How Should Practices Interpret CMS Benchmarks When Targeting a Higher MIPS Score?

Understanding CMS benchmarks can make or break your MIPS performance score. These benchmarks determine how many points you earn for each quality measure you submit, directly affecting your Medicare payment adjustments. With a maximum penalty of 9% for the 2025 and 2026 performance years, interpreting benchmarks correctly isn’t optional.

Key Takeaways

CMS benchmarks compare your performance against historical data to assign points between 1 and 10 for each quality measure.
Historical benchmarks for 2025 are based on data submitted during the 2023 performance period.
Your performance rate doesn’t directly translate to your score; decile placement determines your points.
Topped out measures are capped at 7 points when identified for two consecutive years.
Strategic measure selection based on benchmarks can significantly improve your overall MIPS score.

What CMS Benchmarks Actually Mean

CMS benchmarks work as the scoring scale for every quality measure you submit. Your performance rate gets compared to the benchmark for that specific measure and collection type, placing you in a decile from 1 through 10.

Here’s what many practices get wrong. A high performance rate doesn’t automatically mean a high score. If 60% of providers achieve 100% on a measure, you’ll need perfect performance just to reach the sixth decile. CMS uses historical benchmarks from 2023 submissions for 2025 scoring, meaning you’re competing against data from two years ago.

How Decile Placement Works

The decile system divides performance into ten segments. Decile 1 earns 1 to 1.9 points, Decile 5 earns 5 to 5.9 points, and Decile 10 earns the full 10 points.

The benchmark file shows exactly what performance rate you need for each decile. If a measure’s sixth decile starts at 85% and the seventh at 92%, a rate of 89% places you in the sixth decile for 6 to 6.9 points.

Some measures don’t have all ten deciles populated. When many providers hit the maximum rate, higher deciles show dashes. If deciles 7 through 10 are blank and decile 6 ends at 95%, any performance above 95% automatically earns you 10 points.

Special Benchmark Rules for 2025

CMS introduced changes that affect scoring strategies. Medicare CQMs, available only to ACOs within the APP Plus measure set, now use flat benchmarks for their first two performance periods.

For non-inverse Medicare CQMs, any performance at or above 90% lands in the top decile. Performance between 80% and 89.99% falls in the second highest decile, with lower deciles decreasing by 10% increments.

Topped out measures present another consideration. When a measure is topped out for two consecutive years through the same collection type, it gets capped at 7 points. You could achieve perfect performance and still max out at 7 points instead of 10. However, some topped out measures in specialty sets with limited choices use a special methodology and aren’t subject to the 7-point cap.

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Strategic Measure Selection Using Benchmarks

Start by accessing the current benchmark file from the Quality Payment Program website. Download it as a CSV, open it in Excel, and apply filters to narrow down measures by your specialty and collection type.

Look for measures where your current performance places you in higher deciles. If you’re consistently hitting 85% on a measure where the eighth decile starts at 80%, that’s a strong candidate. Avoid measures where your typical performance barely reaches the third or fourth decile unless you have a concrete improvement plan.

Pay attention to collection type differences. The same measure can have dramatically different benchmarks depending on whether you submit it as a MIPS CQM, eCQM, or Medicare Part B claims measure. Practices focused on quality metrics for ACOs should review all available collection types to find the most favorable benchmark.

Understanding Inverse Measures

Inverse measures flip the typical scoring structure. Lower performance rates indicate better outcomes, and benchmark deciles reverse accordingly.

Hospital readmission measures are a common example. If you’re reporting an inverse measure where the first decile caps at 16%, you need to keep your rate at or below 16% to score in the top tier. The benchmark file marks inverse measures in column G for easy identification.

What Happens Without a Historical Benchmark

Some measure and collection type combinations lack historical benchmarks. This occurs when fewer than 20 providers submitted the measure in 2023 or when the measure is new to the program.

Without a historical benchmark, CMS attempts to create a performance period benchmark using 2025 submission data. If enough providers submit the measure with sufficient data completeness and case minimums, a benchmark gets calculated after the submission period closes and your measure gets scored retroactively.

Practices using electronic quality reporting should note that measures without benchmarks earn 0 points at submission unless you’re a small practice (which earns 3 points).

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Additional Considerations for Complete Reporting

Meeting data completeness (75%) and case minimum requirements (20 cases) is non-negotiable for benchmark scoring. Without these thresholds, your measure receives 0 points regardless of how favorable the benchmark looks. Small practices earn 3 points as protection.

Practices participating in ACO reporting should understand that administrative claims measures use performance period benchmarks exclusively. These include hospital readmission rates and complication rates following certain procedures.

The CAHPS for MIPS survey measures follow their own structure. Each summary survey measure gets scored individually against its benchmark, then averaged for your final CAHPS score.

Putting Benchmark Knowledge Into Action

Smart benchmark interpretation starts with downloading the current file and filtering for your specialty. Look at your historical performance data and honestly assess where you fall in current deciles. Select measures where you have competitive advantages, avoid topped out measures unless you have limited options, and verify that you can meet data completeness requirements.

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Conclusion

CMS benchmarks aren’t just scoring tables, they’re strategic tools. Practices that understand how benchmarks work, how deciles translate to points, and which measures offer the best scoring potential consistently outperform those that select measures based on convenience alone. Review the 2025 benchmark file early, assess your competitive position on available measures, and build your quality reporting strategy around benchmarks that favor your practice’s perform