In 2020, CMS finalized the implementation of the MIPS Value Pathways (MVPs) – a framework intended to streamline MIPS by connecting activities and measures across the four MIPS categories that are relevant to a specific specialty, condition, or population. The 2025 performance year is the third year MVPs are available as a voluntary MIPS participation pathway.
MVPs are composed of quality measures (including one outcome measure [or high-priority measure, if the outcome measure isn’t applicable]), improvement activities, and cost measures relevant to the condition, specialty, or patient population. MVPs are also required to include a foundational layer made up of population health measures and the Promoting Interoperability performance category measures. While MVPs, at least for the foreseeable future, will continue to rely on many current flawed MIPS policies that limit meaningful participation among surgeons, this pathway does include a slightly reduced reporting burden compared to traditional MIPS, as discussed below. In future years, CMS will propose additional MVPs and intends to eventually sunset traditional MIPS, at which point MVPs could become mandatory.
Performance Year 2024 MIPS Value Pathways
- Complete Opthalmologic Care
- Dermatological Care
- Gastroenterology Care
- Optimal Care for Patients with Urologic Conditions
- Pulmonology Care MVP
- Surgical Care MVP
- Advancing Rheumatology Patient Care
- Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes
- Advancing Care for Heart Disease
- Value in Primary Care
- Adopting Best Practices and Promoting Patient Safety with Emergency Medicine
- Improving Care for Lower Extremity Joint Repair
- Patient Safey and Support of Positive Experiences with Anesthesia
- Quality Care for Patients with Neurological Conditions
- Optimal Care for Kidney Health
- Advancing Cancer Care
- Rehabilitative Support for Musculoskeletal Care
- Quality Care in Mental Health and Substance Use Disorders
- Prevention and Treatment of Infectious Disorders Including Hepatitis C and HIV
- Quality Care for the Treatment of Ear, Nose, and Throat Disorders
- Focusing on Women’s Health
Learn more about each of these MVPs.
Who can report an MVP?
MVPs can be reported by individual MIPS eligible clinicians, single specialty groups (a group that consists of one specialty type based on Medicare Part B claims), multispecialty groups (a group that consists of two or more specialty types based on Medicare Part B claims), or an APM Entity. Additionally, MVPs can be reported at the subgroup level, which is not an option under traditional MIPS. Subgroup participation will be required for multispecialty groups wishing to report MVPs beginning with the 2026 performance year. This CMS resource provides examples of how a practice can choose to report at the subgroup level.
If a surgeon or their group elects to participate in an MVP in 2025, they are required to register and select their MVP(s) by June 30, 2025.
What are the reporting requirements for an MVP?
Quality Reporting Requirements
To complete the MVP reporting requirements for the quality performance category, you must:
- Select and report four quality measures from an MVP, including one outcome measure. If no outcome measure is available, you may report a high priority measure.
- The four required quality measures don’t include the required population health measures evaluated as part of the foundational layer.
Improvement Activities Requirements
To meet the requirements for the Improvement Activities performance category, you must:
- Report 1 improvement activity from the MVP; or
- Report the IA_PCMH (participation in a certified or recognized patient-centered medical home or comparable specialty practice) activity.
Cost Category Requirements
Similar to traditional MIPS, Medicare claims data are used to calculate cost measure performance under MVPs, which means that there are no data submission requirements for this performance category. Each MVP includes cost measures that should be relevant and applicable to the MVP’s clinical specialty or medical condition. Unlike traditional MIPS, MVP participants may only be scored on cost measures that are listed in their selected MVP and for which they meet the case minimum of attributed patients.
Foundational Layer Reporting Requirements
The foundational layer of an MVP is made up of the Promoting Interoperability performance category and population health measures that are calculated through administrative claims. The components of the foundational layer apply to ALL MVPs regardless of clinical specialty or medical condition.
Promoting Interoperability Performance Category
The reporting requirements for Promoting Interoperability in MVPs are the same as traditional MIPS. Eligibility for exclusions from this category also follow the same rules as under traditional MIPS.
Population Health Measures
There are two population health measures in the foundational layer of all MVPs:
- Measure 479: Hospital-Wide, 30-day, All-Cause Unplanned Readmission (HWR) Rate for the Merit-based Incentive Payment System (MIPS) Groups
- Measure 484: Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions
These measures, which are also used in traditional MIPS, are scored automatically by CMS based on administrative claims data and do not necessitate reporting by the participant. Similar to traditional MIPS, MVP participants are only scored on these measures if they are attributed a minimum number of patients associated with each measure. Beginning in 2025, CMS will score both population health measures in an MVP, if applicable, and use the highest score in determining a participant’s measure achievement points.
MVP Resources
CMS MIPS Value Pathways Website
