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Centers for Medicare & Medicaid Services Quality Payment Program
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Submit Comments on CMS Proposed Policy Changes for Quality Payment Program

*"Provide Feedback on Proposed Changes to the Quality Payment Program by September 9"*

The Centers for Medicare & Medicaid Services (CMS) recently issued its Calendar Year (CY) 2025 Medicare Physician Fee Schedule (PFS) Proposed Rule [ https://www.federalregister.gov/documents/2024/07/31/2024-14828/medicare-and-medicaid-programs-cy-2025-payment-policies-under-the-physician-fee-schedule-and-other ], 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.

*Submit a Formal Comment by September 9*

You must officially submit your comments in one of the following ways [ https://www.federalregister.gov/documents/2024/07/31/2024-14828/medicare-and-medicaid-programs-cy-2025-payment-policies-under-the-physician-fee-schedule-and-other#open-comment ]:


* Electronically, through Regulations.gov [ https://www.regulations.gov/commenton/CMS-2024-0256-0045 ]
* Regular mail
* Express or overnight mail

Comments are due no later than* 5:00 p.m. ET on September 9, 2024.*

*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 (PDF, 596KB) [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2876/2025-QPP-Proposed-Rule-Fact-Sheet-and-Policy-Comparison-Table.pdf ]
* 2025 Proposed and Modified MVPs Guide (PDF, 948KB) [ https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2877/2025-Proposed-and-Modified-MVPs-Guide.pdf ]
QPP Footer 2023 [ https://qpp.cms.gov/resources/help-and-support ]


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