The Quality Payment Program opened the 2025 performance year submission window on January 2, 2026. It closes March 31, 2026 at 8 p.m. Eastern. Between those dates, every MIPS-eligible clinician or group that does not submit data, and is not otherwise excluded, is headed for the maximum negative payment adjustment on 2027 Medicare Part B claims, which is 9 percent.
We have watched too many practices treat MIPS as a March task. The practices that submit in March are the ones whose quality registry finds a data completeness problem on March 20, or whose EHR vendor needs two weeks to produce the promoting interoperability report, or whose group had a clinician leave in August and nobody checked how that changed eligibility. Here is how we sequence the twelve weeks.
The stakes are asymmetric. The performance threshold for the 2025 performance year is 75 points. A final score below 75 produces a negative adjustment on a sliding scale, and a score at or below 18.75 points, or no submission at all, produces the full 9 percent cut. A score above 75 earns a positive adjustment, but the positive side is budget neutral and scaled, and in recent years it has been small. So the realistic goal for most independent practices is not to win MIPS. It is to clear 75 with data you already have, and to do it without a scramble.
Key takeaways
- The 2025 submission window runs January 2 to March 31, 2026 at 8 p.m. Eastern, and no submission means a 9 percent cut on 2027 Part B payments for every eligible clinician.
- Check eligibility per NPI in the QPP participation status tool before anything else; a clinician who joined or left mid-year changes the picture.
- Quality needs six measures with one outcome or high-priority measure, 75 percent data completeness and at least 20 cases each to be scored against a benchmark.
- Promoting interoperability fails as a whole category if one required measure is zero without an exclusion, or if the security risk analysis was not done during 2025.
- Submit two weeks early, read the preliminary score by category, screenshot everything, and correct before the window closes.
Week 1 to 2: confirm who is in and how you are reporting
Look up every NPI in the QPP participation status tool for the 2025 performance year. The tool tells you whether each clinician is MIPS eligible individually, whether the group is eligible, and whether any clinician qualifies for an exclusion such as the low-volume threshold or first-year status. Eligibility is determined by two review periods during 2025, and a clinician who joined mid-year may have a different status than the group assumes.
Then confirm the reporting choice: individual, group, or an APM entity. A group submits once under the TIN and every clinician in the TIN gets the group score. A practice that added clinicians during 2025 may find that group reporting protects a new clinician who has no individual data, or it may find that one low performer drags the group down. Run both scenarios if your registry can, but decide by the end of January, because the data pull differs.
If your clinicians participated in an ACO during 2025, the ACO usually reports quality on their behalf. Confirm with the ACO in writing what they are submitting and what, if anything, remains for the practice.
Week 3 to 6: quality
Quality is 30 percent of the final score for most participants, and it is where the data problems live. You need six measures, including one outcome measure (or a high-priority measure if no outcome measure applies), each meeting data completeness of at least 75 percent of the eligible denominator across all payers, with at least 20 cases per measure to be scored against a benchmark.
Pull the measure performance report from your registry or EHR now and check three things per measure. First, denominator size: fewer than 20 cases means the measure earns points for reporting but is not scored against the benchmark. Second, data completeness: if the denominator in the report is smaller than the visits you know you had, encounters are being excluded because a field was not captured. Third, performance rate against the published benchmark deciles, so you know which measures carry the score.
| Check | Where to look | What to do if it fails |
|---|---|---|
| Six measures with one outcome or high priority | Registry measure selection | Add a measure your data already supports; do not add one you would need to abstract by hand |
| Data completeness at or above 75 percent | Registry completeness report | Fix the field mapping and re-run; ask the vendor how long a re-pull takes |
| At least 20 cases per measure | Denominator count | Consider a different measure or accept the reporting-only points |
| Performance rate against benchmark | Registry benchmark comparison | Check for documentation captured in the wrong field, which is often the real cause of a low rate |
The topped-out measures, where almost everyone scores near 100 percent, are capped at seven points. If your six measures are all topped out, your quality category has a ceiling well below the maximum. That is a 2026 planning problem, not a March 2026 problem, but note it now.
Small practices, meaning 15 or fewer clinicians, get two things worth knowing about here. They receive six bonus points in the quality category as long as at least one measure is submitted, and measures that fall short of the 20-case minimum still earn three points each rather than zero. For a five-physician practice with weak denominators, those rules are often the difference between clearing 75 and not. Confirm your small practice status in the participation tool; it is determined by CMS from claims, not by what you believe your size to be.
Week 5 to 8: promoting interoperability
Promoting interoperability requires a continuous 180-day performance period during 2025 using certified EHR technology, a security risk analysis completed during the year, the SAFER Guides attestation, and reporting on the required measures including e-prescribing, health information exchange, provider-to-patient exchange and public health reporting. Ask your EHR vendor for the PI report for a 180-day window that ends December 31, 2025, and read the numerators. A zero on a required measure without a valid exclusion scores the whole category at zero, and the category is 25 percent of the final score.
The security risk analysis must have been completed during calendar 2025. If it wasn't, you cannot fix that now, and the honest answer is that the PI category cannot be attested. Practices with 15 or fewer clinicians, and certain other groups, may qualify for automatic reweighting of PI to quality; check your status before assuming.
Week 7 to 9: improvement activities and cost
Improvement activities need attestation to activities performed for at least 90 consecutive days during 2025. Small practices attest to fewer activities than large ones. The documentation is not submitted, but it must exist, because CMS audits a sample every year. Pull the evidence into one folder now: the policy, the report, the meeting notes, whatever shows the activity happened.
Cost is calculated by CMS from claims. There is nothing to submit, but there is something to read: the 2024 cost feedback in your QPP account tells you which episode-based measures you were attributed and how you scored, which is the only preview you get.
Week 10 to 12: submit, screenshot, review
Submit at least two weeks before the deadline. The QPP portal shows a preliminary score after submission; read it category by category and compare to what the registry projected. Take screenshots of the confirmation page and each category summary. Then, if something looks wrong, there is time to correct and resubmit before March 31. Submissions can be updated until the window closes; the last one stands.
Final scores and the 2027 payment adjustment are released in the summer, with a targeted review period afterward for disputing a score. Keep everything from this submission in one place because the targeted review will ask for it.
Our practice transformation team works alongside billing to line up quality data, and if your team wants a walk-through of the QPP portal, the live courses on our training page include QPP reporting.
Questions we hear
We are below the low-volume threshold. Do we need to do anything?
No, unless you want to opt in. Check the participation status tool and save a copy of the result; it is your evidence if a payment adjustment appears in error. Note that opting in is irreversible for the year.
Our EHR vendor says our quality data is submitted automatically. Is that true?
Sometimes. Some vendors submit as a qualified registry with your authorization. Many produce a file you must upload. Get the answer in writing, including the date the vendor will submit, and log into the QPP portal yourself afterward to confirm the data is there.
Our practice had a major EHR outage and a staff turnover in 2025. Is there any relief?
Possibly. The extreme and uncontrollable circumstances exception application is the mechanism, and it can reweight one or more categories to zero. The application window for the 2025 performance year closed at the end of 2025 for most practices, so if you did not apply, the remaining option is to submit what you have and make sure the categories you can support are complete. If your area was affected by a declared disaster, CMS sometimes applies an automatic policy; check the QPP exception page for your county before assuming either way.
What to do this week
- Look up every NPI in the QPP participation status tool for 2025 and record eligibility, small practice status and any exclusions.
- Decide individual, group or APM entity reporting by January 31 and tell the registry or EHR vendor.
- Pull the quality measure performance report and check denominators, completeness and benchmark position for six measures.
- Request the 180-day promoting interoperability report from the EHR vendor and confirm the 2025 security risk analysis is dated and on file.
- Gather improvement activity evidence into one folder with the 90-day dates marked.
- Put the submission on the calendar for the week of March 16 so there is time to read the preliminary score and correct.
