ACEP ID:
- My Account
- My CME
- Sign Out
ACEP ID:
The Medicare Physician Fee Schedule (PFS) regulation makes updates to the Quality Payment Program (QPP), the major quality reporting program for physicians under Medicare. Failure to successfully participate in the Merit-based Incentive Program (MIPS)—the main track within the QPP—could result in a 9% reduction to emergency physicians’ Medicare reimbursement.
ACEP is doing all that we can to simplify the requirements and make it easier to avoid a penalty and even be eligible for a bonus.
Read below about MIPS and what ACEP is doing to help emergency physicians successfully participate.
Final 2025 Policies
On November 1, 2024, CMS released the CY 2025 PFS and QPP final rule.
Current Flexibilities
There are 2 exception applications available to clinicians:
The exception applications are open until 8pm ET on December 31, 2025.
Background
Most emergency physicians participate in the first track of the QPP: MIPS. MIPS includes four performance categories: Quality, Cost, Improvement Activities, and Promoting Interoperability (formerly Meaningful Use). Performance on these four categories (which are weighted) roll up into an overall score that translates to an upward, downward, or neutral payment adjustment that providers receive two years after the performance period (for example, performance in 2025 will impact Medicare payments in 2027).
MIPS Impact on Emergency Physicians
Most emergency physicians will need to participate in MIPS to avoid a penalty and perhaps get a bonus. You can report as an individual or as part of a group. For the 2025 performance year, the potential payment adjustments range between -9 and +2.15%.
MIPS Value Pathways (MVPs)
CMS has heard feedback, including from ACEP, that MIPS reporting should be streamlined and more meaningful to clinicians. Starting in 2023, CMS has been implementing the MIPS Value Pathways (MVPs), an approach that allows clinicians to report on a uniform set of measures on a particular episode or condition in order to get MIPS credit.
ACEP developed and proposed an emergency medicine-focused MVP, the “Adopting Best Practices and Promoting Patient Safety within Emergency Medicine MVP.” For more information on MVPs, click here.
Find Out Whether You’re Eligible
If you see a minimum number of Medicare patients, have a small amount of Medicare charges, or provide a small number of services to Medicare beneficiaries, you may be excluded. You'll need your National Provider Identifier (NPI) number to determine your eligibility.
What is ACEP doing?
ACEP continually advocates on behalf of emergency physicians to reduce provider burden and help our members succeed in the program. Every year, CMS updates program requirements through federal regulatory rulemaking and ACEP actively comments on these regulations.
ACEP also provides our members with helpful tools to report in MIPS. Thousands of emergency physicians are now using CEDR to meet the Quality Reporting requirements and participating in E-QUAL to meet the Improvement Activities requirements.
MIPS includes four performance categories: Quality, Cost, Improvement Activities, and Promoting Interoperability (formerly Meaningful Use). Performance on these four categories (which are weighted) roll up into an overall score that translates to an upward, downward, or neutral payment adjustment that providers receive two years after the performance period (for example, performance in 2023 will impact Medicare payments in 2025).
In 2023, the adjustments will potentially range from –9% to +9%. In order to be eligible for a positive adjustment, a clinician’s score must exceed a certain threshold, which is 75 points in 2022 and in 2023 (proposed).
The 2022 performance period/2024 payment year was the last year with a 5% payment bonus available for participating in an Advanced APM. The bonus will decrease to 3.5% in the 2025 payment year and 1.88% in the 2026 payment year, and then, without congressional action, there won’t be any bonus starting in 2027 – only a slightly higher conversion factor update under the Medicare Physician Fee Schedule.
Once the APM bonus fully expires, the financial incentive for being in an Advanced APM won’t be much larger than it is for MIPS.
Quality Performance Category
To meet this requirement, most emergency physicians will have to report on six measures over a 12-month period. The Quality category will count for 30% of your total score in 2025. One great way to meet the Quality requirement is by reporting through a qualified clinical data registry (QCDR). ACEP has developed its own QCDR, called the Clinical Emergency Data Registry (CEDR). Another option available to emergency physicians for meeting the Quality category is the “facility-based scoring option.” See below for more details.
Cost Performance Category
Cost will represent 30% of your total score in 2025. If these measures do not apply to you or your practice, you will not receive a cost score and your quality score will count for 60% of your total score. Another option available to emergency physicians for meeting the Cost category is the “facility-based scoring option.”
ACEP members helped develop the Emergency Medicine measure, an episode-based cost measure. The Emergency Medicine measure evaluates a clinician’s risk-adjusted costto Medicare for patients who have an ED visit during the performance period. The measure score is the clinician’s risk-adjusted cost for the episode group averaged across all episodes attributed to the clinician. This measure includes costs of Part A and B services during each episode from the start of the ED visit that opens, or “triggers,” the episode through 14 days after the trigger, excluding a defined list of services for each ED visit type that are unrelated to the ED care.
Improvement Activities Performance Category
This category rewards participation in activities that improve clinical practice. There is a list of activities that are classified as either medium or high-weighted based on their value to patient care. To earn full credit in this category, participants must submit one of the following combinations of activities (each activity must be performed for 90 days or more during 2025):
A great way to meet the requirements of this performance category is by participating in ACEP’s Emergency Quality Network (E-QUAL) Initiative.
Promoting Interoperability Performance Category
This category includes measures and objectives related to the use of electronic health records (EHRs). Most emergency physicians are exempt from this category (formally known as the “Meaningful Use” program) because they are “hospital-based” clinicians who use their hospital’s EHR. CMS exempts groups from the Promoting Interoperability category of MIPS as long as 75% of individuals in the group meet the definition of “hospital-based.”
Facility-Based Scoring Option
One scoring option available to emergency physicians starting is called the facility-based scoring option for the Quality and Cost categories of MIPS.
With this scoring option, clinicians who deliver 75% or more of their Medicare Part B services in an inpatient hospital, on-campus outpatient hospital, or emergency room setting will automatically receive the quality and cost performance score for their hospital through the Hospital Value-based Purchasing (HVBP) Program. Most emergency physicians qualify for this option. Clinicians who qualify for the option can still report quality measures through another submission mechanism (such as a QCDR) and receive a “traditional” MIPS score for quality. If they do so, CMS will automatically take the highest of the HVBP score and the traditional MIPS score.
MIPS Value Pathways (MVP)
MVPs have slightly different reporting rules than traditional MIPS.
For more information on the emergency medicine MVP, the “Adopting Best Practices and Promoting Patient Safety within Emergency Medicine MVP,” please click here.
