TIN for each practice and all associated National Provider Identifiers (NPIs) under each TIN

The election period closes on December 31, 2024, at 11:59 p.m. ET.

For more information about virtual group participation and elections, please review the 2025 MIPS Virtual Group Toolkit (ZIP, 2MB).

Prepare for 2024 Performance Year Data Submission

Confirm Access to Healthcare Quality Information Systems (HCQIS) Roles and Profile Account (HARP)

In preparation for the 2024 performance year data submission period, which opens on January 2, 2025, we encourage you to sign in to the QPP website with your existing HARP account to ensure you don’t lose access.

If you don’t already have a HARP account and QPP role, please create one. For more information on how to create a HARP account and user profile, review the QPP Access User Guide (ZIP, 4 MB). For a video walking you through the HARP registration process, visit the HARP YouTube playlist.

If you have a HARP account, confirm that you can access your account. If you’ve forgotten your user ID or password, you can review the HARP Password Reset video for more information on how to regain access to your account.

Upcoming QPP Service Center Hold Times

Due to the opening of the 2024 MIPS data submission period, the QPP Service Center is projecting an increase in volume between January 2, 2025, and March 31, 2025, which could result in longer wait times.

CMS recommends the following to minimize wait times and ensure successful 2024 data submission:

Did you know? . . .

You can request support by clicking on Schedule a Call.

You can also submit a ticket for support by clicking on Request Support.

Live Chat: CCSQ Support Central Chat and Resource Line (CARL)

The Support Central Chat feature, CARL, is another option to use for assistance. To contact the Service Center via Chat, you’ll need to go to the CCSQ Support Central page and click on the Chat icon in the lower right.

Use One Method to Report Issues

Due to the anticipated increase in volume at the QPP Service Center and to minimize a backlog, please use only one method of reporting (email, phone, or CCSQ Support Central) for the same issue. Note: Cases are processed in the order in which they’re received, regardless of how the Service Center was contacted. Please allow time for processing.

Submit Your Data Early

We encourage you to submit your 2024 MIPS performance period data early during the submission period. Early submission will allow you plenty of time for Service Center assistance, if needed.

Relevant Resources

2024 Small Practice Resources