This past week, the Centers for Medicare & Medicaid Services (CMS) announced the suspension of eight improvement activities under the Merit-Based Incentive Payment System (MIPS) for the 2025 performance year.
The notice stated that “this decision aligns with the Improvement Activities Suspension Policy finalized in the CY 2021 Physician Fee Schedule (PFS) Final Rule (86 FR 65465),” and it can be seen as a precursor to their potential removal in future rulemaking.
MIPS, a key component of the CMS Quality Payment Program (QPP), requires eligible clinicians to report across four performance categories: quality, cost, promoting interoperability, and improvement activities. The improvement activities category specifically aims to encourage practice-level enhancements that support patient engagement, access to care, and population health.
For 2025, CMS is suspending the following eight activities:
- IA_AHE_5: MIPS Eligible Clinician Leadership in Clinical Trials or Community-Based Participatory Research (CBPR);
- IA_AHE_8: Create and Implement an Anti-Racism Plan;
- IA_AHE_9: Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols;
- IA_AHE_11: Create and Implement a Plan to Improve Care for LGBTQ+ Patients;
- IA_AHE_12: Practice Improvements that Engage Community Resources to Address Drivers of Health;
- IA_PM_6: Use of Toolsets or Other Resources to Close Health and Health Care Inequities Across Communities;
- IA_ERP_3: COVID-19 Clinical Data Reporting with or without Clinical Trial; and
- IA_PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B.
While these activities are no longer available for selection in 2025, clinicians who have already completed or are in the process of completing them may still attest and receive credit. CMS has stated that all related QPP resources, including guides, factsheets, and the “Explore Measures and Activities” tool are currently being updated to reflect these suspensions. However, as of this report, nothing is available on the QPP website.
The rationale for these changes has not been elaborated on, but the move is expected to stir debate, particularly given that several of the suspended activities focus on health equity, social determinants of health (SDoH), and pandemic-related responses. CMS had previously emphasized these areas as high-priority in the wake of COVID-19 and ongoing efforts to reduce health disparities; however there is clearly a political shift in focus with the current administration.
Clinicians and practices participating in MIPS are advised to consult the updated 2025 Improvement Activities Inventory to identify alternative activities that align with their practice capabilities and patient population needs. The inventory remains a critical tool for guiding MIPS compliance and maximizing performance scores, which directly influence Medicare payment adjustments.
This suspension reflects an evolving policy landscape within CMS as the agency continues to balance an emphasis on regulatory burden reduction with the promotion of value-based care.
Per the news brief, additional updates and proposals are anticipated in future rulemaking cycles.
Programming note:
Listen live on Talk Ten Tuesday today at 10 am Eastern, when Tiffany Ferguson reports this story.
