The Centers for Medicare & Medicaid Services (CMS) has posted the 2025 Quality Payment Program final rule. An analysis of the rule, including key highlights specific to sleep medicine, is provided below. CMS has finalized the following for 2025:

Quality Performance Category

  • Finalized a total of 195 quality measures
    • Addition of seven quality measures
    • Removal of 10 quality measures
    • Significant revisions to 66 quality measures

*Qualified Clinical Data Registry (QCDR) measures are not a part of this finalized measure count.

Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs)

  • 21 total MVPs
    • New:
      • Complete Ophthalmologic Care MVP
      • Dermatological Care MVP
      • Gastroenterology Care MVP
      • Optimal Care for Patients with Urologic Conditions MVP
      • Pulmonology Care MVP*
      • Surgical Care MVP
    • Modified:
      • Adopting Best Practices and Promoting Patient Safety within Emergency Medicine MVP
      • Advancing Cancer Care MVP
      • Advancing Care for Heart Disease MVP
      • Advancing Rheumatology Patient Care MVP
      • Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes MVP
      • Focusing on Women’s Health MVP
      • Improving Care for Lower Extremity Joint Repair MVP
      • Optimal Care for Kidney Health MVP
      • Patient Safety and Support of Positive Experiences with Anesthesia MVP
      • Prevention and Treatment of Infectious Disorders Including Hepatitis C and HIV MVP
      • Quality Care for Patients with Neurological Conditions MVP (CMS is modifying the previously finalized Optimal Care for Patients with Episodic Neurological Conditions and the Supportive Care for Neurodegenerative Conditions MVPs into a single consolidated neurological MVP titled Quality Care for Patients with Neurological Conditions.)
      • Quality Care for the Treatment of Ear, Nose, and Throat Disorders MVP
      • Quality Care in Mental Health and Substance Use Disorders MVP
      • Rehabilitative Support for Musculoskeletal Care MVP
      • Value in Primary Care MVP

*As the measure steward of measures Q277 (Sleep Apnea: Severity Assessment at Initial Diagnosis) and Q279 (Sleep Apnea: Assessment of Adherence to Obstructive Sleep Apnea (OSA) therapy), the AASM strongly advocated for the inclusion of these measures along with all other proposed quality measures and improvement activities in the Pulmonology Care MVP to enhance care for pulmonology patients. We strongly encourage our members to submit this MVP.

MIPS Payment Adjustments

The performance threshold will remain at 75 points for the 2025 performance period/2027 MIPS payment year.

Data Completeness

The 75% data completeness threshold will remain through the 2028 performance period/2023 MIPS payment year.

Advanced Alternative Payment Models (APMs)

CMS established the APP Plus quality measure set as a second measure set distinct from the existing APP quality measure set.

  • There will be six measures available in the APP Plus quality measure set in the 2025 performance period, eight measures in the 2026 performance period, nine measures in the 2027 performance period, and 11 measures no sooner than the 2028 performance period.
    • MIPS eligible clinicians, groups, or APM entities that report the APP may choose to report either the APP quality measure set or the APP Plus quality measure set.

Measure Name Year Measure Will Be Added to the APP Plus Measure Set
Diabetes: Hemoglobin A1c (HbA1c) Poor Control 2025
Preventive Care and Screening: Screening for Depression and Follow-up Plan 2025
Controlling High Blood Pressure 2025
CAHPS for MIPS 2025
Hospital-Wide, 30- day, All-Cause Unplanned Readmission (HWR) Rate for MIPS Eligible MIPS Clinician Groups 2025
Breast Cancer Screening 2025
Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions 2026
Colorectal Cancer Screening 2026
Initiation and Engagement of Substance Use Disorder Treatment 2027
Screening for Social Drivers of Health 2028
Adult Immunization Status 2028

Members may send questions regarding changes to the Quality Payment Program to registry@aasm.org.