Table of Contents
- CMS Final Rule: The Impact on EHRs and Practice Partners
- Risk of Non-Compliance: Penalties and Practice Disruption
- MIPS 2025 Compliance Action Plan
- How MRO’s Qualified Registry Ensures Seamless MIPS Compliance
In the 2024 Physician Fee Schedule Final Rule, CMS made a significant change that directly impacts EHR vendors and their practice partners. Starting with Performance Year 2025, CMS finalized the elimination of the health IT vendor category of third-party intermediaries. As such, health IT vendors, which include EHR vendors, can no longer serve as third-party intermediaries for MIPS submissions unless they become a CMS-approved Qualified Clinical Data Registry (QCDR) or Qualified Registry (QR).
CMS Final Rule: The Impact on EHRs and Practice Partners
This regulatory shift was implemented to remove gaps in third-party intermediary requirements and improve data integrity. EHR vendors can still facilitate data collection and support practices with “sign in and upload” or “sign in and attest” submission types, however, to submit data on behalf of clinicians, a health IT vendor will now need to meet the requirements and self-nominate to become a QR or QCDR. The bottom line: adaptation is mandatory, not optional.
QR/QCDR Integration is Your Competitive Edge
With health IT vendors unable to submit directly without proper credentials, seamless integration with approved QCDRs and QRs becomes critical, and integration capabilities directly impact an organization’s value. This requires robust API development for data exchange, standardized data formats, and streamlined workflows that reduce practice burden.
How Strategic Partnerships Drive MIPS Success in 2025
EHR vendors who previously offered direct MIPS submission services must now pivot toward strategic partnerships. This evolution includes:
- Developing or strengthening direct integration capabilities with approved entities.
- Ensuring a strategic partnership between your EHR vendor and QCDRs/QRs.
- Potentially white-labeling QCDR services within your platform.
- Focusing on specialty-specific measure support through partnerships.
Risk of Non-Compliance: Penalties and Practice Disruption
The timeline for adaptation is tight, and the consequences of non-compliance are severe, therefore organizations must act early to prevent the following:
- Payment penalties: If providers unknowingly use a non-compliant third-party vendor for 2025 submissions, their data may not be accepted by CMS, potentially leading to a negative MIPS payment adjustment (up to -9% in 2027 based on 2025 performance).
- Data rejection: CMS will not accept submissions through unauthorized intermediaries.
- Operational disruption: Practices may need to switch vendors if their current one doesn’t meet the new criteria, leading to potential disruptions in MIPS reporting workflows involving new contracts, data migration, and training.
MIPS 2025 Compliance Action Plan
To best navigate your MIPS submission for 2025, the action plan below should be consulted and utilized:
- Audit Your Current MIPS Services
Determine immediately whether your current offerings comply with the new intermediary requirements. If you’re planning on submitting data directly to CMS without QCDR or QR status, you’re not compliant. - Evaluate Partnership Opportunities
Research CMS-approved QCDRs and QRs that align with your practice demographics. CMS publishes lists of approved QCDRs and QRs, where you can discover possible partners who support your specialties and offer comprehensive measure libraries. - Enhance Your Integration Capabilities
Invest in seamless data transfer technologies that connect your EHR platform with CMS approved entities. Focus on robust APIs and standardized data formats to facilitate efficient and accurate data transfer. - Communicate Proactively with Practices
Help your practices understand these changes before they impact performance. Providers need to be more diligent in verifying their vendor’s CMS-approved status to avoid issues with their MIPS submissions. Provide clear guidance on compliant reporting pathways to build trust and prevent compliance issues. - Considerations for Special Groups
Small practices often rely heavily on third-party assistance for MIPS reporting and will need to be particularly aware of this rule change to ensure continued compliance. Similarly, APM entities and virtual groups also have specific reporting requirements, and their chosen third-party intermediary must be approved by CMS.
How MRO’s Qualified Registry Ensures Seamless MIPS Compliance
The 2025 Performance Year is underway, and practices need compliant reporting solutions now. There is a short timeline to adapt before PY 2025 submissions, and delaying your adaptation strategy puts both your business and your practice partners at risk. Begin your partnership evaluation today, enhance your integration capabilities, and ensure your practices maintain uninterrupted MIPS compliance.
If you need a partner, MRO is prepared for the 2025 regulatory landscape with our CMS-approved Qualified Registry (QR), Polaris. MRO’s QR addresses all compliance requirements, including:
- Established CMS approval: Polaris is fully compliant and ready for PY 2025 reporting.
- Comprehensive EHR integration: MRO integrates with over 160 EHR platforms for seamless data transfer and reporting.
- Complete measure coverage: Polaris supports all MIPS Clinical Quality Measures (CQMs) and electronic Clinical Quality Measures (eCQMs) for PY 2025.
- Multi-specialty expertise: Being a multispecialty QR, Polaris supports all MIPS Value Pathways (MVPs) for PY 2025 reporting.
If your organization needs a reliable partner to navigate these regulatory changes, contact us today to ensure your practices maintain compliant MIPS reporting without disruption.
Ranu Ray, CMS Research Business Analyst at MRO, contributed to the above blog post.
