Today we bring you updates from the latest CMS QPP Newsletter for Small Practices:

CMS Proposes Policy Changes for Quality Payment Program

The Centers for Medicare & Medicaid Services (CMS) has issued its Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule, which includes proposed policies for the Quality Payment Program (QPP).

The Notice of Proposed Rulemaking (NPRM) includes proposals for the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs), as well as several Requests for Information (RFIs).

Specifically, we’re proposing policies that:

• Continue the transformation of MIPS through MIPS Value Pathways (MVPs).
• Are responsive to feedback and concerns raised by interested parties.
• Maintain stability within the MIPS program through the established performance threshold.

2026 Policy Proposal Highlights

Key QPP policies that we are proposing in the CY 2026 PFS Proposed Rule include:

• Introducing 6 new MVPs for the 2026 performance year that are related to diagnostic radiology, interventional radiology, neuropsychology, pathology, podiatry, and vascular surgery.
• Introducing a 2-year informational-only feedback period for new cost measures, allowing clinicians to receive feedback on their score(s) and find opportunities to improve performance before a new cost measure affects their MIPS final score.
• Maintaining the current performance threshold policies, leaving the performance threshold set at 75 points through the 2028 performance year.
• Introducing Qualifying APM Participant (QP) determinations at the individual level, in addition to existing determinations at the APM entity level.

Overview of RFIs

We are also seeking feedback on RFIs about the following topics:

• Establishing Core Elements for MVPs, to require reporting on key quality measures within each MVP.
• Establishing a process to assign clinicians to an MVP, to facilitate the most relevant reporting for their scope of care.
• Transitioning to FHIR-based electronic clinical quality measure (eCQM) reporting in quality reporting programs.
• Understanding the current environment, including challenges, with collecting and exchanging high-quality healthcare data.
• Changing requirements for the Query of Prescription Drug Monitoring Program (PDMP) Measure and Performance-Based Measures in the Public Health and Clinical Data Exchange Objective.
  

The Center for Medicare and Medicaid Services (CMS) has announced it is suspending eight improvement activities for the 2025 performance year.

The suspension is in accordance with the Merit-based Incentive Payment System (MIPS) Improvement Activities Suspension Policy finalized in the CY2021 Physician Fee Schedule final rule.  CMS intends to propose removing these improvement activities in future rulemaking.

MIPS Improvement Activities Suspended for PY 2025

CMS says that clinicians should select other improvement activities to complete.  However, if any of the suspended improvement activities have already been completed or were in the process of being completed, clinicians will still be able to attest to completing them and receive credit.  Please review the 2025 Improvement Activities Inventory for available improvement activities.

Visit the QPP website for more information.

Source: Improvement Activities Suspension Announcement, Small Practices Newsletter, 2025

The Centers for Medicare & Medicare Services (CMS) has released Merit-based Incentive Payment System (MIPS) performance feedback and final scores for the 2023 performance year and associated MIPS payment adjustment information for the 2025 payment year.

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. The newsletter is sent on the 2nd Tuesday of each month.

The Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) registration window is open for the 2023 performance year.  Individuals, groups, subgroups, and Alternative Payment Model (APM) Entities that wish to report an MCP can register until November 30, 2023 at 8 p.m. ET.  

The MIPS Final Score Preview period for the 2022 performance year is now open. Small practices are strongly encouraged to sign in to the Quality Payment Program website to preview their final score based on data submitted for the 2022 performance year.

We encourage you to subscribe  to the Quality Payment Program Small Practices Newsletter. It is a valuable resource from CMS to help your practice be successful in the Quality Payment Program. This week we bring you selected resources:

Today we share a recent newsletter from CMS (Center for Medicare and Medicaid Services):

CMS has contracted with an entity ("Guidehouse") to conduct audits of data submitted as part of the Merit Based Incentive Payment System (MIPS). These audits will  look at Performance Years 2019, 2020 and 2021, and notification emails will begin in January 2023.

Given the public health emergency, participants in the Quality Payment Program may find it difficult to meet the requirements for the Merit-based Incentive Payment System (MIPS) for program year 2021.