Every year brings something new, especially in the context of healthcare rules and regulations. We’ve already seen the changes the government has planned for anesthesia and pain reimbursement, post-op pain coding, telehealth, and opioid treatment; now it’s time to take a look at what the Centers for Medicare and Medicaid Services (CMS) has in store for its Quality Payment Program (QPP) beginning with the new year. Along with the rule, CMS also published a QPP fact sheet that some providers may find helpful. It can be viewed by clicking on the following link: 2025-QPP-Proposed-Rule-Fact-Sheet-and-Policy-Comparison-Table.pdf.

While there is not much that is anesthesia-specific in the proposed rule, there are changes to note that may impact those providers and groups who participate in QPP programs such as the Merit-based Incentive Payment System (MIPS). With that said, let’s take a look at the proposed program for 2025 and beyond.

Component Values

The percentage value set for each MIPS component will remain the same for the coming year, assuming these proposals become final. The quality performance category will be weighted at 30 percent. The cost performance category will also be weighted at 30 percent. The promoting interoperability category will be set at 25 percent. Finally, the improvement activities category will remain at 15 percent. Since most anesthesia services are excluded from the promoting interoperability measure, the effective weighting of the quality category increases to 55 percent.

Quality Measure Inventory

There are 198 quality measures available for the 2024 performance period, excluding Qualified Clinical Data Registry (QCDR) measures. Under the proposed rule, there would be 196 quality measures for the 2025 performance period. It should be noted that QCDR measures are approved outside the rulemaking process and aren’t included in this total.

These proposals include the following details:

• Addition of 9 quality measures, including 2 patient-reported outcome measures. (See Appendix D of the proposed rule).
• Removal of 11 quality measures from the MIPS quality measure inventory. (See Appendix E). None of the anesthesia measures are currently proposed for removal.
• Substantive changes to 66 existing quality measures.

These changes apply to Traditional MIPS, MIPS Value Pathways (MVPs) and the Alternative Payment Model (APM) Performance Pathway (APP).

Data Completeness

The data completeness threshold for electronic clinical quality measures (eCQMs), MIPS clinical quality measures (CQMs), Medicare CQMs, Medicare Part B claims measures, and QCDR measures is 75 percent through the 2026 performance period; so, this would include next year. The proposed rule maintains the data completeness threshold of 75 percent for the 2027 and 2028 performance periods for all available collection types. These apply to MIPS, MVPs and the APP.

Performance Threshold

The proposed rule maintains the performance threshold at 75 points for 2025. Scoring above 75 points would allow an individual or group a payment bonus. Scoring below 75 points would result in a payment penalty in 2027.

CMS estimates the median positive payment adjustment in the 2027 payment year based on 2025 performance will be 1.31 percent. The median penalty is expected to be -1.48 percent. However, solo practitioners and small practices are expected to fare far worse, with median adjustments to their Medicare reimbursements of -6.42 percent and -5.88 percent, respectively. Many of these solo or small-group providers are expected to receive the maximum -9 percent adjustment.

Minimum Criteria

Any submission received in the QPP environment during the designated MIPS submission period will be considered a submission and assigned a score. Per the proposed rule, a submission for the quality performance category must include numerator and denominator information for at least one quality measure from the list of MIPS quality measures to be considered a data submission and scored.

A data submission with only a date and practice ID won’t be considered a data submission and will be assigned a null score. This proposal is intended to mitigate the negative scoring impact on clinicians due to data submitted with only a practice ID, date or measure ID included (no numerator or denominator) that results in a zero score. Again, this applies to traditional MIPS, MVPs and the APP.

Measures

Upon reviewing Appendix D of the above-referenced QPP proposed rule fact sheet, there are no new quality measures added for 2025 that appear to be particularly pertinent to the practice of anesthesia or chronic pain. Indeed, none of these newly proposed measures were sponsored by the American Society of Anesthesiologists (ASA) or any of the national pain medicine organizations. Similarly, none of the 10 deleted measures in the proposed rule appear to apply to anesthesia or chronic pain.

Finally, the lists of newly proposed improvement activities, as well as those slated for deletion, are not particularly relevant to the anesthesia and pain community.

QCDR

Coronis Healthcare is again submitting to be a QCDR for the 2025 reporting year and is collaborating with other anesthesia QCDRs to offer many reporting options. The approvals should be made public when the final rule is released, allowing some time to prepare for the upcoming year. Once the final rule is released in November, we will recommend participation options for our readers. Until then, if you have further questions about this topic, please feel free to reach out to your account executive.