CMS Suspends Eight MIPS Improvement Activities, Announces 2025 Exception Applications Process
By Phil West

The Centers for Medicare & Medicaid Services (CMS) has suspended eight improvement activities for the Merit-Based Incentive Payment System (MIPS) as of May 6, and announced details about two exception applications due by the end of the year.  

CMS notes that if a participant has already completed or is in the process of completing one or more of the eight marked for removal, that participant “will still be able to attest to completing them and receive credit.”  

Physicians participating in CMS’ Quality Payment Program (QPP) who have not initiated any of these eight improvement activities after May 6 as part of the 90-day reporting period should select from the remaining 96 on the traditional MIPS list to meet requirements for the improvement activities performance category.  

The eight suspended improvement activities are:  

• MIPS Eligible Clinician Leadership in Clinical Trials or Community-Based Participatory Research;  

• COVID-19 Clinical Data Reporting with or without Clinical Trial; 

• Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B 

• Practice Improvements that Engage Community Resources to Address Drivers of Health;  

• Use of Toolsets or Other Resources to Close Health and Health Care Inequities Across Communities; 

• Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols; 

• Create and Implement an Anti-Racist Plan; and 

• Create and Implement a Plan to Improve Care for Lesbian, Gay, Bisexual, Transgender, and Queer Patients. 

“We intend to propose removing these improvement activities in future rulemaking,” CMS said in its notification, adding that it is in the process of updating resources including guides, fact sheets, and webpages. As of this writing, the suspended improvement activities remained on QPP’s list of 2025 improvement activities for traditional MIPS. 

The Texas Medical Association continues to monitor further updates from CMS. 

While the list of improvement activities will typically gain and lose a few entries each year, TMA staff note it’s unusual for improvement activities to be suspended in the middle of a performance year.  

The QPP website informs participants that beginning with the 2025 performance period, improvement activities won’t be classified as medium-weight or high-weight as they were in previous years, streamlining what’s required to receive full credit in this performance category. Now, per QPP’s guidance for reporting improvement activities:  

• Clinicians, groups, and virtual groups with the small practice, rural, non-patient facing, or health professional shortage area special status must attest to one activity; and 

• All other clinicians, groups, and virtual groups must attest to two activities.  

Exceptions for QPP physicians

As it has in previous years, in 2025, CMS will offer two exceptions for physicians seeking reweighting in determining their QPP performance category scores.  

Both exception applications for 2025 are due by Dec. 31 at 7 pm CT, impacting 2027 Medicare payment adjustments.  

First, the MIPS Extreme and Uncontrollable Circumstances (EUC) Exception allows QPP physicians to request reweighting for the cost, quality, improvement activities, and promoting interoperability categories upon experiencing what CMS terms “rare events” entirely out of a physician’s or practice facility’s control.  

To use the EUC exception, CMS says the circumstances in question should: 

• Cause a physician to be unable to collect information necessary to submit for a MIPS performance category; 

• Cause a physician to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, unable to collect data for the quality performance category for three months); and/or 

• Impact a physician’s normal processes, affecting performance on cost measures and other administrative claims measures. 

CMS also will provide a MIPS Promoting Interoperability Performance Category Hardship Exception to physicians and groups using traditional MIPS, a MIPS Value Pathway, or an Alternative Payment Model (APM) Performance Plan – though the exception will not be available to APM entities.  

That hardship exception allows reweighting of the category for those who:  

• Have decertified electronic health record (EHR) technology (which must be decertified under the Office of the National Coordinator for Health Information Technology’s Health IT Certification Program); 

• Have insufficient internet connectivity; 

• Face extreme and uncontrollable circumstances such as a disaster, practice closure, severe financial distress, or vendor issues; or  

• Lack control over the availability of certified EHR technology (CEHRT). 

CMS cautions that “simply lacking the required CEHRT doesn't qualify [a participant for reweighting.” 

Learn more about QPP and other Medicare Access and CHIP Reauthorization Act (MACRA) concerns via TMA’s MACRA Resource Center, and visit the Clinical Quality and Payment page to stay up to date.