In its proposed 2025 QPP regulations the CMS will:

• Leave the performance threshold to 75 points for 2025, which the CAP opposes due to the increased burden on pathologists.
• Maintain the data completeness threshold at 75 points for 2025, a previously finalized policy.
• Not add or remove any measures from the Pathology Specialty Measure Set.
• Reduce the available options for Improvement Activities, including several IAs that are commonly performed by pathologists.
• CMS continues to implement MIPS Value Pathways (MVPs) and for the first time, has included two pathology quality measures in a new proposed MVP: Dermatological Care.
  • Participants need at least 4 quality measures in order to report an MVP.
  • The CAP will evaluate the potential impact of this proposal on pathologists, as well as CMS’ request for input on developing MVPs for non-patient-facing specialties.

The CAP continues to advocate for pathologists’ success in the MIPS program. We encourage practices (and their billing companies) to review the scoring changes and contact CAP at mips@cap.org to understand the availability of higher-scoring measures and how to best report them.

Advanced Alternative Payment Models (APMs)

For the Advanced APM track, if an eligible clinician participates in an Advanced APM and achieves Qualifying APM Participant (QP) or Partial QP status, they are excluded from the MIPS reporting requirements and payment adjustment. According to CMS, the agency continues to focus on transforming health care delivery towards the goal of having all traditional Medicare beneficiaries in an accountable care relationship with their health care provider by 2030. In this proposed rule, CMS is proposing changes around beneficiary attribution for purposes of QP determinations. The proposed rule also incorporates changes made by Congress to continue the APM Incentive Payment amount for the 2026 payment year (performance year 2024) of 1.88 percent.