With exceptional performance bonuses eliminated, MIPS incentives remain modest. Emerging CMS payment models introduce substantially greater financial risk and opportunity.
CMS has released the 2025 Merit-based Incentive Payment System (MIPS) performance results and corresponding 2027 payment adjustments. These results highlight the changing financial dynamics of quality reporting and raise important questions about how healthcare organizations should approach performance measurement.
For the 2025 performance year, clinicians achieving a perfect score of 100 points will receive a maximum positive payment adjustment of 1.3868% in 2027. While this is slightly higher than last year's 1.05%, it remains substantially below the incentives available just a few years ago.
Meanwhile, clinicians with the lowest scores continue to face negative payment adjustments of up to 9%. The financial downside of poor MIPS performance is significantly greater than the reward for exceptional performance.
As CMS introduces models such as the Ambulatory Specialty Model (ASM), the relationship between quality, cost, and financial accountability is becoming even more important.
Important deadline: Requests for a targeted review must be submitted by Nov. 30, 2026, at 8 p.m. ET.
How have MIPS payment adjustments changed?
The maximum positive MIPS payment adjustment has fluctuated considerably over the past four performance years.
| Performance year | Payment year | Maximum positive adjustment |
|---|---|---|
| 2022 | 2024 | +8.26% |
| 2023 | 2025 | +2.15% |
| 2024 | 2026 | +1.05% |
| 2025 | 2027 | +1.3868% |
The dramatic decline after the 2022 performance year reflects a fundamental change in how MIPS incentives are funded. Through the 2022 performance year, MIPS included an exceptional performance adjustment supported by an additional $500 million annual federal funding allocation. That funding ended after 2022.
Beginning with 2023 performance, positive MIPS adjustments depended on the program's budget-neutral payment methodology. Even clinicians achieving perfect scores have since received substantially smaller incentives.
The 2027 maximum positive adjustment represents a modest improvement over 2026, but it remains about 83% below the maximum adjustment available for the 2024 payment year.
How 2025 MIPS scores translate into 2027 payment adjustments
The 2025 MIPS performance threshold was 75 points. Payment adjustments are determined by the final score and the applicable CMS methodology:
- 75 points: A neutral adjustment. No increase or decrease in Medicare Part B payments.
- Below 75 points: For scores above 18.75, the negative adjustment generally increases by 0.12 percentage points for every point below 75. A score of 50 results in minus-3%.
- 18.75 points or below: The maximum 9% penalty. Immediately above that threshold, a score of 18.76 produces approximately minus-6.75%.
- Above 75 points: Positive adjustments increase with the final score, reaching plus-1.3868% for a perfect score of 100.
Why are positive MIPS adjustments so small?
MIPS operates under a budget-neutral payment methodology. In general, penalties assessed on clinicians who perform below the threshold help finance positive adjustments for clinicians who exceed it.
When a substantial proportion of clinicians achieve scores above the threshold, relatively few negative adjustments are available to fund positive incentives. Consequently, even perfect performance scores may generate relatively small increases.
The final positive scaling factor depends on the distribution of scores and payment adjustments across participating clinicians. It can't be known with certainty before CMS calculates the results.
What does this mean in Medicare payments?
Consider a physician or practice with $1 million in Medicare-paid covered professional services subject to MIPS adjustments in 2027.
| MIPS score | 2027 adjustment | Illustrative financial impact |
|---|---|---|
| 100 | plus-1.3868% | +$13,868 |
| 75 | 0% | $0 |
| 50 | minus-3% | –$30,000 |
| 18.75 or below | minus-9% | –$90,000 |
A perfect score would generate approximately $13,868 in additional Medicare payments, while a score of 50 would result in a $30,000 reduction. At the lowest performance levels, the potential reduction reaches $90,000. These examples assume the same Medicare payment base and don't represent an individual organization's actual adjustment.
Three important takeaways for healthcare organizations
1. Avoiding MIPS penalties remains essential
Although positive incentives are modest, the financial consequences of poor performance remain substantial. Organizations should monitor performance, identify gaps throughout the reporting year, and ensure that clinical data is complete, accurate, and appropriately attributed.
2. The financial return on a perfect score is limited
Strong MIPS performance still matters. It demonstrates an organization's ability to manage clinical quality data and comply with complex reporting requirements. However, the incremental financial benefit of moving from a strong score to a perfect score is relatively small. Organizations should weigh the cost of maximizing MIPS performance against the expected payment benefit and the broader value of quality improvement.
3. Quality measurement must deliver value beyond reporting
The data infrastructure supporting MIPS can also enable ACO quality and shared savings performance, clinical gap identification, provider benchmarking, cost-of-care and utilization analysis, episode-based measurement, and broader value-based care arrangements.
The Ambulatory Specialty Model (ASM) changes the financial equation
While traditional MIPS offers relatively modest positive incentives, CMS' Ambulatory Specialty Model (ASM) represents a very different approach to performance-based payment. Beginning Jan. 1, 2027, selected specialists treating heart failure and low back pain will participate in a mandatory five-year CMS Innovation Center model.
| Feature | Traditional MIPS | ASM |
|---|---|---|
| Participation | Based on MIPS eligibility | Mandatory for selected specialists |
| Scoring | 75-point threshold for 2025 | Performance relative to peers |
| Maximum positive adjustment | plus-1.3868% for 2027 payment year | Up to plu-s9% initially |
| Maximum negative adjustment | minus-9% | minus-9% initially |
| Future financial range | Varies by MIPS methodology | Expands to ±12% |
| Primary emphasis | Quality reporting and performance categories | Specialty-specific quality, cost, and care performance |
ASM begins with a potential payment-adjustment range of minus-9% to plus-9%, with that range increasing to ±12% by the final performance year. ASM has no reporting-only year: performance measurement begins Jan. 1, 2027, and the first related payment adjustments apply in 2029.
Participating specialists will be evaluated through an ASM-specific methodology that includes quality, cost, care coordination and interoperability, and engagement and accountability. The payment adjustment is determined relative to other specialists treating the same targeted condition. The upper end of the adjustment corridor is a ceiling, not a guaranteed bonus.
For a physician with $1 million in applicable Medicare Part B payments, a 9% adjustment would represent a potential $90,000 increase or decrease, subject to the actual model methodology. For selected specialists, monitoring quality and episode-level costs early in the performance year will be critical.
What ASM signals about the future
ASM reflects a broader move from measuring and reporting performance toward more direct financial accountability for quality and cost outcomes. Organizations will need to connect clinical quality measurement, episode-based cost analytics, and actionable performance management, rather than relying on retrospective reporting alone.
Special considerations for Shared Savings Program ACOs
Medicare Shared Savings Program ACOs should carefully review their 2025 performance feedback and verify that participating clinicians receive the appropriate final scores and payment adjustments. Authorized ACO representatives can access APM Entity feedback using their approved ACO Management System (ACO-MS) permissions.
An ACO Participant TIN may see a Quality score of zero at the practice level because the ACO, rather than the individual practice, submitted the applicable quality measures through the APM Performance Pathway. That doesn't necessarily represent the score or payment adjustment ultimately assigned to participating clinicians. Organizations should verify actual final scores and the applicable APM Participant List rather than relying solely on an isolated practice-level result.
Targeted review deadline: Monday, Nov. 30
CMS has released 2027 payment adjustment information, and organizations should review their performance feedback promptly. The deadline to request a targeted review is Monday, Nov. 30, 2026, at 8 p.m. ET.
A targeted review allows CMS to reconsider a MIPS final score or payment adjustment when an error may have occurred. Examples include:
- Submitted data associated with an incorrect TIN or NPI
- Incorrect Qualifying APM Participant status
- A performance category that should have been reweighted
- An approved exception or submitted data not correctly reflected
- Other errors affecting final score or payment adjustment calculations
To request a targeted review:
- Sign in to the QPP website.
- Select Targeted Review.
- Explain the potential calculation or eligibility error.
- Submit supporting documentation as requested.
CMS targeted review decisions are final and can't be appealed further through this process. Organizations should investigate unexpected results well before the deadline.
Looking ahead: The value of quality measurement is changing
The 2025 MIPS payment adjustments reinforce a growing distinction between regulatory reporting and performance-based financial accountability. Under traditional MIPS, a perfect score produces a modest positive adjustment, while low performance can result in a substantial penalty. Newer models like ASM are changing the stakes.
As CMS moves toward more specialty-specific and value-based payment arrangements, healthcare organizations need a more comprehensive view of quality, cost, and performance.
At Healthmonix, we believe quality measurement should do more than produce a regulatory score. It should help organizations understand clinical performance, identify opportunities to improve care, manage costs, and make informed decisions that improve patient outcomes and financial results.
Traditional MIPS may offer modest financial rewards, but the importance of accurate quality and cost measurement is only increasing.
