2025 QPP: Proposed Changes from the PFS Proposed Rule

CMS has released the 2025 PFS Proposed Rule. In this rule, CMS has proposed several changes to the Quality Payment Program (QPP) and the reporting frameworks.

The three reporting paths are the Merit-based Incentive Payment System (MIPS), the MIPS Value Pathways (MVPs), and the Alternative Payment Model (APM) Performance Pathway (APP).

CMS is pushing the industry to start reporting specialty data and said in the ruling, “we anticipate that we may be ready to fully transition to MVPs by CY 2029.”

Furthermore, CMS is pushing for a digital-first approach, especially for ACOs. In 2025 they are increasing the number of required measures and only allowing for eCQM or Medicare CQM measure collection types but identified eCQMs as the “gold standard” that they want ACOs to work toward submitting.

There were several other changes they proposed to the program. Here is a slideshow that highlights the key changes in 2025 that you should know about.

Download the slides >>

Here are a few more resources we think may be helpful.

• Article: MIPS Value Pathways (MVPs): Should I Start Now?
• Download: [Checklist]: How to Select a MIPS Value Pathways Vendor
• Download: MVP Reporting Bundle
• Download: MVP Selection Worksheet: A Guide to Choosing Which MVP to Report
• Article: What is a Medicare CQM?
• Resource: More about MIPS Reporting & QPP Overview eBook