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2023 QPP Performance Data are Out: 14.56% of Practitioners Will See a Penalty in Their 2025 Medicare Payments

by | Jul 9, 2025 | Fight the Good Fight, Healthcare Payment Policy | 0 comments

2023 QPP Performance Data are Out: 14.56% of Practitioners Will See a Penalty in Their 2025 Medicare Payments

CMS has released Quality Payment Program (QPP) performance data for 2023. Under the QPP, payment “adjustments” (bonuses and penalties) occur two years after the “performance year,” so that 2023 scores impact a practitioner’s 2025 Medicare payments. It’s important to know that a practitioner’s bonus or penalty goes with him/her to the next practice setting. If you are hiring a new practitioner, you might want to check out whether they are going to bring a “negative payment adjustment” to your organization in 2025. The CMS annual report tracks participation in each of the QPP reporting pathways – the traditional Merit-Based Incentive Payment System (MIPS), the MIPS Value Pathway (MVP), and alternative payment models (APMs), sharing performance results in the areas of quality, cost, interoperability, and improvement activities. 

The results indicate that a slightly greater percentage of QPP participants will receive positive payment adjustments in 2025 due to overall better 2023 scores. Overall, 80.86% of MIPS-eligible clinicians scored above the 75% performance threshold needed to avoid a penalty, whereas in 2022, 79% of participants scored above the performance threshold. That’s a 2.4% increase in physicians who get a bonus – which is incredibly disappointing. The practitioners who scored above the 75% threshold in 2023 will receive bonuses of up to 2.15% in their 2025 Medicare payments. Depending on your volume of Medicare claims, that bonus may not even cover the costs involved in reporting — but remember that practitioners who were required to participate and didn’t will get a 9% penalty.  

In fact, 2.26% of practitioners will receive the maximum 9% penalty applied to their 2025 Medicare payments, slightly up from 2% the year before. Sadly, 12.3% of practitioners got “less than the maximum” penalty  (no more than 6.75%) which is a small increase from the previous year (12%).  This means that 14.56% of all practitioners will get some reduction in their 2025 Medicare payments, based on their 2023 performance. These penalties tend to hit small practices the hardest since they are generally less likely to have the infrastructure to play the MIPS game successfully.

If you participate in an Advanced Practice Model (APM), you probably did well since those doctors automatically get credit for the Improvement Activity requirement and have other scoring advantages. Their average performance score was 94.4 thanks to some (in my opinion) magical calculations which CMS can effectively make up as an incentive to join an APM. The practitioners who reported through a “MIPS Value Pathway” (MVP) had a mean score of 87.86 points – five points higher than traditional MIPS reporting. Wound care practitioners do not yet have an MVP – but it could be coming. An MVP can’t be created without a “cost measure.” If you missed my scintillating posts about CMS’ attempt to create a cost measure for “non-pressure ulcers,” you can still read about it (see below and “Calculating the Medicare Cost of a Chronic Ulcer – the Answer Might Determine the Future of Wound Care – Caroline Fife M.D.”). This year there will be a second attempt to create a cost measure for chronic ulcers. and I can virtually guarantee that the powers which determine these things will ensure that one is created – even if it is a bad one. And if you suspect this initiative has something to do with the increased use of “skin substitutes,” you would probably be right.

The rest of the practitioners who are stuck with MIPS had an overall mean score of 83.2 which is a small improvement from the previous year. That means practitioners have gotten very slightly better at this complex game.  MIPS is required by law to be a budget-neutral program, which generally means that the projected negative adjustments must be balanced by the projected positive adjustments – a “zero sum game.” When more clinicians receive a penalty, the pool of money for bonuses increases so that the physicians at the top get a larger bonus. (In other words, the penalties that will be levied on all the “mobile” doctors who thought they were exempt in 2024 will help fund bigger bonuses for the rest in 2026.)

Just as a reminder, MIPS is your pathway, there’s a Dec. 31 deadline for two hardship exceptions, as well as recent changes CMS made in the improvement activities category, eliminating eight of the 104 options in May 2025.

Physicians can also preview their 2023 QPP scores through June 25 at 7 p.m., providing corrections or appealing as needed before they’re made publicly available on the Care Compare section of the Medicare.gov site, for consumers wishing to compare a variety of Medicare physicians and facilities, and on the Provider Data Catalog, where visitors can download and access physicians’ MIPS performance scores and improvement activities.  

Resources about developing a Cost Measure for Chronic Ulcers:

The opinions, comments, and content expressed or implied in my statements are solely my own and do not necessarily reflect the position or views of Intellicure or any of the boards on which I serve.

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