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Centers for Medicare & Medicaid Services Quality Payment Program
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CMS Proposes Policy Changes for Quality Payment Program

The Centers for Medicare & Medicaid Services (CMS) has issued its Calendar Year (CY) _2025 Medicare Physician Fee Schedule (PFS) Proposed Rule [ https://www.federalregister.gov/public-inspection/2024-14828/medicare-and-medicaid-programs-calendar-year-2025-payment-policies-under-the-physician-fee-schedule ]_, 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 development and maintenance of MVPs
* Establish the APM Performance Pathway (APP) Plus quality measure set
* Update the MIPS measure/activity inventories and scoring methodologies

Finally, we’re proposing a small number of policies intended to maintain stability within the MIPS program through the established performance threshold and data completeness criteria.

*2025 Policy Highlights*

Key QPP policies that we are proposing in the 2025 PFS Proposed Rule include:


* Introducing *6 new MVPs for the 2025 performance period* that are related to ophthalmology, dermatology, gastroenterology, pulmonology, urology, and surgical care.
* Creating APP Plus, an *additional quality measure set under the APP,* which would include the 6 measures currently in the APP quality measure set and incrementally incorporate the remaining 5 Adult Universal Foundation quality measures for a total of 11 measures by the 2028 performance period/2030 payment year.
* *Maintaining the current performance threshold policies*, leaving the performance threshold set at 75 points for the 2025 performance period.
* *Keeping the 75% data completeness criteria* through the 2028 performance period.

*Overview of RFIs*

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


* MVP adoption and subgroup participation
* Public Health and Clinical Data Exchange Objective under the Promoting Interoperability performance category
* Guiding principles for the development of patient-reported outcome quality measures
* Changes to the administration of the Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey

*For** More Information*

Learn more about the QPP proposals by reviewing the following 2025 QPP Proposed Rule Resources:


* "2025 Quality Payment Program Proposed Rule Fact Sheet and Policy Comparison Table" [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2876/2025-QPP-Proposed-Rule-Fact-Sheet-and-Policy-Comparison-Table.pdf ] –Provides an overview of QPP proposals and RFIs included in the CY 2025 Medicare Physician Fee Schedule (PFS) Proposed Rule, and a comparison table contrasting existing policies with proposals.
* "2025 Proposed and Modified MVPs Guide" [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2877/2025-Proposed-and-Modified-MVPs-Guide.pdf ] – Highlights newly proposed MVPs and modifications to previously finalized MVPs, beginning with the 2025 performance year.
QPP Footer 2023 [ https://qpp.cms.gov/resources/help-and-support ]


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