Every March a practice manager calls us in the last week of the month with the same problem: the MIPS submission is "mostly done", the registry needs a signature, and nobody can find the HARP login. The 2024 performance year submission window opened on January 2, 2025 and closes on March 31, 2025 at 8 p.m. Eastern. That is a hard stop. CMS has occasionally extended deadlines in past years, but we tell practices to plan as if it will not, because a missed submission for a clinician who was required to report means a negative payment adjustment on every Medicare Part B claim in 2026.
What follows is the sequence we use in the last four weeks. It is written for the independent practice with one to fifteen clinicians that reports as a group or as individuals, not for the health system with a quality department. MIPS (the Merit-based Incentive Payment System) is Medicare's quality program for clinicians: a score out of 100 built from four categories, compared to a threshold, that raises or lowers Part B payments two years later.
Key takeaways
- Confirm eligibility per clinician in the QPP participation status tool before deciding anything else. Clinicians under the low-volume threshold have nothing to submit and nothing at stake.
- The 2024 performance threshold is 75 points. Below it, the adjustment on 2026 Part B payments is negative, down to minus 9 percent.
- Small practices (15 or fewer clinicians) are automatically reweighted out of Promoting Interoperability in 2024 unless they choose to submit that category, and they get six bonus points in Quality.
- Submit at least three business days early, save the confirmation, and file the supporting documents in one folder in case of audit.
Week one: confirm who has to report
Look up each clinician's 2024 eligibility in the Quality Payment Program participation status tool using their NPI. A clinician is required to participate if, during the determination periods, they exceeded all three low-volume thresholds: more than $90,000 in Medicare Part B allowed charges, more than 200 Part B patients, and more than 200 covered professional services. Clinicians below any one threshold are not required to report and receive no adjustment, though they may opt in if they exceed at least one threshold. Clinicians in their first year of Medicare enrollment are exempt, and so are clinicians in an Advanced APM who reach the qualifying participant thresholds.
Write the list down: required, opt-in eligible, exempt. The opt-in election, for those who choose it, must also be completed by March 31, 2025 at 8 p.m. Eastern, and it cannot be undone. Most small practices should not opt in unless they already know their score would be well above the threshold, because opting in exposes the clinician to the negative adjustment as well as the positive one. Also check the group's status: a practice can be required to report as a group even when some individual clinicians would be excluded on their own.
Week two: know what score you are chasing
For the 2024 performance year, the performance threshold is 75 points. A final score below 75 produces a negative adjustment on 2026 Part B payments, scaled from zero at 75 points down to the maximum of negative 9 percent at the bottom of the scale. A score above 75 produces a small positive adjustment, sized by how many clinicians nationally fall below. Category weights for most clinicians in 2024: Quality 30 percent, Cost 30 percent, Promoting Interoperability 25 percent, Improvement Activities 15 percent. Cost is calculated by CMS from claims, so there is nothing to submit; the other three are on you.
| Category | Weight (2024, standard) | Weight for a small practice with PI reweighted | What you submit | Common last-month problem |
|---|---|---|---|---|
| Quality | 30% | 55% | Six measures, one an outcome or high-priority measure, full-year data, at least 75% data completeness | A measure with too few cases, or data completeness under 75% because the EHR report excludes a location |
| Promoting Interoperability | 25% | 0% (unless the practice chooses to submit) | Numerators and denominators for a continuous 180-day period, plus the security risk analysis and SAFER Guides attestations | The security risk analysis was not done in 2024, which zeroes the category for anyone who submits it |
| Improvement Activities | 15% | 15% | Attestation to activities performed for at least 90 continuous days | No documentation on file to support the attestation if audited |
| Cost | 30% | 30% | Nothing; CMS calculates from claims | None to fix now |
Small practices, meaning 15 or fewer clinicians under the tax ID, get two things in 2024 that larger groups do not. First, the Promoting Interoperability category is automatically reweighted to zero without a hardship application, with its 25 percent moving to Quality. If the practice submits PI data anyway, CMS scores it, so a small practice with a weak PI year should simply not submit that category. Second, six bonus points are added to the Quality category for submitting at least one measure. Small practices can also report Quality through Medicare Part B claims measures, which is the one method that needs no registry.
The arithmetic matters for the decision in week three. A small practice scoring 70 out of 100 on Quality, 40 on Cost and full credit on Improvement Activities lands at roughly 38.5 plus 12 plus 15, or about 66 points, below the threshold. The same practice at 85 on Quality reaches about 74. That is why the last month is spent on measure selection, not on paperwork.
Week three: pick the submission path and run a dry submission
There are three practical routes: a qualified registry or a qualified clinical data registry (QCDR) that pulls data from your EHR or accepts files, direct submission from a certified EHR, or manual entry in the Quality Payment Program portal (mainly for Improvement Activities and Promoting Interoperability attestations, and for reviewing claims-based Quality data). Whichever you use, the person submitting needs a HARP account (the CMS identity system) connected to the practice's TIN, and that account must be active. If the person who set it up left the practice, start the new account now; the identity verification can take days.
Ask the registry for a preliminary score report this week. Read it as a reviewer would: measures with fewer than 20 cases will not score fully, a measure with a benchmark you cannot reach may be worth swapping for one you can, a topped-out measure has a capped score, and a Quality measure below the data completeness floor will score zero regardless of performance. This is the moment to fix it, not March 30. If a location or a provider is missing from the EHR extract, the data completeness percentage is the first place it shows.
Week four: submit, save the receipt, and document
- Submit at least three business days before March 31. The portal and registries slow down in the last 48 hours.
- Download and save the submission confirmation and the preliminary score for each clinician or the group, with the date.
- File the supporting documentation for Improvement Activities and, if submitted, Promoting Interoperability in one folder: the security risk analysis with its date, the SAFER Guides attestation, activity descriptions and dates. CMS audits a sample of submissions and asks for this later, sometimes years later.
- Record who submitted, when, and by which method, in the practice's compliance log.
- Read the final feedback report when CMS releases it in the summer, and note the targeted review deadline in case the score is wrong.
The mistakes we see every March
Reporting as individuals when the group would score better, or the reverse. If you report both, CMS uses the higher score for each clinician. There is no penalty for reporting both ways if your registry supports it.
Assuming the EHR vendor submitted. Some do, most require the practice to review and approve. A vendor dashboard that says "ready" is not a submission.
Submitting Promoting Interoperability as a small practice without checking the score. The automatic reweighting protects you only if you do not submit the category. A practice that uploads PI data with no 2024 security risk analysis turns a zero-weight category into a zero score on 25 percent of its total.
Forgetting the security risk analysis where PI does count. It has to have been performed during the 2024 calendar year. The proposed HIPAA Security Rule published in January is a reminder of how central this document has become for reasons beyond MIPS.
Ignoring Cost. Nothing to submit, but 30 percent of the score. Practices with high episode costs relative to peers are surprised by low final scores despite good Quality data, and the only lever is next year's referral and utilization patterns.
Questions we hear
We are required to report but our Quality data is bad. Is it better to submit nothing?
No. Submitting nothing when required scores zero and draws the full negative 9 percent. Submitting even a partial set of measures, plus Improvement Activities, scores something, and the adjustment is scaled. A weak submission is always better than none for a clinician who is required to report.
Can we still apply for a hardship exception for 2024?
The 2024 exception applications closed on December 31, 2024. Small practices do not need one for Promoting Interoperability because the reweighting is automatic. For other circumstances, the only route now is to submit what you have and, if the score is wrong, request a targeted review after the feedback report.
What does Revelrex do with MIPS?
Our PCMH annual review and closing gaps in care services work from the same quality measure data, and our training courses cover MIPS reporting for small practices. We do not promise a score; we make sure the data that exists gets submitted correctly and on time.
What to do this month
- Confirm eligibility per NPI and for the group, and decide the reporting level by March 10.
- Confirm the HARP account holder is still with the practice and can log in today.
- Get the preliminary score report from your registry by March 17 and fix measure selection and data completeness.
- Small practices: decide whether to submit Promoting Interoperability at all; if the 2024 security risk analysis is missing, do not.
- Submit by March 26, save the confirmation, and file the documentation in one folder.
- Put the summer feedback report and the targeted review window on the calendar.
