Every year in the first days of August we get the same call. A practice manager has just noticed that the quality dashboard in the EHR shows 40 percent data completeness on a measure that needs 75, or that nobody has documented the security risk analysis, or that the group's MIPS eligibility changed when a provider left in March. In August there is still time. In November there usually is not.
The 2025 performance year is a stable one on paper. The performance threshold is 75 points for the fourth year running, the category weights have not changed, and the penalty for scoring below the threshold remains a sliding scale down to a 9 percent cut in 2027 Medicare Part B payments. Stable rules are exactly when practices get complacent, so this is our midyear list.
Key takeaways
- The 2025 rules are unchanged from 2024: a 75-point threshold, the same category weights, and a penalty of up to 9 percent on 2027 Part B payments for scoring below it.
- The last possible start date for a 180-day Promoting Interoperability window was July 5, so the question now is whether the required measures have data for the window you will pick, not whether one exists.
- Quality data completeness is 75 percent of eligible encounters across all payers for the whole year; a measure at 55 percent in July needs a workflow fix this month, not in November.
- Check eligibility for every NPI and the TIN in the participation status tool rather than assuming; practices report for excluded clinicians and forget eligible ones every year.
- MVP registration closes December 1 and hardship exception applications close December 31; both are dates to put on the calendar now.
The numbers that govern 2025
| Element | 2025 requirement |
|---|---|
| Performance threshold | 75 points |
| Category weights (traditional MIPS) | Quality 30 percent, Cost 30 percent, Promoting Interoperability 25 percent, Improvement Activities 15 percent |
| Quality data completeness | 75 percent of eligible encounters across all payers, for the full calendar year |
| Promoting Interoperability period | A minimum of 180 continuous days within 2025 |
| Improvement Activities period | A minimum of 90 continuous days |
| Payment adjustment | Up to 9 percent negative on 2027 Part B payments; positive adjustments scaled to the budget-neutral pool |
| Submission window | Opens early January 2026 and closes March 31, 2026 |
Checkpoint 1: confirm who is actually eligible
Look up every clinician's NPI in the QPP participation status tool, and look up the group TIN. Eligibility is determined at the TIN and NPI level and can change between the two determination periods. A provider who joined the group in 2025 may be eligible under the old TIN and not the new one. A group that dropped below the low-volume threshold ($90,000 in Part B allowed charges, 200 Part B patients, or 200 covered services) is excluded unless it opts in. Practices routinely report for people who are excluded and forget people who are not.
Also confirm your special status flags: small practice (15 or fewer clinicians), rural, health professional shortage area. Small practice status brings six bonus points in the quality category and the option to reweight Promoting Interoperability. Those flags are worth checking rather than assuming.
Checkpoint 2: traditional MIPS or an MVP
MIPS Value Pathways are optional in 2025, and registration runs through December 1. An MVP narrows the quality measure set to a specialty-relevant group and can simplify reporting, but it also fixes your cost measures and requires a population health measure. If your specialty has an MVP, compare the measure list against the traditional measures you already collect. Switching in August is realistic only if the data already exists in the EHR. Otherwise, note it for 2026 and report traditional MIPS this year.
Checkpoint 3: Promoting Interoperability
The 180 continuous days must fall within calendar 2025, which means the latest possible window began on July 5. If your EHR has been in use all year, this is not a crisis: you choose the window at submission time and it can be January through June. What matters is that the required measures have data for the window you pick.
- Run the PI dashboard for a January to June window today. Every required measure should have a numerator and denominator, or a valid exclusion.
- Confirm the security risk analysis has been performed, or is scheduled, during 2025. It must be done in the performance year, and a report from 2024 does not count.
- Confirm the SAFER Guides attestation and the actions to limit or restrict information blocking attestation are on the submission checklist.
- Check public health reporting: immunization registry and electronic case reporting are required unless an exclusion applies, and active engagement has to be documented.
- Confirm the EHR vendor's certification ID for the 2025 edition. Vendors change these, and the wrong ID fails the whole category.
If you qualify for a hardship exception (small practice, EHR decertification, extreme circumstances), the application deadline is December 31, 2025. Apply if you need it. We see practices take a zero in PI because nobody knew the form existed.
Checkpoint 4: quality data completeness
The 75 percent data completeness rule trips more practices than any other. It counts all payers, not just Medicare, and it counts the full year. If a measure shows 55 percent completeness at the end of July, the practice has five months of encounters to raise the average, and the arithmetic is unforgiving: it needs well above 75 percent on the remaining visits to finish at 75.
The usual cause is a workflow gap, not a documentation gap. The blood pressure was taken but recorded in a field the measure logic does not read. The depression screening was done on paper. The tobacco status was captured by the nurse in a note rather than the structured field. Find the field the measure reads, and make sure the person doing the work is using it. Then re-run the dashboard in two weeks.
Pick your six measures now, including one outcome or high-priority measure, and drop any topped-out measure that is capped at seven points unless it is the only one available. Check the benchmark for each measure against your current rate. A measure at 95 percent with a benchmark decile that tops out at 92 is worth more than a measure at 98 percent that everyone scores 99 on.
Checkpoints 5 and 6: cost and improvement activities
Cost, which you cannot fix in August
Cost is 30 percent of the score and is calculated from claims. There is nothing to submit, and there is very little to change by midyear. What you can do is understand which episode-based measures and which total per capita cost attribution your group is likely to receive, and make sure the practice is not carrying costs that belong elsewhere. Our view is that cost has become the category where good practices lose points for reasons they cannot see, and the feedback report you receive next summer is the only real window into it. Read last year's.
Improvement activities
Ninety continuous days is easy to satisfy and easy to forget to document. Choose your activities now, assign one person to gather the evidence (policies, screenshots, meeting notes, registry reports), and store it in one folder. Attestation is on the honor system until an audit, and CMS does audit.
Questions we hear
We are in an ACO. Do we still need this?
Shared Savings Program ACO participants report quality through the APM Performance Pathway, and the ACO usually handles it, but PI is still reported by each practice or group. Confirm with your ACO who submits what.
Is it worth aiming above 75?
The positive adjustment pool is small and has been for years. Our advice is to secure 75 with certainty and spend the remaining effort on the work that improves care and payer contracts, rather than chasing a fraction of a percent. Practices working toward PCMH recognition often find that the same structured data does double duty in MIPS quality and improvement activities, and that is a better return than an extra five points.
We switched EHRs in May. Can we still report Promoting Interoperability?
Yes, if the new system is certified and has been in use continuously since the go-live. A May 1 go-live gives you a window from May 1 to October 27 at the earliest, and any 180 days from then to December 31. What you cannot do is stitch together data from two systems into one window unless both were certified and the measures can be reported across them, which is rarely practical. Run the PI dashboard in the new system for the window you intend to use, and if the migration broke a measure (public health registry connections are the usual casualty), look at the hardship exception categories before December 31.
What to do this month
- Print the participation status for every NPI and the TIN, and file it.
- Run the PI dashboard for January to June and list any measure without data.
- Run the quality dashboard for year to date, and list every measure below 75 percent completeness with the field it reads.
- Schedule the 2025 security risk analysis if it has not been done.
- Decide traditional MIPS or MVP, and if MVP, register before December 1.
- Put the January to March 2026 submission window on the calendar with a named owner.
