An Overview - Quality Payment Program (QPP) - 2025
The Quality Payment Program (QPP) is a Medicare program that rewards physicians and other clinicians for providing high-quality care, improving interoperability and achieving positive patient outcomes. This interactive guide will provide you with a simplified overview to help you understand the history and evolution of QPP, the eligibility criteria, collection methods, pathways, critical updates and challenges. The landscape for quality reporting has changed significantly, penalties for non-compliance have increased and it is challenging to achieve a higher score by default. The key to succeeding in QPP lies in strategic alignment, technical readiness, and early action.
QPP Timeline
This interactive timeline traces the policy evolution from the Sustainable Growth Rate (SGR) era from pre-2015 to the sophisticated 2025 QPP program. Click on the timeline and "plus sign" era to get an overview of legislative and regulatory shifts that have increased administrative and technical burden for providers and ACOs.
Pre-2015: The SGR Era
"Fee-for-service, Low Quality Accountability"
2009-2014: The Meaningful Use Era
"Fragmented compliance programs emerge"
2015: Introduction of MACRA
"The Change Begins"
2017 - 2024: QPP Launch & Refinement
"The Value Based Care Era"
2025 – Sophisticated Quality Payment Program
"High Readiness, Early Action, Proactive Intervention"
Paradigm Change in 2025
The United States healthcare industry's journey from the fragmented programs under SGR, to MACRA and the final shift towards value-based care and increased accountability is consolidated in the QPP 2025 program structure. The Centers for Medicare & Medicaid Services (CMS) provided extensions related to the Alternative Payment Model (APP) track of the Quality Payment Program (QPP) in both 2023 and 2024, to ensure that organizations are ready for the new reporting methods.
Administrative Evolution
- Increased data and documentation burdens
- Higher expectations for interoperability
- Enhanced care coordination requirements
- Complex reporting infrastructure needs
Strategic Implications
- Shift from volume to value-based care
- Technology investment requirements
- Staff training and expertise needs
- Risk management and compliance focus
Summary of Keypoints of 2025 QPP Program
Expanded APP Reporting
The APP framework is now the primary path for ACOs, requiring submission of Medicare CQMs, eCQMs, and MIPS CQMs. Data aggregation across your network is critical.
To meet program requirements, ACOs must now submit one or more of the following types of quality measures:
- Medicare Clinical Quality Measures (Medicare CQM)
- Electronic Clinical Quality Measures (eCQMs)
- MIPS CQMs
This shift emphasizes network-wide data aggregation, which requires ACOs to extract and combine data from multiple electronic health record (EHR) systems across participant TINs. CMS expects not only submission of high-quality data but also the demonstration of consistency, completeness, and traceability—placing a premium on robust health IT infrastructure and interoperability.
Increased Data Thresholds
For the 2025 performance year, the data completeness threshold for all eCQMs and MIPS CQMs rises from 70% to 75%. This means that for each submitted quality measure, ACOs and clinicians must report data on at least 75% of all eligible patients, regardless of payer source (not just Medicare).
This significant increase introduces operational challenges, including:
- Enhanced EHR integration across ACO networks
- Data validation and audit participation
- Timely documentation and coding accuracy
Failing to meet the threshold may lead to invalid measure submissions or a zero-point score, impacting overall MIPS or APP scores and future Medicare reimbursements.
MVP Pathway Viability
CMS continues to expand the MIPS Value Pathways (MVPs) model in 2025, offering more specialty-specific, condition-based, or episode-driven reporting options for individual clinicians or groups not aligned with ACOs. MVPs are designed to reduce reporting burden and increase relevance by aligning quality measures with clinical focus areas.
However, for ACO participants, MVPs may be viable only for subgroups or non-ACO-aligned TINs. Key considerations for using MVPs in 2025 include:
- Measure set compatibility with your patient population
- Reporting infrastructure readiness
- Overlap with APP and MSSP requirements
A detailed MVP-to-ACO alignment analysis is crucial before electing this pathway.
QPP Eligibility
Understanding your eligibility for the Quality Payment Program is the first step in determining your reporting requirements and pathway options for 2025.
2025 Eligibility
ACO Eligibility
- Must be a Medicare Shared Savings Program (MSSP) ACO
- Must have assigned beneficiaries
- Must meet ACO-specific reporting requirements
- Must have valid ACO agreement with CMS
Individual Clinician Eligibility
- Must be a Medicare-enrolled clinician
- Must meet low-volume threshold criteria
- Must not be a Qualifying APM Participant (QP)
- Must not be in first year of Medicare enrollment
Group Practice Eligibility
- Must have 2+ eligible clinicians
- Must meet group-level volume thresholds
- Must not be exclusively in Advanced APMs
- Must have valid Tax Identification Number (TIN)
2025 Volume Thresholds
ACOs:
- Medicare Part B claims: $90,000 or more
- Medicare patients: 200 or more
- Covered professional services: 20 or more
- Across all eligible clinicians in the ACO network
- Must be a Medicare Shared Savings Program (MSSP) ACO
- Must have assigned beneficiaries
Individual Clinicians:
- Medicare Part B claims: $90,000 or more
- Medicare patients: 200 or more
- Covered professional services: 20 or more
- Must have assigned beneficiaries
Group Practices:
- Medicare Part B claims: $90,000 or more
- Medicare patients: 200 or more
- Covered professional services: 20 or more
- Across all eligible clinicians in the group
Exemptions and Exceptions
Automatic Exemptions:
- New Medicare-enrolled clinicians (first year)
- Qualifying APM Participants (QPs)
- Partial QPs with sufficient APM participation
- Clinicians below all volume thresholds
Hardship Exceptions:
- Insufficient internet connectivity
- Extreme and uncontrollable circumstances
- EHR certification issues
- Practice closure or bankruptcy
COLLECTION TYPES
Defining MIPS Collection Types
Collection types are the way you report the data to CMS. There are six collection types in 2025.
eCQMs
(Electronic Clinical Quality Measures)Electronic Clinical Quality Measures from certified EHR technology using structured data.
MIPS CQMs
MIPS Clinical Quality Measures with flexible data sources and formats.
QCDR Measures
(Qualified Clinical Data Registry)Specialty-specific measures submitted through qualified clinical data registries.
Medicare Part B Claims Measures
Automatically calculated from Medicare Part B claims data by CMS.
CAHPS for MIPS Survey
Patient experience and satisfaction data collected through standardized surveys.
CMS Web Interface Measures
(available for MSSP ACOs only)Web-based reporting interface for MSSP ACOs (being phased out in 2025).
Collection Type Comparison
| Collection Type | Best For | Advantages | Considerations |
|---|---|---|---|
| eCQMs | Large practices, integrated health systems | Real-time data, comprehensive reporting, preferred by CMS | EHR certification requirements, technical setup, 75% threshold |
| MIPS CQMs | Flexible practices, multiple data sources | Flexible data sources, multiple formats, preferred by CMS | Data aggregation challenges, 75% threshold |
| QCDR Measures | Specialty practices, quality-focused groups | Specialty-specific measures, registry expertise | Registry fees, manual data entry, limited to specialty |
| Medicare Part B Claims | Small practices, low-volume clinicians | No additional reporting, automatic calculation | Limited measure availability, claims lag, 60% threshold |
| CAHPS for MIPS Survey | Patient experience focus, primary care | Patient perspective, experience measures | Response rates, survey administration, high burden |
Your 2025 Reporting Pathway
For performance year 2025, ACOs have several MIPS reporting options. This section allows you to compare the primary pathways to determine the best fit for your organization. Select a pathway to see its specific requirements, scoring weights, and key considerations.
Scoring Breakdown
Exemption Eligibility
Clinicians may be exempt from MIPS due to low-volume thresholds, QP status in an Advanced APM, or other exceptions. ACOs must track eligibility network-wide to manage reporting burdens.
APP Deep Dive
Performance Categories: Challenges & Solutions
Each MIPS performance category presents unique operational challenges for ACOs in 2025. This section provides a focused analysis of the common "pain points" within each domain and highlights key changes. Use the tabs to explore each category.
Resources & Glossary
This final section contains a glossary of common acronyms used throughout this analysis and links to official CMS resources for further reading. Use the search bar to quickly find definitions.