Every year, the Quality Payment Program (QPP) Merit-Based Incentive Payment System (MIPS) measure categories are reviewed, and changes are published in the Federal Register within the Medicare Physician Fee Schedule Final Rule.1 For eye care practices, the changes for 2025 range from minimal in the Quality and Promoting Interoperability categories to substantial in the Cost and Improvement Activities categories. A new Complete Ophthalmologic Care MIPS Value Pathway (MVP) was also developed and is available for reporting. Here, we respond to frequently asked questions we have received thus far.
Quality
Q: Are there changes in the Quality category?
A: Overall, this category does not appear to have significant changes beyond minor verbiage alterations. Quality must still be reported for the whole year, and the Centers for Medicare & Medicaid Services (CMS) will still consider your best-scoring measures to calculate your quality score. It is best practice to review the CMS specification sheets2 for your chosen measures and check your electronic health record (EHR) vendor’s updated workflows to ensure your practice’s documentation is adequate and workflows do not need tweaking in 2025.
Promoting Interoperability (PI)
Q: Has anything changed with PI for 2025?
A: Not that we have seen. Small practices are still automatically exempt unless they choose to report. The 180-day reporting period and the requirement to complete your Security Risk Analysis (SRA)3 and Safety Assurance Factors for EHR Resilience (SAFER) Guide4 remain in effect. Be sure to download new versions of the assessment tools to capture any requirement updates. You must make progress in setting up electronic case reporting unless eligible for an exclusion, with one year allowed in the Pre-Production and Validation5 phase and the second year required for Validated Data Production.
Additionally, if you e-prescribe controlled substances (Schedule II opioids or Schedule III or IV drugs), you must still attest “yes” for participation with your state’s Prescription Drug Management Program (PDMP) for at least one prescription sent.5
Improvement Activities (IA)
Q: We have used the 24/7 Access measure for years; is it still available?
A: Unfortunately, no. You will need to pick a different measure. However, the IA category has been simplified! Small practices only need one measure, while large practices must select two. Elimination of “medium” and “high” weighting means you can now pick any relevant measure to perform for 90 days.
Cost
Q: This seems complicated; what do I need to know?
A: Cost appears to be where the most significant changes have occurred. The Cataract Removal with Intraocular Lens (IOL) Implantation6 Cost measure has substantive inclusion updates which include mild eye disease comorbidities and additional Medicare Part B services that CMS will consider related to the cataract surgery event. You can review the 2025 measure codes list to see exactly what will be included in the measure and the excluded diagnoses. For example, non-proliferative diabetic retinopathy and primary open-angle glaucoma of any severity are no longer excluded. Additionally, emergency department and office visits for related conditions, and durable medical equipment (DME) (spectacle lenses) will also be included in the cost calculation.6
Additional pass-through ambulatory surgery center (ASC) drugs have been added to include Dextenza (dexamethasone ophthalmic insert, Ocular Therapeutix) (J1096) and IHEEZO (chloroprocaine hydrochloride, Harrow) (J2403). Omidria (phenylephrine and ketorolac intraocular solution, Rayner Surgical Group) (J1097) and others included in 2024 will continue to count toward your cost score. CMS responded to comments and concerns by saying, “Not including these medications would result in important costs not being captured when looking at the overall costs of a cataract removal episode.”7
Don’t be discouraged—the cost category calculation methodology has changed in a positive way. CMS estimates that the calculation change will allow for an increase of about 3.89 points8,9 for each participant over the previous year with similar performance, and this calculation methodology should be applied to 2024 scoring.9
MIPS Value Pathway (MVP) Option
2025 will be the first year eye care has an MVP to report. There is no penalty for reporting both the MVP and your usual method, as CMS will apply the higher of the two scores. Because the MIPS program is expected to transition fully to MVPs around 2028, now is an excellent opportunity to familiarize yourself with the process while it is still optional. MVPs were designed to provide a more targeted measure group for a specialty and require fewer quality measures than traditional MIPS.10,11
Q: How do I report the MVP?
A: It is very similar to traditional MIPS, but with specialty-specific, targeted measures only. You must sign up to report with QPP between April 1 and December 1, 2025. You must be able to pull specific reports for four of the 20 MVP quality measures you select; it is unclear at this time if reporting the MVP will be an option through all EHRs or the IRIS Registry for 2025.
For the MVP, small practices are still automatically excluded from the PI category, but like traditional MIPS, they can choose to report. You will select from 14 of the MVP’s Improvement Activities, one for a small practice and two for large practices. CMS will calculate PI population health measures and Cost categories through claims data.
Submission for 2025
Q: Can I still submit my MIPS data using my EHR vendor?
A: Beginning in 2025,12 an EHR vendor must become a certified qualified data registry (QCDR) or a qualified registry (QR) to report MIPS performance to CMS for you.13 Many vendors may already qualify as registries, but not all, so follow up with your EHR vendor if you have not already used one of the many available certified registries. Typically, the IRIS Registry provides a tremendous advantage as the ophthalmology measure steward, offering additional specialty and subspeciality measures to report as they are developed each year. Participation in the IRIS Registry14 is also included in your physicians’ AAO membership.
Preparing for What’s Next
Q: This seems like a lot of change. What do you suggest we do?
A: It is essential to stay on top of the changes to this program every year. Start early by training staff to optimize EHR workflows for quality measures, selecting your IA measure(s) to perform, and continuing to monitor PI measures. We suggest collaborating with surgeons and administrators on delivering excellent patient care while considering the impact of the cost measure.
Keep calm, prepare early, and do what you know is best for your patients. With the proper training, proactive approach, and clear communication, you will continue to succeed! OM
References
1. U.S. Department of Health and Human Services. Medicare and Medicaid programs; CY 2025 payment policies under the Physician Fee Schedule and other changes. Federal Register. December 9, 2024. https://www.federalregister.gov/documents/2024/12/09/2024-25382/medicare-and-medicaid-programs-cy-2025-payment-policies-under-the-physician-fee-schedule-and-other.
2. Centers for Medicare & Medicaid Services. Quality requirements under the Merit-based Incentive Payment System (MIPS) for 2025. Quality Payment Program. https://qpp.cms.gov/mips/quality-requirements?py=2025. Published 2024.
3. Office of the National Coordinator for Health Information Technology. Security risk assessment tool. HealthIT.gov. https://www.healthit.gov/topic/privacy-security-and-hipaa/security-risk-assessment-tool.
4. Office of the National Coordinator for Health Information Technology. SAFER guides. HealthIT.gov. https://www.healthit.gov/topic/safety/safer-guides. Published 2024
5. Centers for Medicare & Medicaid Services. Promoting Interoperability (PI) for MIPS. Quality Payment Program. https://qpp.cms.gov/mips/promoting-interoperability?py=2025. Published 2024.
6. Centers for Medicare & Medicaid Services. Cost Performance Category for MIPS. Quality Payment Program. https://qpp.cms.gov/mips/cost?py=2025. Published December 2024.
7. Centers for Medicare & Medicaid Services. Calendar Year (CY) 2025 Medicare Physician Fee Schedule Final Rule. Centers for Medicare & Medicaid Services. https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2025-medicare-physician-fee-schedule-final-rule. Published December 2024:2071-2072.
8. U.S. Federal Register. Medicare and Medicaid Programs; CY 2025 Payment Policies Under the Physician Fee Schedule and Other Revisions to Part B for CY 2025. U.S. Federal Register. https://www.govinfo.gov/content/pkg/FR-2024-07-31/pdf/2024-14828.pdf. Published July 31, 2024.?
9. U.S. Department of Health and Human Services. Medicare and Medicaid Programs; CY 2025 Payment Policies Under the Physician Fee Schedule and Other Changes; Final Rule. Federal Register. 2024 Dec 9; 89(234):1895. https://www.federalregister.gov/documents/2024/12/09/2024-25382/medicare-and-medicaid-programs-cy-2025-payment-policies-under-the-physician-fee-schedule-and-other#h-612.
10. Centers for Medicare & Medicaid Services. Explore MIPS Value Pathways (MVPs). Quality Payment Program. https://qpp.cms.gov/mips/explore-mips-value-pathways. Published 2024.
11. Centers for Medicare & Medicaid Services. MIPS Value Pathways (MVPs). QPP website. https://qpp.cms.gov/mips/mips-value-pathways.
12. U.S. Department of Health and Human Services. Medicare and Medicaid Programs; CY 2025 Payment Policies Under the Physician Fee Schedule and Other Changes; Final Rule. Federal Register. 2024 Dec 9; 89(234). https://www.federalregister.gov/documents/2024/12/09/2024-25382/medicare-and-medicaid-programs-cy-2025-payment-policies-under-the-physician-fee-schedule-and-other.
13. Centers for Medicare & Medicaid Services. 2024 MIPS Guide to QCDR and Qualified Registry. Centers for Medicare & Medicaid Services. Published 2024. https://qpp-cm-prod-content.s3.amazonaws.com/uploads/2681/2024mips-guide-to-qcdr-qualifiedregistry.pdf.
14. American Academy of Ophthalmology. IRIS Registry. American Academy of Ophthalmology. https://www.aao.org/iris-registry.
