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CMS Halts Eight MIPS Improvement Activities for 2025: What Providers Need to Know
This decision, rooted in the Improvement Activities Suspension Policy finalized in the CY 2021 Physician Fee Schedule Final Rule, signals a possible shift in CMS’s long-term priorities for clinician performance evaluation.The Centers for Medicare & Medicaid Services (CMS) has officially suspended eight Improvement Activities (IAs) under the Merit-Based Incentive Payment System (MIPS) for the 2025 performance year. This decision, rooted in the Improvement Activities Suspension Policy finalized in the CY 2021 Physician Fee Schedule (PFS) Final Rule, signals a possible shift in CMS’s long-term priorities for clinician performance evaluation.
MIPS remains a central element of the Quality Payment Program (QPP), assessing providers across four categories: Quality, Cost, Promoting Interoperability, and Improvement Activities. The Improvement Activities domain encourages providers to implement practice-wide changes that elevate patient engagement, care coordination, access, and overall population health outcomes.
The 8 Suspended Activities
Effective for 2025, CMS has paused the following Improvement Activities:
- IA_AHE_5 – Leadership in clinical trials or community-based participatory research
- IA_AHE_8 – Development and implementation of an anti-racism plan
- IA_AHE_9 – Protocols for identifying and addressing food insecurity and nutritional risks
- IA_AHE_11 – Care plan enhancements for LGBTQ+ patient populations
- IA_AHE_12 – Community engagement strategies addressing drivers of health
- IA_PM_6 – Tools and resources to close health disparities across communities
- IA_ERP_3 – COVID-19 clinical data reporting
- IA_PM_26 – Staff vaccination initiatives for COVID-19, influenza, and hepatitis B
Although these measures will no longer be available for selection in 2025, providers who have completed or are currently working on these activities may still attest and earn credit. CMS has indicated that QPP educational materials, such as factsheets, measure exploration tools, and program guides, are being updated to reflect the latest changes—though, at the time of writing, these updates have not yet been published to the QPP website.
Implications and Concerns
CMS has not released a detailed explanation behind the suspensions, but the move is already raising questions—especially as many of the paused activities align with national efforts to address health equity, social determinants of health (SDoH), and COVID-19 response. Previously, these areas were designated as strategic priorities under CMS initiatives to reduce disparities in healthcare access and outcomes. The latest changes may reflect a broader administrative shift away from these objectives.
Navigating the New Landscape
Clinicians and organizations engaged in MIPS should promptly review the updated 2025 Improvement Activities Inventory to identify viable alternatives. Selecting appropriate activities remains essential for meeting reporting requirements and optimizing payment adjustments tied to performance scores.
These changes underscore CMS’s ongoing attempts to strike a balance between reducing reporting complexity and advancing value-based care. Further proposals and refinements are anticipated in upcoming regulatory updates.
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