What’s New for Quality Payment Program in 2025

The Centers for Medicare & Medicaid Services (CMS) finalized several updates to the participation requirements for year 9 of the Quality Payment Program (QPP). Updates to the QPP are part of the calendar year 2025 Medicare Physician Fee Schedule (MPFS) released November 1, 2024. This article highlights the finalized QPP policies for the 2025 QPP performance year/2027 payment year that are most relevant to surgeons.

ACS QPP Advocacy Efforts

The ACS has strongly urged CMS to reframe the QPP from its inception and continues to highlight the need to redefine quality based on what is important to patients and their caregivers.

Existing measurement strategies are overly focused on single metrics that do not map to the patient, care team, or episode of care. In addition, current metrics do not capture the whole picture of patient care nor offer meaningful information to distinguish quality. As a solution, the ACS advocates for the incorporation of programmatic measures that build upon the ACS’s experience developing and implementing quality programs.

These metrics combine structure, process, and outcome-based measures that align with clinical frameworks based on evidence-based best practices to provide goal-centered, clinically effective care for patients. This multifaceted approach differs from current single metric philosophies by looking across the entire service line or episode of care. This provides information that is more meaningful to patients as they try to determine where to find the best care for their needs that aligns with the programmatic nature of modern care delivery and helps drive quality improvement cycles. 

Throughout its comments to the 2025 MPFS proposed rule, the ACS highlighted the problems with CMS’s current strategy for the QPP and recommended that CMS think about how it can drive team-based care, put greater focus on patient goals, and incorporate more programmatic measures that align with episodes of care such as the Age Friendly Hospital Measure.

The Age Friendly Hospital Measure is the first programmatic measure modeled after the ACS Geriatric Surgery Verification (GSV) Program and will be required for reporting in the Inpatient Quality Reporting Program in 2025.

The measure includes five domains that closely align with high-impact standards incorporated in the ACS GSV Program with goals to create standardized structures and processes that focus on the unique needs of older adults. The ACS sees the incorporation of programmatic measures in CMS quality programs as an opportunity to further goals of team-based, patient-centered care.

In addition, since many surgeons report to Merit-Based Incentive Payment System (MIPS) through their employers and this better aligns with goals of forming teams around patients, the ACS continues to advocate for the alignment of hospital and physician programs by encouraging CMS to allow performance in hospital quality reporting programs to be used in MIPS.

ACS Advocacy for PROMs and PRO-PMs

The ACS urged CMS to incorporate Patient-Reported Outcome Measures (PROMs) and Patient-Reported Outcome Performance Measures (PRO-PMs) in its programs. These measures offer meaningful insight to the patient’s perspective as well as the performance of the care team that cannot be captured using traditional outcome measures. The College emphasized the importance of defining episodes and understanding the needs of patient populations and care teams before designing the measures in order to best inform patients where to seek the best care for their needs.

QPP Updates for 2025

What to Know about MVPs

MIPS Value Pathways (MVPs) remain a voluntary reporting option in 2025, and surgeons who wish to report an MVP in 2025 must register in advance.

Whether a surgeon participates in traditional MIPS or an MVP, they will still be scored on Quality, Cost, Improvement Activities (IA), and PI, with lessened reporting requirements for the quality and IA performance categories compared to traditional MIPS. Those who elect to participate in MVPs also will be scored on population health-based measures.

CMS automatically calculates the cost and population health measures associated with the MVP using administrative claims measures. A clinician or group is only scored on these measures if enough patients are attributed under each measure.

Like traditional MIPS, MVP reporting is available for individuals, groups, and Alternative Payment Model (APM) Entities. However, MVPs also have an option for subgroup reporting. Subgroups consist of some but not all clinicians in a multispecialty practice. While subgroup reporting for performance year 2025 is voluntary, surgeons should note that it will be required beginning with the 2026 performance year.

Clinicians can choose from 21 MVPs starting with the 2025 performance year (see Figure). Six new MVPs were added, three of which are relevant to surgical care:

• Ophthalmology
• Urology
• Surgical Care

The ACS has opposed the implementation of the MVP framework and raised multiple concerns with the Surgical Care MVP. These concerns include a lack of alignment between quality and cost measures within the MVP, inclusion of broad surgical measures not applicable to many surgical episodes, and focus on individual physicians instead of patient-centered team-based care.

The ACS advocated that CMS should leverage programmatic measures to reframe MVPs because they incorporate key elements for value, which include:

• Creating a clinical program focused on informing patients or their surrogates such as primary care physicians as to where to find care
• Assembling care teams around patients and giving them meaningful feedback necessary to drive improvements in care
• Providing payers with key information to reward care they value for elements of safety, good outcomes, affordability, and meeting patients’ goals

What’s New for Quality Performance Category

The goal of the Quality category is to measure the quality of care provided. For performance year 2025, surgeons can choose from 195 quality measures. Participants can explore the 2025 MIPS quality measure inventory for more details. MVP participants can choose quality measures from their selected MVP.

CMS also finalized its proposal to remove the seven-point scoring cap for topped-out measures that are included in specialty sets where there a limited number of measures applicable to that specialty. Topped-out measures are those for which performance is so consistently high that CMS noted that meaningful distinctions in quality are limited, so it capped the number of points a clinician could receive for reporting these measures to seven.

For many years, the ACS has opposed CMS’s topped-out measure policy and urged the agency to remove the scoring cap on all topped-out measures; however, CMS maintained its proposal to only address measures in specialty sets with limited choice.

What’s New for Cost Performance Category

The goal of the Cost performance category is to measure a participant’s total cost of care during the year, a hospital stay, or an episode of care. There are no individual reporting requirements for Cost, as CMS calculates this category based on administrative claims data. CMS continues to add episode-based cost measures to the cost measure inventory. Surgeons can explore these measures on the CMS website.

While many policies for the Cost performance category remain the same in 2025, CMS finalized a new scoring methodology for this category, beginning with the 2024 performance year. The new methodology creates updated benchmark ranges that will inform achievement points in the Cost performance category. CMS said this new methodology will increase both the mean Cost performance category score and mean final score for MIPS participants. The ACS urged CMS to apply this new methodology to performance years before 2024, but CMS did not do so.

What’s New for Improvement Activities Performance Category

The goal of the IA performance category is to reward clinicians for participating in activities that improve clinical practice. CMS made a number of updates to the IAs available for reporting in the upcoming performance year. They also made a notable change to how IAs are scored by eliminating the weighting of activities.

In the past, IAs were categorized to either high (worth 20 IA points) or medium (worth 10 IA points) weights. Beginning in 2025, all IAs will be weighted the same and worth 20 IA points, therefore reducing the number of activities to which clinicians are required to attest.

MIPS-eligible clinicians who participate in traditional MIPS will be required to report two activities (20 points each). MIPS-eligible clinicians who are categorized as small practice, rural, in a provider shortage area, or nonpatient facing will now be required to report one activity (40 points). MVP participants also are required to attest to only one activity.

What’s New in APMs

APMs provide additional incentive payments to clinicians who demonstrate high-quality and cost-efficient care. APMs can apply to specific conditions, episodes of care, specialties, or populations; however, most available APMs are focused on primary care, despite the ACS’s advocacy efforts to involve more specialists.

While many of the APM policies remain unchanged for performance year 2025, it is important to note that there will be two APM options for surgeons whose hospitals participate in the Transforming Episode Accountability Model (TEAM), set to begin in January 2026 (see article here):

• Advanced APM option, for TEAM participants who are able to attest to using Certified Electronic Health Record Technology (CEHRT)
• Non-Advanced APM option, for those who do not meet CEHRT criteria

Surgeons can use the QPP Participation Status tool to determine if they are eligible for participation in an Advanced APM or MIPS.

The ACS’s response to the 2025 MPFS proposed rule can be found on the ACS website. For more detailed information on how to successfully report to the QPP in 2025, surgeons can visit the ACS QPP Resource Center at Quality Payment Program Resource Center.

Kate Murphy is a Regulatory and Quality Assistant, Haley Jeffcoat is a Quality Affairs Associate, and Jill Sage is Chief of Quality Affairs in the ACS Division of Advocacy and Health Policy in Washington, DC.