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Timeline for Payment Year 2025

December 2024: initial MIPS eligibility published
Jan 1, 2025- reporting year begins
April 1- Dec 1, 2025 MVP Registration window
July 5, 2025: last day to start 180 day Promoting Interoperability reporting period
October 3, 2025: last day to start 90-day Improvement Activities reporting period
December 2025: final MIPS eligibility published
Jan 2, 2026: submission period opens
March 31, 2026: submission period closes
Summer 2026: performance feedback available
January 1, 2027: payment adjustments from performance in PY2025 go into effect

MIPS Changes for 2025

2025 CMS Promoting Interoperability (PI) Program Requirements - Eligible Hospitals (EH) & Critical Access Hospitals (CAH)

Summarized Changes:

All EH and CAH are required to use Certified Electronic Health Record Technology that has been updated to meet the latest CEHRT Edition criteria.

Report on the measures within the four objectives (categories) for 180 consecutive days. The minimum scoring threshold is increasing from 60 points to 70 points. The threshold will rise to 80 points in 2026.

CMS split the Antimicrobial Use & Resistance Surveillance measure into two separate measures: the AU Surveillance and AR Surveillance measures. The AU Surveillance and AR Surveillance measures will be treated as new measures in terms of active engagement levels. EH and CAH may spend only one year in Option 1 (Pre-production and Validation) before advancing to Option 2 (Validated Data Production level) the following year.

The overall PI score, as well as the eCQM performance, will be publicly reported on Care Compare.

Mandatory PI Program Reporting Requirements:

Electronic Prescribing - Two measures required: E-prescribing (10 points) and Query of PDMP (10 points)

Health Information Exchange - Support Electronic Referral Loops (15 points) by Sending Health Information (15 points), or HIE Bi-Directional Exchange (30 points) or Enabling Exchange Under TEFCA (30 points).

Provider to Patient Exchange - Provide Patients Electronic Access to their Health Information (25 points)

Public Health and Clinical Data Exchange - Six measures required: Syndromic Surveillance Reporting, Immunization Registry Reporting, electronic Case Reporting (eCR), Electronic laboratory Result Reporting, Antibiotic Use (AU) Surveillance, Antimicrobial Resistance (AR) Surveillance (25 points). If a hospital claims an exclusion for the required measures in the Public Health and Clinical Data Exchange category, CMS will redistribute the 25 points to the Provide Patients Electronic Access to their Health Information measure. Additional optional measures available for bonus points: Public Health Registry Reporting or Clinical Data Registry Reporting (5 points).

Attest (yes/no) to the following within the Protect Patient Information objectives - Security Risk Analysis and complete 8 Safety Assurance Factors for EHR Resilience (SAFER) Guides.

Successfully submit 6 eCQMs for four quarters of data (12 months)- Three self-selected eCQMs and Safe Use of Opioids (CMS506), Cesarean Section (PC-02), and Severe Obstetric Complications (PC-07). . The eCQM requirements under PI are the same as the 2025 Inpatient Quality Reporting (IQR) program requirements. CMS proposing a mandatory submission of eight eCQMs in 2026, nine in 2027, and 11 by 2028. CMS is also using 2025 to introduce a new eCQM auditing process that could also impact hospitals in the years ahead.

For more information: https://www.qualityreportingcenter.com/globalassets/2025/01/iqr/pi_infographic_cy-2025-requirements_jan2025_vfinal_508.pdf or https://www.cms.gov/medicare/regulations-guidance/promoting-interoperability-programs

Clinical Laboratory Improvement Amendments (CLIA) program

The Centers for Medicare and Medicaid Services (CMS) is improving the Clinical Laboratory Improvement Amendments (CLIA) program by switching to electronic fee coupons and CLIA certificates. To take full advantage of these improvements, laboratories and providers that perform laboratory testing have until March 1, 2026, to switch to CMS email notifications and begin receiving electronic CLIA fee coupons and certificates. After this date, paper fee coupons and paper CLIA certificates will no longer be available.

Benefits to going paperless:

Electronic Fee Coupons* - no longer paper coupons. In addition, you can pay your CLIA certification fees via Pay.gov, a secure online platform. Your payment gets processed overnight – a faster way to pay!
Electronic CLIA Certificates *- no need to wait for it to come in the mail. Certificates will be sent to your laboratory’s email address.

*This does not apply to CLIA-exempt states or state licensure.

Download the Partner Toolkit which provides ready-to-use messaging for your outreach to laboratories and providers.

Download CLIA Fees & Certificates Factsheet

Download Fees & Certificates Poster