An individual is defined as a single National Provider Identifier (NPI) tied to a single Tax Identification Number (TIN). In comparison, a group is defined as a set of clinicians (two or more, identified by their NPIs) sharing a common TIN, irrespective of specialty or practice site.

Reporting as Individuals

• The data for all applicable MIPS performance categories will need to be reported for every eligible clinician in the group. (No data submission is required for the Cost category. CMS captures the Cost related data from your claims, if applicable.)

• MIPS score will be calculated based on the individual performance reported, and the payment adjustment will apply to each individual.  

• Eligible clinicians can submit MIPS data as Individuals via a combination of collection types for the Quality category: EHR (eCQMs), Registry (MIPS-CQMs, QCDR measures), and Medicare Part-B Claims measures.
  

Reporting as a Group

• Data will need to be aggregated at the group level for each of the MIPS categories and then reported.

• All the eligible clinicians in the group will get one MIPS score based on the group’s performance.

• Small Practices (2-15 eligible clinicians) can report as a group using Claims measures ONLY if they submit data for another performance category as a group. CMS recognized that not all Small Practices that report Medicare Part B claims measures intend to participate as a group. Therefore, CMS will only calculate a group-level quality performance category score from Medicare Part B Claims measures if the practice submits data for another performance category (PI or IA) as a group, signaling their intent to participate as a group.

• Quality data can be reported via a combination of collection types for the Quality category: EHR (eCQMs), Registry (MIPS-CQMs, QCDR measures), Medicare Claims measures (for small groups only), and CAHPS for MIPS (counts as one quality measure)

• For Groups of 16 or more, an additional measure will be applicable: Hospital-Wide, 30-Day, All-Cause Unplanned Readmission (HWR) Rate. CMS will calculate the score from the Administrative Claims data and apply it to the Quality category. No additional effort is required.

Reporting as Facility-Based Clinicians or Groups

MIPS-eligible providers can check their eligibility to utilize facility-based scoring as individuals or groups using the QPP Participation Status Tool. The qualifying clinicians and groups may have the option to use facility-based measurement scores for their Quality and Cost performance categories.

Facility-based clinicians will automatically receive Quality and Cost performance category scores as an individual based on their facility’s FY 2025 Hospital VBP Program score, even if they do not submit the data for PI and IA performance categories.

In comparison, the facility-based groups will need to submit PI and IA performance categories data as a group to receive Quality and Cost scores based on their attributed facility. The best MIPS score out of the two will determine the Payment Adjustment.

Facility-based measurement scoring will be used for Quality and Cost performance category scores when:

• Clinicians/groups are identified as facility-based; and

• Can be attributed to a facility with a Hospital Value-Based Purchasing (VBP) Program score for the 2025 performance period; and

• The Hospital VBP score results in a higher score than the MIPS Quality measure data you submit and MIPS Cost measure data that CMS calculates for you.

Reporting as a MIPS-APM

The MIPS score for MIPS APM participants will be calculated using the APM Scoring Standard. The performance category weights have been made uniform for all the MIPS APMs. That means the performance category weight distribution stays the same for the Medicare Shared Saving Program (MSSP), Next-Gen ACO, and the Other APMs. 

In addition to the MIPS APM participants, the APM Scoring Standard will also apply to the participants of dual-status APMs (Advanced APM and MIPS-APM) who are not deemed to be a Qualifying Participant (QP) or Partial QP. It will also apply to participants who qualify for Partial QP status and choose to participate under MIPS. The APM Scoring Standard takes precedence for MIPS score calculation for clinicians reporting both as a Group and as a MIPS-APM.  

MIPS APM participants will also have the option to participate in the APM Performance Pathways (APP).

Reporting through MIPS Value Pathways (MVP)

In 2025, eligible clinicians can continue to report through the MIPS Value Pathways (MVP) program, a streamlined reporting option introduced by CMS to reduce the reporting burden by offering pre-selected, specialty-specific measure sets. To participate, clinicians must register for MVP reporting between April 1 and December 1, 2025. CMS offers detailed guidance on the registration process. Providers may report as Individuals or Groups.

There are 21 MVPs available for 2025, each tailored to specific specialties or care areas.
[Explore the 2025 MVPs on QPP]
[Register for 2025 MVP Reporting on QPP]