How to Succeed in MIPS, MVPs, and the APM Performance Pathway (APP) in 2025
In this episode, Dr. Dan Mingle and Brigid Whitney-Gallagher, Manager of Client Services at Mingle Health, discuss the important details, requirements, and changes for healthcare providers participating in MIPS, MIPS Value Pathways (MVPs), and the APM Performance Pathway (APP) in 2025.
Click play on the video below to listen to the discussion between Dr. Mingle and Brigid, or scroll down to read each question and answer.
Use the links below for quick navigation to each topic covered in this episode:
MIPS Value Pathways (MVPs) in 2025
APM Performance Pathway (APP) Plus in 2025
Question One: 2025 Changes Affecting MIPS Participants
Dr. Mingle asks: “With the release of the Final Rule for MIPS for 2025, what do you see as the most significant changes affecting the MIPS clients you and your team work with?”
Brigid: For MIPS, many things have stayed the same.
Performance and Data Completeness Thresholds
The Performance Threshold, that is the number of points to avoid a MIPS penalty, has stayed at 75. The Data Completeness Threshold, that is how many patients and encounters you have to report on, has stayed at 75%. The Performance Threshold of 75 is through the 2025 Performance Year and CMS has said that the Data Completeness Threshold will stay at 75% through 2028.
Cost Category
In the Cost category there have been some scoring changes for the better, in my opinion.
The curve has been skewed upward to line up with the average Cost score. Now, unless you are on one far end or the other of the scale, your performance in the Cost category will earn you more points than it has in previous years. So it’s less likely that Cost will drag your entire MIPS score down.
A lot of practices have struggled with predicting Cost scores and understanding how to make a positive change to their performance, so with the way they’ve shifted scoring requirements, the Cost category will be less of a burden as far as overall MIPS performance.
Improvement Activities
Previously, Improvement Activities had high weighted and medium weighted activities and practices had to choose different amounts of different activities to meet the requirements.
In the 2025 Final Rule, they’ve simplified it:
- For traditional MIPS, you have to report two activities.
- If you are a small practice, non-patient facing practice, or if you’re doing an MVP, you report one activity.
This should help the Improvement Activities category be more approachable for some practices.
New EUC Application Category
There also is a new Extreme and Uncontrollable Circumstances (EUC) application category.
After your submission, you would now be able to file an EUC hardship application if you have experienced vendor issues that have affected your submission. So, if you were under contract with someone and they didn’t make a submission, or made a submission that was incorrect, or there was some other vendor issue, you would be able to address that with CMS to mitigate any penalties or negative ramifications.
Question Two: Annual MIPS Reporting Rhythm
Dr. Mingle: “Let’s just back off a moment to that whole MIPS annual recurring project. It seems that there may be an annual rhythm to MIPS quality reporting. What does that rhythm look like to you and your team?”
Brigid: You are absolutely right.
MIPS reporting is a cycle, and it follows about a 15-month calendar. We usually break this up into five quarters. The best way to optimize and get your best results working with us is to get started in quarter one, which would be January, February, and March of 2025 for 2025 MIPS reporting.
Before we start on MIPS for 2025 though, we want to make sure that your 2024 submission or exemption is already resolved. We’ll make sure that’s buttoned up before moving on to 2025.
MIPS Reporting: Quarter One – Planning and Review
There are many things that require you to get an early start. For example, there are new Quality measures and Improvement Activities that CMS releases every year. Quality measures and Improvement Activities also retire, so we want to see if measures you’ve reported previously are still available.
And we want to see if there are new measures that are a better fit. It can be easy to kind of fall into a habit of “we’re doing the same thing we did last year,” and sometimes that’s okay, but it doesn’t mean it’s the best option for your MIPS performance.
It’s important in the first quarter to take some time to think about how you need reporting to go this year both in terms of group or individual MIPS performance. And you want to consider technical challenges like switching EHRs, switching to a new billing company, and changing requirements from any new Quality measures or Improvement Activities you may select.
It’s easy to get into a habit of doing things one way year after year and not realize that over time, measures and activities change, and there might actually be better, easier options that more closely align with the care you’re providing.
So, in the first quarter, it’s really worthwhile to get in touch with your Mingle Health Consultant and schedule your yearly kickoff call. This call is essentially a way for us to start the project, understand your goals, understand your previous performance, prepare for challenges in the coming year, and see how we can make MIPS reporting meaningful (or hopefully reduce the burden of MIPS reporting for your practice).
This yearly kickoff process is important and helps us cover important details that lay the foundation for your MIPS performance in the coming year:
- For Quality, we want to start as early as possible with your Quality metrics and ensure that all the required documentation is in place.
- For Promoting Interoperability, we want to stress that the reporting period is now 180 days. We need to make a plan early in the year to ensure that we address some of the requirements that take time to fix if there’s an issue. These requirements could be participating in Clinical Registries, keeping certifications up to date, and ensuring your EHR dashboards are turned on, to name a few.
- With the reporting period at 180 days, if you’re starting in the third quarter, we’re already missing the timeframes that we need for some of these items.
- For the Cost category, we have containment and mitigation strategies that can help you understand your Cost performance and create a positive impact on your score.
- Many times, it can feel like you’re in the dark with the Cost category and you don’t have the information you need. CMS has started producing some patient-level reports that can be really helpful in investigating how you’re doing in the Cost category. Your Mingle Health Consultant can help you with this in your kickoff call.
The sooner we get started in the first quarter, the better off we’re going to be with the project overall, and you increase your chances of earning the highest MIPS score possible.
MIPS Reporting: Quarter Two – Implementation and Validation
Quarter Two is all about two things: implementation and validation.
This is where we’ll ask you to send us your billing data and your Promoting Interoperability information and dashboards. We’ll look at your data and see what we are dealing with and what the current state of your MIPS performance looks like. Then, we’ll start looking for trends, vulnerabilities, and concerns. We’ll see if there’s anything we can learn from trends identified, and we’ll work to address your concerns and mitigate vulnerabilities.
Our work in Quarter Two is all about doing some deep dives into your data. We want to make sure we’re receiving all the billing data we expected. We want to make sure that the required technical infrastructure and processes to get your data are in place.
Quarter Two is also where we should be discussing what an audit would look like for you.
It’s easy to pretend audits aren’t a problem until they’re right there in front of you, so one of the things that I recommend our clients do as you’re looking at your data is to talk to your Mingle Health Consultant about what to do if you were to be audited. They’ll help you understand the documentation requirements and help you improve your workflows and documentation processes. They can also suggest other projects that you could undergo to make the audit process less burdensome.
Your Mingle Health Consultant can help you build a great safety net in the event that you are selected for a Mingle Health audit, or if CMS chooses to audit your practice or your submission.
Finally, we want to make sure that the assumptions we made in Quarter One are what we want to go with. If you decide maybe you’d like to try a new measure in Q1, Q2 is the time to decide if this measure is a good fit. This is your testing and validation phase as we’re double-checking all of our assumptions and decisions from Q1.
MIPS Reporting: Quarter Three – Feedback Reports and Proposed Rule Review
Quarter Three might seem like a mellower time as you should already be sending data at a regular cadence and checking in on your performance, but CMS is really busy this time of year.
Q3 is when hat’s when we get all CMS feedback reports from the previous year’s submissions so there’s a lot to look at there and we can see how CMS scored you in the previous year. We can see if you’ve had providers who receive different scores from different places, we can see how you scored in the Cost category and what that ends up looking like in terms of overall MIPS performance. We can understand if your previous Cost performance creates a vulnerability for your current submission that we can mitigate.
This is also when the Proposed Rule comes out. CMS publishes the Proposed Rule as their statement of intention – they say what they would like to have happen as far as the rules of all QPP reporting programs in the coming year.
The Proposed Rule is a huge opportunity for every practice and organization to have their voice heard and decide how they want this program to change in the future. The comment period for the Proposed Rule is 60 days, and CMS is required by law to review and respond to any comment that is made.
There are a lot of challenges in MIPS, MVPs, and the APM Performance Pathway (APP), and it’s kind of tough when you’re running a practice to take a moment to comment on the Proposed Rule. But it’s your chance to tell CMS how the program works for you (or not) and the challenges you’re facing, and changes you’d like to see them make to the Quality Payment Program.
I recommend that everyone, from large health systems and medical societies to solo practitioners and support staff make a comment on the Proposed Rule. If you have ideas or concerns about how the program should change, you should make a comment.
MIPS Reporting: Quarter Four – End-of-Year Decisions
This is where we’re making all of the end of the year decisions that affect your MIPS performance.
If for some reason you need to apply for the Extreme and Uncontrollable Circumstances hardship to have one or more of the categories not apply to you, this is the time to make your application.
We also want to make sure that all of the processes and decisions we have put in place over the year are really what we want to do.
Many MIPS participants choose to start the year tracking their performance in ten measures, and by the end of the year they’ve narrowed it down to their best six measures.
Or, you may have decided that you want to work on a Traditional MIPS submission and a MIPS Value Pathways (MVP) submission concurrently. Quarter Four is where we’ll decide which submission is going to be best for your organization.
Quarter Four sets us up for Quarter Five by tying up the loose ends and making decisions so we’re ready to make a submission when the submission period opens.
MIPS Reporting: Quarter Five – Submission and Restart
We’re ready to make your MIPS submission!
The goal is that you have all the decisions made, all of those confirmations in place. Maybe you’re waiting on some last-minute billing data or some last-minute paperwork, but in Quarter Five you should be ready to go, and we’ll make that submission to CMS.
Then we start the process all over again for the 2026 Performance Year.
Question Three: Starting MIPS Late in the Year
Dr. Mingle asks: “It sounds like to optimize things, a practice really has to start 15 months before the submission is due. Does that mean you can’t take practices late in the year?”
Brigid: Not at all!
One of the things that we really pride ourselves on is meeting clients where they’re at. We take practices year-round, and new folks come to us at various points throughout the year.
Mingle Health has been around for a while, and we’ve helped many practices with submissions, and we have some tricks up our sleeve. There are ways to minimize your reporting burden in your first year so that in subsequent years you can begin to optimize and measure things that are important for your practice. And if you start halfway through the year, we can help you get caught up.
Starting early in the year is optimal of course, but starting at any point is better than not starting at all. Any time you’re able to reach out to us and get started, you’re helping your submission. Then, we get to start again in Q1 the following year and hopefully improve your scores and get even more value out of the process.
Question Four: How to Get the Most Out of Mingle Health
Dr. Mingle asks: “What tips do you have for MIPS participants to get the greatest value from their Mingle Health Consultant?”
Brigid: I think my best advice for a practice working with Mingle Health is to make sure you are engaged with your MIPS project throughout the year.
One of the things I recommend is to get in touch with your Consultant early in the year and stay in touch with your questions and concerns as often as possible.
Sometimes, it can be tough to get your data to us until late in the year. You may miss out on some value from our Consultants in terms of data validation and early recommendations that can improve your overall performance.
So engage early, engage often, ask a lot of questions. Our Consultants are experts and we know the MIPS program in and out. We have a deep bench of Subject Matter Experts to help you understand the intentions of measures and clinical nuances. Even if your dedicated Consultant doesn’t have the information right at hand, we have the resources and experience to guide you on our team.
The more questions you ask, the more engaged you are with the project and your Consultant, the more we can help you and meet your goals for your MIPS submission.
Question Five: Characteristics Predictive of Higher MIPS Scores
Dr. Mingle asks: “As you look over the clients you’ve assisted, what are the characteristics of a MIPS participant that seems to be predictive of higher scores?”
Brigid: I think probably the biggest characteristic is engagement.
There are many different reasons why a person may or may not have a high score. Quite frankly, sometimes the design of the program gets in the way of specific folks getting a high score with no reflection on the quality of care they’re providing.
I will say that in most cases, engaging with us, being able to share information with us, allowing us to talk you through things and consider your options while navigating your own systems and practice needs will be really helpful in how we can support you to get the best MIPS score.
Sometimes the program is just really challenging. We have specific specialties that don’t have a wide variety of measures. We have some folks that only see and treat patients in very specific ways, so they don’t really have a lot of options with MIPS or MIPS Value Pathways. All of those components can be mitigated and navigated as long as we have some time and some engagement to work on them with you.
Folks who perform really well in terms of score are engaged and they continue to work on the project year-round. Instead of getting in touch with your Consultant once or twice a year, you should work on continuous improvement and try new things.
Question Six: Changes to MIPS Value Pathways (MVPs) in 2025
Dr. Mingle asks: “Let’s take a different tack now because we’ve got the MIPS Value Pathways (MVPs) program that Medicare has been bringing into the mix for the last few years. So, with the release of the Final Rule for MVPs in 2025, what do you see as the most significant changes affecting the clients you and your team work with?”
Brigid: When it comes to MVPs, what we’re really seeing in 2025 is that CMS is dedicated to this pathway and they’re investing in the pathway.
They’ve added six new MVPs, which puts us at a total of 21 MVPs. According to CMS estimates, about 80% of MIPS-eligible clinicians would have eligibility for one MVP or another.
They’re trying to make sure that MVPs have a broad reach and that many different types of providers, in terms of credentials, specialty, patient population, etc. can report an MVP successfully.
They have done a bit of simplification to MVPs. In previous years, the practice or provider had to choose between two population health measures. CMS has removed this requirement in 2025. Now they will calculate your population health measures and apply the best score to your submission.
This administrative simplification should make MVPs more available and accessible to all types of practices.
Question Seven: Development of MVPs in the Future
Dr. Mingle asks: “Medicare has been developing the MVP program in a stepwise manner. What is your understanding of the steps or milestones that we can expect from the MVP program going forward?”
Brigid: This type of stepwise development is very common with Medicare. We’ve seen it in many of their different quality programs within the QPP.
CMS usually starts with the bar low. They want to give everyone a chance to get some practice using a new measure or new pathway with very low stakes, and then they gradually increase the requirements so that they’re able to assess what is high-quality and low-cost care and what isn’t.
One note on the development of MVPs that is worth mentioning: what we are expecting to see is that in Performance Year 2026, subgroup reporting will be mandatory for those multi-specialty practices that report an MVP in 2026. If you choose to not report an MVP, no problem, there’s no subgroup requirement. And there is still no requirement to do an MVP submission for anyone. But if you do choose to report an MVP in 2026 and you’re a multi-specialty practice, you will be expected to use subgroups.
This is really the next step in CMS encouraging practices to participate in MVPs in a meaningful and relevant way.
CMS is anticipating that Traditional MIPS will end and MVPs will be the process for MIPS participation at some point, but we have no time frame associated with this change. It will likely take a lot of further development of MVPs and a lot of clarification in the rules before we are able to reach that point. But it is clear that the direction CMS wants to move is everyone doing MVPs and Traditional MIPS no longer being an option.
As they work toward this goal, we’ll see more and more MVP options and we’ll see higher expectations around MVPs. We’ll likely also see some of the same simplifications that we’ve seen in 2025 with the administrative claims measures.
CMS is really dedicated to making MVPs a great option for reporting for as many practices and providers as they can.
Question Eight: MVP Submissions Before They Are Required
Dr. Mingle asks: “As you look at the MVP program, why should a MIPS participant consider using an MVP before they’re required?”
Brigid: MVPs work really well for many practices and providers.
For one reason, you only have to report on four quality measures as opposed to six under Traditional MIPS. If you’re a practice that struggles with measure selection or you have a tough time accessing your data, four measures will be easier than six.
The other factor that makes MVPs beneficial to practices is that they are a great way to limit your exposure to the Cost category. When you select an MVP to report, you know which Cost measures could apply to you. Instead of having the full range of Cost measures that may apply to you for a variety of reasons in MIPS, MVPs allow you to know the exact Cost measures that will apply, and you can focus on those areas to make sure you are impacting your Cost score in a positive way.
Another great thing about MVPs is that for Improvement Activities, you only have to report one, instead of two in Traditional MIPS.
These points add up to the primary reason folks should consider an MVP: it can make your reporting significantly easier, and an MVP can be a great way to reduce some of the burden and risk that you can experience in Traditional MIPS.
Question Nine: MVPs and Subgroups, and Providers Without Applicable MVPs
Dr. Mingle asks: “There’s two issues that I really haven’t been satisfied with what I’ve heard from Medicare on when it comes to MVPs. When Medicare requires MVPs, how do they define who can use a subgroup, and what do they do with providers who don’t have an MVP that’s that is applicable to them?”
Brigid: Those are exactly the questions that come up when we talk about MVPs with Mingle Health clients.
To answer the first question of how a practice knows if they have to be a subgroup: we aren’t sure yet.
We have obviously done a great deal of research, and we’ve put in many tickets to CMS, and they have provided some information to help us understand how they’re determining requirements for a multi-specialty practice.
It still isn’t very well defined, and what we are finding through tickets, support calls, and questions to Medicare and their contractors is that it seems like there is an idea that a specialty or multi-specialty practice would have their specialties clearly defined.
For example, if you’re providing cancer care, maybe you have a hematology department, an imaging department, and a palliative care department. But what we find is that many practices don’t follow that clean and neat model.
In this example, you might have someone whose taxonomy is palliative care but they only work with cancer patients. So, the Advancing Cancer Care MVP would be very appropriate for the work they’re doing but may not match their taxonomy.
CMS hasn’t really clearly defined where the rules and lines are around this example situation, and how a practice or a vendor such as Mingle Health would be able to identify which MVPs are appropriate for which practices, providers, and subgroups.
What I do expect with this issue is that with the 2026 timeframe kind of looming, we will either get a lot of clarification very soon, or that timeframe might be kicked out a little bit.
The other question you brought up that I think is really interesting and important to address is what to do in the event that you are required to do an MVP but no MVPs are available to you.
Going back to the example of a cancer care center with a palliative care specialist, there is no palliative care MVP at the moment. In this instance, we’re not really sure what CMS would expect from that provider. We’re not exactly sure what they would have to do.
These are some of the ongoing operational questions that haven’t been fully defined by CMS when it comes to MVPs.
They have a great idea with MVPs, and it makes a lot of sense that they want practices and providers to report on the type of care they’re doing so that patients can be healthier, and costs can be lower.
But when we get into the nitty-gritty details of how to implement the idea, it can take a bit longer to sort everything out. I think what we’re seeing with MVPs is that there’s still some definitions and resources that CMS needs to provide.
So again, this brings me back to the importance of commenting on Proposed Rules. Every practice and provider probably will need to report MVPS at some point. Being very mindful of the requirements, rules, and nuances of those rules as they’re being formed can help all of us set MVPs up for success.
This means that we need to be reading Proposed Rules, making comments on how a proposed process would work for your practice, and letting CMS know how you think the program should change and evolve.
Question Ten: Changes for MSSP ACOs in the 2025 Final Rule
Dr. Mingle asks: “Let’s move our attention now to the APP, that is the APM Performance Pathway as it pertains to Medicare Shared Savings Program (MSSP) ACOs. With the release of the 2025 Final Rule for the Medicare Shared Savings Program, what do you see as the most significant changes affecting the MSSP clients that you and your team work with?”
Brigid: MSSP has some changes coming, that’s absolutely for sure.
Originally CMS had proposed to sunset MIPS CQM reporting in 2025. They have postponed that for at least two years, so there’s still some time for APP submissions to be made using MIPS CQMs.
In the Final Rule, CMS finalized the APP Plus measure set. In this, they’ve added additional measures in a similar stepwise pattern to what we talked about previously with MVPs. They’re doing it very slowly, adding one measure per year at the moment.
In 2025, the breast cancer screening measure has been added. In 2026, we expect to see the colorectal cancer screening measure added. In 2027, the substance use disorder measure. In 2028, they are anticipating adding the screening for social drivers of health.
Question Eleven: MIPS and APP Plus Differences
Dr. Mingle asks: “We talked about an annual rhythm to MIPS reporting earlier. Are there any differences in that when you’re thinking about APP Plus?”
Brigid: Absolutely! The key difference is just in the amount of time required.
For a MIPS submission, we’re usually talking about one to three practices and a handful of locations, probably on similar if not the same systems.
For APP reporting, the volume is increased. The steps are primarily the same:
- We’ll start by identifying the goals of the ACO and their participants.
- Then we start to get data and begin data validations.
- We make sure we are all on the same page as far as what data is required and what that means for the ACO.
- Then, we look at scoring and optimizing the ACO’s performance.
While the steps are the same, the time frame is significantly longer for an ACO. For a MIPS submission, we’re talking about the 15-month Performance Year outlined earlier. For an APP client, we’re probably looking at two years to have optimal results.
The data validation piece always takes longer than expected. We all anticipate getting systems connected to each other and getting all the required information back and forth for one instance. But when you multiply that instance by 40, 50, or 100 for some ACOs, the challenge only grows that much larger.
Question Twelve: When to Start APP Reporting
Dr. Mingle asks: “Does that mean that an ACO shouldn’t even bother to sign up if they don’t have two years to work with?”
Brigid: Not at all! Very similar to MIPS, the speed of the project really depends on how you are able to engage with us. The more time you can give the project, the better your results are going to be, but you should start when you are able.
There are definitely ACO practices that are able to engage very quickly, and the data comes through for us to do our validation and feel confident that we can move forward. Just like in MIPS with a shortened timeframe, the early results may not be the optimal results, but the important thing to remember is that we need to start with “good” and reach toward optimal.
If we wait until we can do it perfectly, we’re waiting forever.
Question Thirteen: Service Differences Between MIPS and APP Reporting
Dr. Mingle asks: “How do you find that your service differs from the typical MIPS participant to the typical MSSP ACO with an APP submission?”
Brigid: When we work with a practice to report MIPS, we’re working directly with the practice and sometimes directly with the provider themselves.
When we’re working with an ACO for their APP submission, we’re working with the ACO at the organizational level. The ACO entity usually has support staff with very knowledgeable folks to move the project forward.
In this case, our role at Mingle Health is to be the technical support that keeps the ACO updated on regulatory changes, clarifications as we process their data, and assist in technical issues that may be slowing the APP project down. We support the ACO, who in turn supports the practices in the ACO.
Now there are times when the ACO might find (or know off the bat) that they don’t have the staff or the expertise that would be needed to support the practices themselves.
We’re definitely available to help if that’s a need that the ACO has, but in general, what we find is that Mingle Health gets to help ACOs at the organizational level to share knowledge and support their practices in the best way possible.
And, if an ACO starts working with us and thinks their need is one thing but they discover other things that we can help with, we’re happy to be flexible and add additional support and services. We can rethink the way we work together if the ACO’s needs change, and we have products and support in place to make sure that the ACO and its member practices are successful.
That can look a little different for everyone, and we work to meet our clients where they are to move their quality reporting project forward.
Question Fourteen: Characteristics of ACOs that Succeed in APP Reporting
Dr. Mingle asks: “Pulling it all together, for the MSSP ACOs doing APP Plus submissions, what are the characteristics your team sees in clients who excel?”
Brigid: It really comes down to engagement, once again.
The more understanding that the ACO has about the requirements and their current performance, and the more connection that the ACO has with their practices, the better their results will be.
If ACOs are working with us and following the steps with their Mingle Health Consultants and support team, they’re going to be successful.
There are of course some unique barriers in the ACO landscape. Oftentimes, the ACO doesn’t necessarily own the data that the practices have. So the more time the ACO has to cultivate a relationship and gain access to that data, the better.
Send us your value-based care questions!
If you’d like to ask a question about the APP transition, MIPS, ACO quality reporting, or any other Alternative Payment Model, you can reach out to us in three ways:
You can leave your questions in a YouTube comment under any episode of Ask Dr. Mingle.
On LinkedIn, leave your questions in a comment on any of our posts.
And you can reach out directly by sending an email to hello@minglehealth.com.

As MIPS becomes more difficult, it's crucial to have a plan in place. We've made a guide that provides an overview of 2025 MIPS requirements and changes to help you and your organization find success in the 2025 Performance Year.