Summary of Updates to the Quality Payment Program (QPP)

The Center for Medicare and Medicaid Services’ (CMS) Quality Improvement Program aims to reward high-value, high-quality Medicare clinicians with payment increases, while at the same time reducing payments to clinicians who aren’t meeting performance standards.

The Quality Program has two tracks for reimbursement, the Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (APMs).

CMS has released important updates related to the MIPS, the Quality Payment Program and the APMs as summarized below.

Suspension of Merit-Based Incentive Payment System (MIPS) Improvement Activities

For the 2025 performance year, CMS has suspended eight improvement activities and proposes to remove these improvement activities from future rulemaking. This suspension means clinicians should select other activities to complete. Available improvement activities can be found here: Links to 2025 Merit-based Incentive Payment System (MIPS) Measure Specifications, Supporting Documentation, and Improvement Activity Descriptions.

If clinicians have already completed these improvement activities or were in the process of completing them, they will still be able to attest to their completion and receive credit.

The table below outlines the improvement activities that have been suspended.

2025 Quality Payment Program (QPP) Exception Applications

Quality Payment Program (QPP) exception applications allow clinicians to indicate the reason why they are unable to report data for one or more MIPS performance categories.

There are two types of exceptions:

• MIPS Promoting Interoperability Performance Category Hardship Exception Application
• MIPS Extreme and Uncontrollable Circumstances Exception Application

Quality Payment Program (QPP) exception applications for 2025 are available until Dec. 31, 2025.

Approval of exception applications means you won’t be required to report data for the performance category(ies) included in the approved application.

Applications may be submitted through the Quality Payment Program (QPP) website.

New Alternative Payment Methods (APM) Resources

New resources related to the Alternative Payment Model (APM) Peformance Pathway (APP) have been posted to the QPP Resource Library - QPP.

Newly release resources include:

• 2025 APP Toolkit: 2025 APP Fact Sheet, 2025 APP Quick Start Guide, 2025 APP Scoring Guide and 2025 APP Infographic
• 2025 APP Quality Requirements, Excluding SSP ACOs
• 2025 APP Quality Requirements, SSP ACOs Only

Full details about these updates as well as other official information about the quality payment program can be found at the QPP website https://qpp.cms.gov/.

References

• Quality Payment Program - https://qpp.cms.gov/

For more than 30 years, HIA has been the leading provider of compliance audits, coding support services and clinical documentation audit services for hospitals, ambulatory surgery centers, physician groups and other healthcare entities. HIA offers PRN support as well as total outsource support.

The information contained in this coding advice is valid at the time of posting. Viewers are encouraged to research subsequent official guidance in the areas associated with the topic as they can change rapidly.