This article is your ultimate guide to the Quality Payment Program. This program encompasses three primary reporting frameworks: Traditional MIPS, MIPS Value Pathway (MVP), and APM Performance Pathway (APP). Each framework comes with its own set of requirements, aiming to ensure that clinicians not only avoid penalties but also have the opportunity to earn significant bonuses. To succeed, clinicians must achieve a minimum score of 75 points. In this article we provide a refresher on QPP history, provide the outline of how the program works, and then review the requirements according to each reporting framework.
QPP was born out of the 21st Century Cures Act of 2016 and the Medicare Access and CHIP Reauthorization Act (MACRA). These legislative initiatives aimed to transform the way healthcare professionals are reimbursed for their services and improve the quality of care provided to Medicare beneficiaries.
QPP was officially implemented in 2017 with the goal of emphasizing the transition from volume-based to value-based care. First, there were two distinct reporting tracks or “frameworks” for Eligible Clinicians: The Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (APMs).
Since then, CMS has added two more reporting frameworks to the mix. The APM Performance Pathway (APP) and the MIPS Value Pathway (MVP) which will eventually replace Traditional MIPS.
Let’s dive into the details.
CMS puts Eligible Clinicians into one or more categories.
To find out your participation framework you must check your eligibility on the QPP website. Enter the provider NPI to determine eligibility.
Once you identify whether you are eligible to report as an individual or group, you may choose how to participate.
APM Entities will be referenced throughout.
APM stands for Alternative Payment Model. An APM Entity is responsible for reporting to this program on behalf of their participants. There are two types of APM Entities.
Understanding the Frameworks
Once you know your participation status, you will understand which framework you can use for submission. Each framework has slightly different requirements and different category weights. There are three QPP frameworks in 2025:
This is the usual MIPS framework made up of four categories and a composite score.
The MVP framework focuses on sub-group reporting by specialty type – applicable specialty measures designed for specialists. This reporting framework will eventually replace Traditional MIPS.
The APP Framework is available to MIPS APM Entities and required for ACOs if they are part of MSSP.
Collection types are the way you report the data to CMS. You can think of them like measures. There are six collection types in 2025.
*Only small practices may use claims to fulfill their quality measures requirements.
**Only available for MSSP ACOs reporting under the APP framework.
Now we are ready to review the requirements for each framework.
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Improvement Bonus: Up To 10 Points
Clinicians will be rewarded if they demonstrate improvement over their 2024 Quality score (pending there is enough data for comparison). Clinicians may earn up to 10 additional percentage points based on their improvement.
Clinicians may also earn a cost improvement score of 1 percentage point out of 100 percentage points.
Complex Patient Bonus: 5 Points
For clinicians who work with patients that have more complex cases, CMS will award up to 5 points to account for the additional complexity of treating their patient population.
Complex Organization Adjustment: 1 Point for Each eCQM Submitted
This is available for APM Entities and virtual groups reporting eCQMs. CMS will add one measure achievement point for each submitted eCQM. The adjustment may not exceed 10% of the total available measure achievement points in the quality category.
Small Practice Bonus: 6 Points
An additional 6 bonus points will be added to the numerator of the Quality category for anyone qualifying as a small practice.
PI Public Health and Clinical Data Exchange Bonus: 5 Points
Your organization may earn five bonus points for submitting a "yes" response for one of the optional Public Health and Clinical Data Exchange measures in the PI measure list.
To avoid a -9% penalty, you must score at least 75 points.
0-18.75 Points
If your score is between 0 and 18.75 points, you will lose -9% from your Medicare fee schedule (in red above).
18.76-75.00 Points
If your score is between 18.76 and 75.00 points you will receive a reduction to your Medicare fee schedule between -8.99% and 0%.
75.01 -100 Points
Starting with those who score 75.01 or more, CMS will take the funds of those who did not meet the threshold (in red) and distribute them among those who did meet the threshold (in green). Anyone whose MIPS score is between 75.01 and 100 points will receive some portion of those funds – up to a 9% increase to your Medicare fee schedule.
Note: There is no longer an Exceptional Performance bonus
How do I get my maximum shared savings?
To get the maximum shared savings for your ACO you must:
AND
AND
The Quality Performance Standard is met if you score ≥ 40th percentile on every quality measure.
There are two ways that make it easier to meet the Quality Performance Standard.
How do I know what performance to aim for?
CMS uses historical benchmarks to determine what performance score equals which decile. The decile is the points you get for that measure. So to achieve the 40th percentile on a measure, you must achieve the performance score at or above decile 4. You can find these benchmarks on the QPP Resource Library.
For Medicare CQMs, CMS established flat benchmarks.
Flat Benchmarks for Non-Inverse Medicare CQMs:
| Decile |
Performance Rate Range |
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1 |
<10.00 |
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2 |
10.00 - 19.99 |
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3 |
20.00 – 29.99 |
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4 |
30.00 – 39.99 |
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5 |
40.00 – 49.99 |
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6 |
50.00 – 59.99 |
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7 |
60.00 – 69.99 |
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8 |
70.00 – 79.99 |
|
9 |
80.00 – 89.99 |
|
10 |
≥90.00 |
January 1, 2025
The start date to track 365 days of Quality and Cost category measures.
April 1, 2025
Registration opens for MVP selection and for CAHPS for MIPS election. MSSP ACOs are automatically registered for CAHPS.
June 30, 2025
Registration for CAHPS for MIPS election closes.
July 4, 2025
The last day to start measures in the Promoting Interoperability category to meet the minimum of 180 continuous days.
October 2, 2025
The last day to start Improvement Activities to meet the minimum requirement of 90 continuous days.
December 2, 2025
Last day to register for an MVP.
March 31, 2026
The last day to submit all of your performance data.
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