MIPS Value Pathways (MVPs)

MIPS Value Pathways (MVPs) (2025)

Merit-based Incentive Payment System Value Pathways (MVPs) are a subset of measures and activities, established through rulemaking, that can be used to meet MIPS reporting requirements. 

Those choosing to report MVPs will be able to report their data through AQI NACOR's Qualified Registry (MIPS measures only) or Qualified Clinical Data Registry (QCDR) options (MIPS and QCDR measures may be reported).

The MVP framework aims to align and connect measures and activities across the quality, cost, and improvement activities performance categories of MIPS for different specialties or conditions. In addition, the MVP framework incorporates a foundation that leverages Promoting Interoperability measures and a set of administrative claims-based quality measures that focus on population health in order to reduce reporting burden.

For Performance Year 2025, CMS approved a revised "Patient Safety and Support of Positive Experiences with Anesthesia MVP." MVP scoring and special status designations do not differ from Traditional MIPS policies. Those groups choosing to report the MVP in 2025 will only need to report four quality measures, one improvement activity and promoting interoperability measures (optional depending on your special status designation). CMS will calculate the Medicare Spending Per Beneficiary (MSPB) Clinician measure for the Cost Performance Category.

Eligible clinicians and their groups will need to choose four measures from this designated list:

• Q404: Anesthesiology Smoking Abstinence
• Q424: Perioperative Temperature Management
• Q430: Prevention of Post-Operative Nausea and Vomiting (PONV) - Combination Therapy
• Q463: Prevention of Post-Operative Vomiting (POV) - Combination Therapy (Pediatrics)
• Q477: Multimodal Pain Management
• Q487: Screening for Social Drivers of Health 
• AQI48: Patient-Reported Experience with Anesthesia
• ABG44: Low Flow Inhalational General Anesthesia
• ePreop31: Intraoperative Hypotension (IOH) Among Non-Emergent Noncardiac Surgical Cases

Eligible clinicians and their groups also have a set of twelve (12) improvement activities to choose:

• IA_BE_6: Regularly Assess Patient Experience of Care and Follow Up on Findings
• IA_BE_22: Improved practices that engage patients pre-visit
• IA_BMH_2: Tobacco use
• IA_CC_2: Implementation of improvements that contribute to more timely communication of test results
• IA_CC_15: PSH Care Coordination
• IA_CC_19: Tracking of clinician’s relationship to and responsibility for a patient by reporting MACRA patient relationship codes
• IA_MVP: Practice-Wide Quality Improvement in MIPS Value Pathways
• IA_PCMH: Electronic submission of Patient Centered Medical Home accreditation.
• IA_PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B
• IA_PSPA_1: Participation in an AHRQ-listed patient safety organization
• IA_PSPA_7: Use of QCDR data for ongoing practice assessment and improvements
• IA_PSPA_16: Use of decision support and standardized treatment protocols

Individuals and groups will need to register with CMS during the 2025 performance period to report an MVP. The registration period runs April 1 and November 30th of the performance year.

At the time of registration, individuals and groups:

• Must indicate whether the MVP participant would like to be evaluated on an outcomes-based administrative claims measure (if one is included in the MVP) as 1 of their 4 required quality measures. If the MVP participant doesn’t meet case minimum for the outcomes-based administrative claims measure, they’ll receive 0 out of 10 points for the required outcome measure unless they submit another outcome measure.

Even if you register to report an MVP, you can still choose to report traditional MIPS or the APM Performance Pathway (APP), if applicable.

Subgroup Reporting

CMS defines a subgroup as, “A subset of a group which contains at least one MIPS eligible clinicians and is identified by a combination of the group Taxpayer Identification Number (TIN), the subgroup identifier, and each eligible clinician’s National Provider Identifier (NPI).” Anesthesiologists who participate in MIPS with non-anesthesiologists may be able to report the anesthesia MVP. Please check with your group administrator or CMS for eligibility requirements.

What are the differences between Traditional MIPS and MVPs?

Anesthesiologists and their groups may report either Traditional MIPS or the Anesthesia MVP in 2025. The table below includes some considerations when choosing whether to report one or the other.

For more information, please contact ASA Department of Quality and Regulatory Affairs at qra@asahq.org.

MIPS Improvement Activities Performance Category (2024)

The MIPS Improvement Activities performance category rewards eligible clinicians (ECs) and groups for engaging in clinical practice improvement activities such as care coordination, beneficiary engagement, and patient safety. Improvement Activities account for 15% of the total MIPS score in performance year 20243. Most anesthesiologists and their groups will attest to the MIPS Improvement Activities category via a Qualified Registry, a Qualified Clinical Data Registry, or though the Quality Payment Program website.

CMS has finalized a list of more than 100 activities for the 2024 performance year. AQI NACOR supports attestation for more than fifty anesthesia-related improvement activities. The list of MIPS Improvement Activities and their data validation requirements are available via the Quality Payment Program Resource Library. Please make sure to check improvement activities requirements and descriptions each year as CMS adds, deletes, and amends improvement activities.

Each individual improvement activity is assigned a weight of either medium or high. Medium weighted activities receive 10 points and high weighted activities receive 20 points. To receive full credit for the performance category, eligible clinicians and groups must receive a score of 40 points. Small practices, rural practices, practices located in geographic health professional shortage areas (HPSAs), and non-patient facing MIPS eligible clinicians will have their medium weighted activities count for 20 points and their high weighted activities count for 40 points. They will still be required to reach 40 points to receive full credit for this component.

For groups, CMS requires 50% of the group’s National Provider Identifier (NPI) clinicians to perform the same improvement activity during any continuous 90-day period within the same performance year.

Eligible clinicians and groups are subject to auditing from their data/registry vendor or CMS for up to six years AFTER the performance year. Eligible clinicians and their groups should retain documentation of their improvement activity performance.

MIPS Value Pathways (MVPs) (2024)

For Performance Year 2024, CMS approved a revised "Patient Safety and Support of Positive Experiences with Anesthesia MVP." MVP scoring and special status designations do not differ from Traditional MIPS policies. Those groups choosing to report the MVP in 2024 will only need to report four quality measures, 1 high-weighted or 2 medium weighted improvement activities (or one Patient Centered Medical Home Improvement Activity) and promoting interoperability measures (optional depending on your special status designation). CMS will calculate the Medicare Spending Per Beneficiary (MSPB) Clinician measure for the Cost Performance Category.

Eligible clinicians and their groups will need to choose four measures from this designated list:

• Q404: Anesthesiology Smoking Abstinence
• Q424: Perioperative Temperature Management
• Q430: Prevention of Post-Operative Nausea and Vomiting (PONV) - Combination Therapy
• Q463: Prevention of Post-Operative Vomiting (POV) - Combination Therapy (Pediatrics)
• Q477: Multimodal Pain Management
• Q487: Screening for Social Drivers of Health
• AQI48: Patient-Reported Experience with Anesthesia
• ABG44: Low Flow Inhalational General Anesthesia
• ePreop31: Intraoperative Hypotension (IOH) Among Non-Emergent Noncardiac Surgical Cases

Eligible clinicians and their groups also have a set of eleven (11) improvement activities to choose:

• IA_BE_6: Regularly Assess Patient Experience of Care and Follow Up on Findings (High)
• IA_BE_22: Improved practices that engage patients pre-visit (Medium)
• IA_BMH_2: Tobacco use (Medium)
• IA_CC_2: Implementation of improvements that contribute to more timely communication of test results (Medium)
• IA_CC_15: PSH Care Coordination (High)
• IA_CC_19: Tracking of clinician’s relationship to and responsibility for a patient by reporting MACRA patient relationship codes (High)
• IA_EPA_1: Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real-Time Access to Patient’s Medical Records (High)
• IA_MVP: Practice-Wide Quality Improvement in MIPS Value Pathways
• IA_PCMH: Electronic submission of Patient Centered Medical Home accreditation.
• IA_PSPA_1: Participation in an AHRQ-listed patient safety organization (Medium)
• IA_PSPA_7: Use of QCDR data for ongoing practice assessment and improvements (Medium)
• IA_PSPA_16: Use of decision support and standardized treatment protocols (Medium)

For more information, please contact ASA Department of Quality and Regulatory Affairs at qra@asahq.org.