CMS recently released updated MIPS quality measure benchmarks that affect how your performance translates into points for 2024 (https://qpp.cms.gov/api/frontend/benchmarks-csv/quality/2024). Below, we summarize what's new and provide complete lists of newly benchmarked measures, categorized by decile completeness. 

Why some quality measures had no benchmark during 2024 

CMS establishes benchmarks for each quality measure (e.g., Measure ID 001) and collection type (e.g., Medicare CQM, eCQM, QCDR) at the start of every reporting period. In 2024, there were 453 measure/collection type combinations. Of these 215, nearly half (46%) didn’t have a benchmark available for the performance year. 

A measure/collection type may lack a benchmark for several reasons, such as insufficient data from prior reporting years, changes to the measure specifications, or the measure being newly introduced. 

Reasons for no benchmark 

• Insufficient data: If fewer than 20 instances of a measure are reported for a given collection type or the submissions don’t meet data completeness and minimum case requirements, CMS can’t establish a benchmark. (Example: MIPS CQM #102: Prostate Cancer). 

• Specification changes: Measures that have changed specifications, have been newly introduced, or were suppressed during the baseline period aren’t comparable to historical data. That makes historical benchmarks impossible to establish. (Example: MIPS CQM #144: Oncology). 

• Low or non-variable performance rates: If a significant percentage of clinicians report the same score (e.g., nearly all score 100%), it can prevent creation of a meaningful benchmark or lead a measure to be considered “topped out,” sometimes with capped scores but not always a lack of benchmark.  

• New measures:  If a measure is new, it has no benchmark. CMS score new measures at least 7 points in their first year and 5 points in their second year. (Example: MIPS CQM #493: Adult Immunization). 

• Measure suppression: When CMS determines that a quality measure shouldn’t be scored for a given performance year, even if it was originally available in the program, it’s called measure suppression. (Example: MIPS CQM #238: High-Risk Medications).  

What happens when these measures are reported 
If providers reported one or more of the measures without benchmarks, they would have had no knowledge of the resulting score. After all data was submitted to CMS, CMS then attempted to create performance-period benchmarks based on the data submitted in the 2024 performance year for those measures that didn’t have a historical benchmark. This occurs only if reporting thresholds are met and enough eligible clinicians submit data. 

If no benchmark existed, the measure wasn’t in its first or second year, and CMS couldn’t create a benchmark by the end of the year, the measure received 0 points (3 points if submitted by a small practice). 

This week, CMS released the newly calculated quality measure benchmarks for 2024. The new benchmarks in this update reflect measures where CMS received valid reporting data from at least 20 eligible providers or groups for the 2024 reporting period. Each collection type (MIPS CQM, eCQM, QCDR, Medicare CQM) was evaluated separately and received its own benchmark. 

Updated benchmarks for 2024 scoring at a glance 

The data released this week included 78 newly benchmarked quality measures compared to the benchmarks released during the reporting period. New coverage spans QCDR, MIPS CQM, eCQM, and Medicare Part B Claims. All new benchmarks are performance period-based (provisional). 

Why these benchmarks matter 

Benchmarks determine decile scoring. When measures acquire benchmarks, they move from unscored or limited scoring potential to contributing meaningfully to your MIPS score.  

Not all benchmarks, however, are equal. Measures with a full 10-decile distribution provide more predictable, stable scoring than those with partial deciles.  

All measures that received performance year benchmarking could get you 10 points. For some, you would have had to been at 100% performance to get 10 points. 

In reviewing this data, it should be considered in 2 views: 

1. Review from the perspective of your final scores for 2024. Some scores might have improved based on benchmarks created. 
2. Use this data to further plan your 2025 reporting strategy. Measures that received benchmarks means they were deemed usable in 2024. That’s a good indication that they will again get performance year benchmarks in 2025. 

Consider reporting extra measures in 2025 that don’t have benchmarks, as benchmarks may be created after the reporting period and scores could get a boost. Don’t ignore measures with no benchmarks. As we have shown, almost 50% of them ended up with benchmarks in 2024. 

➡️Check out the newly benchmarked measures here ⬅️

What to do next 

• Review from the perspective of the final scores for 2024. Some scores might have improved based on benchmarks created. 
• Refine your 2025 reporting strategy based on this data. Consider additional emphasis for measures with 10 good deciles.    
• Tag measures newly benchmarked with 10 deciles as “priority” for stable points. 
• Optimize by collection type. Where feasible, shift reporting to the collection type with the strongest deciles (e.g., eCQM vs. CQM vs. QCDR), recognizing each has its own benchmark 
• Add a safety net of extra measures. Report 1–2 additional measures that align with your workflows. If CMS creates benchmarks post-period, you gain upside potential. 
• Model MVP scenarios for 2025. Use the new benchmarks to test MVP vs. traditional MIPS scoring. Prioritize MVPs where fully benchmarked measures align with your practice lines.  

If you want to learn more about MVPs, watch our webinar 2026 PFS Proposed Rule: Understanding the impact on MIPS or reach out to us.