The era of cherry-picking MIPS measures is ending. CMS is pushing healthcare providers toward MIPS Value Pathways (MVPs), replacing the old “pick your own measures” approach with specialty-focused, thematic measure sets. This isn’t just a policy tweak; it’s a complete overhaul of how quality reporting works in 2025 (and beyond.)
Key Takeaways
- MVPs bundle related measures into specialty-specific pathways, eliminating the ability to select individual measures across categories.
- Multi-specialty practices must use subgroup reporting to align different provider types with appropriate pathways.
- Data collection workflows need major updates to handle comprehensive pathway requirements instead of selective measure reporting.
- Registry systems must provide real-time validation across entire measure sets rather than isolated measures.
- Transition planning should start now to avoid scoring penalties when legacy options disappear.
Understanding MIPS Value Pathways
Traditional MIPS let you pick and choose measures that were easier to report or score well on. MIPS Value Pathways flip this approach entirely. Instead of individual measure selection, you’re working with pre-built bundles that reflect how specialty care actually happens.
Each pathway contains three integrated layers:
- Quality measures specific to the specialty’s patient population
- Improvement activities that align with the clinical focus
- Promoting interoperability requirements tailored to the pathway
The value in primary care pathway, for example, emphasizes preventive care, chronic disease management, and care coordination. These aren’t random measures thrown together—they represent the core activities that primary care practices handle every day.
Related: Understanding the Latest CMS Proposed Rule and How It Impacts You
Who Can Use MVPs and How Subgrouping Works
Not every pathway fits every practice, as CMS bases availability on specialty, size, and MIPS history. Single-specialty groups often have clear choices, while multi-specialty practices benefit from subgroup reporting, allowing each specialty to use relevant pathways, like cardiology under a cardiology pathway and primary care under a primary care pathway, with scores calculated at the subgroup level before rolling up to the overall practice score.
The Quality Payment Program structure makes this more complex than old-school MIPS reporting, but it also makes the measures more clinically relevant to what each provider actually does.
How Measure Selection Changes Everything
The biggest shift is moving from tactical to comprehensive reporting. Under the old system, you could game the measures by picking ones that were easier to document or score well on, even if they didn’t represent your full scope of care.
MVPs eliminate this gaming potential completely. You choose a pathway, and you’re committed to reporting on at least 4 quality measures of a set cluster in that bundle. No more selective reporting—if chronic disease management is in your pathway, you’re reporting on at least 4 of the chronic disease measures clustered within the set, not just the ones you perform well on.
Related: The QPP 2020 Proposed Rule: What are the Major Changes and What Can we Do?
This creates both challenges and opportunities. The challenge is that you can’t hide weak performance areas. The opportunity is that your quality scores will actually reflect comprehensive care delivery instead of isolated activities.
The CMS Proposed Rule makes it clear that this pathway approach will gradually become mandatory for most specialties, so adaptation isn’t optional—it’s inevitable.
Data Infrastructure Requirements
MVP reporting demands much more from your data systems. You can’t focus your data collection on just a few favorite measures anymore. The pathway approach requires comprehensive capture across all measures in your selected bundle.
Your data flow needs to handle this complexity:
- Clinical documentation in your EHR captures patient encounters and interventions
- Registry aggregation pulls data across all pathway measures simultaneously
- Validation processes ensure completeness across the entire measure set
- Submission to CMS happens at the pathway level, not individual measures
The validation piece gets tricky because MVP measures often connect to each other in ways that standalone measures don’t. Care coordination measures might require documentation that also feeds into your chronic disease management measures. Miss one piece, and multiple measures suffer.
MIPS Value Pathways require real-time monitoring across all pathway components, not just the measures you find easiest to track.
Scoring Under the New System
MVP scoring still uses the 100-point scale, but the points get distributed across your entire pathway performance. You can’t rely on a few high-performing measures to carry your score anymore. Consistency across the full measure set becomes critical.
Watch out for these common scoring traps:
- Incomplete pathway reporting kills your entire pathway score
- Wrong subgroup assignments hurt providers who don’t match their pathway
- Data quality gaps become more visible when measures interconnect
- Inconsistent documentation throughout the year rather than just during reporting periods
The integrated scoring approach means you need comprehensive performance management instead of tactical measure optimization. This requires different analytics and monitoring than traditional MIPS reporting provided.
Building Your Transition Strategy
Moving to MVPs isn’t something you can figure out during reporting season. The planning needs to start now, with systematic steps that account for pathway selection, workflow changes, staff training, and system updates.
Your transition timeline should include:
Phase 1: Assessment and Selection
- Evaluate available pathways against your patient populations
- Determine optimal subgroup structure for multi-specialty practices
- Review current data infrastructure capabilities
Phase 2: Infrastructure Updates
- Modify EHR workflows to capture pathway-specific data elements
- Upgrade registry capabilities for comprehensive pathway monitoring
- Establish validation processes for interconnected measures
Phase 3: Implementation and Training
- Train clinical staff on pathway-specific documentation requirements
- Implement real-time performance monitoring across all pathway measures
- Test data flow and validation processes before go-live
The APP requirements add complexity for practices in alternative payment models, requiring coordination between MVP reporting and APM quality measures.
Where Registry Support Makes the Difference
Managing MVP transition requires more than basic measure reporting—it needs integrated data aggregation, validation, and real-time analytics across full measure sets. Patient360 supports this with automated measure selection, seamless multi-EHR data integration, API and sFTP acquisition for comprehensive capture, and continuous analytics that flag performance gaps early enough for clinical and workflow adjustments.
Ready to protect your MIPS scores during the MVP transition? Schedule your MIPS reporting with Patient360 for comprehensive pathway support and performance analytics.
Moving Forward Successfully
The shift from “pick your own measures” to MIPS Value Pathways marks a move toward quality measurement that reflects comprehensive clinical care. Though it reduces some scoring flexibility, it opens opportunities for meaningful improvement, making early transition planning, complete data capture, and strong registry support essential for practices to succeed as CMS phases out traditional measure selection.
