A three-physician cardiology group called us last week with a familiar question. Their registry vendor had sent the quality data in January, the practice manager assumed the job was done, and nobody had logged into the Quality Payment Program portal to look. When she finally did, the Promoting Interoperability category showed nothing at all. The EHR vendor had exported the report to a shared drive in December and it had never been uploaded.
That is the shape of most MIPS problems we see in March. The work was mostly done. The last mile, the part where a person checks what CMS actually received, was skipped. The 2025 performance year submission window opened January 2, 2026 and closes March 31, 2026 at 8 pm Eastern. After that time CMS accepts no corrections. Whatever is in the portal at 8:01 pm is your score.
This article is the four-week plan we walk practices through in March. It assumes you are a MIPS-eligible clinician or group reporting traditional MIPS. If you report through an MVP or an APM Entity the mechanics differ slightly, but the checks are the same.
Key takeaways
- The 2025 performance threshold is 75 points. Below it, the 2027 Part B payment adjustment is negative, down to minus 9 percent for a score of zero or no submission.
- Cost is calculated by CMS. Quality, Improvement Activities and Promoting Interoperability all need something from you, and a blank attestation zeroes the whole PI category.
- Vendors submit what you gave them, when you told them to. The only way to know what CMS has is to log in with a HARP account and look at the preview.
- Aim to have everything visible in the portal by March 24 and use the last week to fix what looks wrong, not to upload for the first time.
What is at stake this year
The performance threshold for the 2025 performance year is 75 points. Score below it and the payment adjustment applied to your 2027 Medicare Part B professional claims is negative, on a sliding scale down to minus 9 percent for a score of zero or for not reporting at all. Score above it and the adjustment is positive, though the positive side is funded by the penalties collected from everyone else, so it has been small for several years. In our experience the realistic goal for most independent practices is to clear 75 and stop worrying, not to chase a bonus.
A 9 percent cut sounds abstract until you put your own numbers next to it. A practice that bills $1.2 million a year in Medicare Part B professional services would give up $108,000 across 2027. That is more than a full-time biller. It is also entirely avoidable, because the cut for not reporting is the same as the cut for reporting badly, and reporting something is not hard.
The penalty is also sticky in a way people forget. It applies to every Part B professional claim the TIN and NPI combination submits during calendar year 2027, including claims for patients who were not in any of your quality measures, and it is applied by the Medicare Administrative Contractor at payment time. There is no appeal once the targeted review window closes, and there is no way to earn it back mid-year.
Week one: confirm who has to report
Run every NPI in the practice through the QPP Participation Status Tool. Eligibility is set per TIN and NPI combination, and it changes. A clinician who joined mid-2025 may fall under the low-volume threshold this year and be excluded. A clinician who was excluded last year may be in this year. We also see practices that assume a Qualifying APM Participant status that lapsed when their ACO contract ended.
Decide, if you have not already, whether you are reporting as a group or as individuals. Group reporting means one submission covers everyone under the TIN and everyone gets the same score. Individual reporting lets a strong performer avoid being pulled down, but it multiplies the work. Most practices under 15 clinicians report as a group.
Also confirm your special status flags in the tool: small practice (15 or fewer clinicians), rural, health professional shortage area, non-patient-facing. Small practice status matters more than people realize. It adds six bonus points to the Quality numerator, allows Improvement Activities to be satisfied with fewer activities, and can qualify you for automatic reweighting of Promoting Interoperability if you apply for a hardship exception. If the tool shows the wrong status, the fix goes through the QPP Service Center, and it takes time.
Week two: check every category, not just quality
The four performance categories and their weights for the 2025 performance year are Quality at 30 percent, Cost at 30 percent, Improvement Activities at 15 percent and Promoting Interoperability at 25 percent. Cost is calculated by CMS from claims and needs no submission. The other three need something from you.
| Category | Weight | What CMS needs from you | Common failure |
|---|---|---|---|
| Quality | 30% | Six measures including one outcome or high-priority measure, 75% data completeness | Registry sent data for five measures; sixth never mapped |
| Cost | 30% | Nothing; CMS calculates from claims | None to submit, but it cannot be improved after the fact |
| Improvement Activities | 15% | Attestation to activities for a continuous 90 days | Nobody attested; activities were done but never recorded |
| Promoting Interoperability | 25% | Numerators and denominators for required measures plus attestations (security risk analysis, SAFER guide, information blocking) | Report exported but never uploaded; security risk analysis attestation left blank |
The Promoting Interoperability row deserves a second look. Reporting the measures is only part of it. You also attest yes to having completed a security risk analysis during the performance year, yes to the SAFER Guides self-assessment, and to the prevention of information blocking statements. A missing attestation zeroes the whole category. That is 25 points, which is most of the gap between passing and failing.
Data completeness is the other quiet failure. For 2025 each quality measure must include at least 75 percent of the eligible patients across all payers, not just Medicare. A registry that only received your Medicare encounters, or an EHR report filtered to one location, can leave a measure below the threshold. A measure below data completeness scores zero points if you are not a small practice and three points if you are, regardless of how well you performed on it.
Week three: log in and preview
Whoever owns MIPS in your practice needs a HARP account connected to the TIN, with the Security Official or Staff User role. If the only person with access left the practice in 2025, sort that out now; identity verification takes days, not minutes.
Once inside, the portal shows a preliminary score for each category as data arrives. Registries and EHR vendors usually submit on your behalf, but you can see what they sent. Compare the measure list against what you agreed to report. Check that the performance rates look like your own numbers and not a default. If a measure shows a performance rate of zero with a denominator of several hundred, something mapped wrong.
We also recommend looking at the preliminary Quality score against the measure benchmarks. A measure with no benchmark caps at three points regardless of how well you did. If two of your six measures are unbenchmarked and you are hovering near 75, swap one before the deadline if your registry allows it.
Here is the arithmetic for a practice that is close. Suppose Quality is showing 22 of 30 points, Cost is estimated at 18 of 30 (you will not see the final Cost score until summer, so use last year as a guide), Improvement Activities is blank, and Promoting Interoperability is showing 20 of 25. That is 60 points with 15 sitting on the table. A completed Improvement Activities attestation, twenty minutes of work, takes the practice to 75. Nothing else in the portal is that cheap.
Week four: submit, then confirm
Do not leave the final upload for March 31. The portal slows down in the last 48 hours every year and vendor support queues fill up. Aim to have everything visible in the portal by March 24 and use the last week to fix what looks wrong.
When the score preview matches what you expect, save a screenshot or PDF of each category page with the date visible. In our experience this is the single most useful piece of paper you will have if there is a dispute later during the targeted review period, which typically opens when final scores are released in the summer.
One more check that takes five minutes: open the submission for each clinician if you reported individually, or the group submission if you reported as a group, and confirm the status reads as submitted rather than saved or in progress. We have seen a practice lose a year because a submission was saved as a draft and the person who saved it assumed that was the same thing.
Mistakes we keep seeing
- Assuming the vendor submitted. Vendors submit what you gave them, when you told them to. Log in and check.
- Reporting Quality and forgetting Improvement Activities. Attestation takes twenty minutes and is worth 15 points.
- Leaving the security risk analysis attestation unanswered because the analysis was done by an outside IT firm and nobody has the report. Get the report.
- Reporting as a group but only submitting one clinician's EHR data. Group reporting aggregates across the TIN.
- Reporting a measure below data completeness because the registry only saw Medicare patients. Check the denominator against your own visit counts.
- Missing the hardship route. The Extreme and Uncontrollable Circumstances application window for 2025 closed at the end of the year, so it is too late for this cycle, but if a disaster or EHR failure affected 2026, calendar the 2026 application deadline now.
Questions we hear
We only see a handful of Medicare patients. Do we still have to report?
Check the Participation Status Tool. The low-volume threshold excludes clinicians with $90,000 or less in Part B allowed charges, 200 or fewer Part B patients, or 200 or fewer covered services. You have to fall under all three to be excluded automatically. If you exceed one or two, you can opt in but are not required to.
Our score preview is 71. Is there anything we can do in March?
Sometimes. Improvement Activities is the fastest lift if it is empty. Adding a benchmarked quality measure in place of an unbenchmarked one can help if your registry still accepts changes. Promoting Interoperability attestations that were left blank are free points. Cost cannot be changed.
Should we pay someone to handle this?
If the practice has never cleared the threshold or nobody owns the portal, an outside pair of hands for the last two weeks of March is usually cheaper than a year of penalties. Our RCM audit includes a MIPS readiness check, and our live RCM training covers the QPP portal walkthrough every winter. Rates are on the pricing page.
What to do this week
- Run every NPI through the QPP Participation Status Tool and write down eligibility, group or individual status, and special status flags.
- Confirm one person in the practice has a working HARP login connected to the TIN and can see the 2025 submission.
- Open each category in the portal and note what is showing: measure count, performance rates, attestations, and whether the status is submitted or saved.
- Ask your registry and EHR vendor, in writing, for the date they submitted and a copy of what they sent.
- Book a thirty-minute review for March 24 to compare the preview against your expectations while there is still time to fix it.
