MIPS Highlights 2025 – Q4 Wrapping Up the Year

As the year winds down and we head into the holiday season, it’s the perfect time to make sure your practice is well-positioned for a strong finish to the 2025 MIPS performance year. Your Verana IRIS dashboard will continue refreshing monthly, giving you updated insights to help guide your planning and strategy for next year. Before we turn the page to 2026, here’s a recap of the key dates and updates you’ll want to keep in mind: 

2025 MIPS Deadlines 

December 31, 2025

• End of the 2025 MIPS performance period 
• Deadline to submit an Extreme & Uncontrollable Circumstances Hardship Application or PI Exemption 
• Final day to complete the 2025 Security Risk Analysis (SRA) and SAFER Guide 
• Verana Submission Portal – Please refer to the recent email from Verana for details.
  • Upload completed CMS 1500 Claim Form (HCFA)
  • Verify Clinicians 
  • Update TIN details 

January 31, 2026 

• DRCF Form: If you are participating in the 2025 Merit-based Incentive Payment System (MIPS) via the AAO IRIS Registry, the DRCF (Data Release Consent Form) must be signed by January 31, 2026. Important: A $500 fee will be applied to any DRCF signed after January 31, 2026.
  *Verana deadlines may be subject to change. 

End-of-Year Reminder: Improvement Activities 

As we move through the final month of 2025, this is your last opportunity to ensure your practice meets the Improvement Activity (IA) requirement for the 2025 MIPS reporting year. Since CMS requires a minimum 90-day IA performance period, the latest possible start date was October 3, 2025. 

If your practice did not begin an IA by that deadline, you still have options: 

Option 1: Identify an Activity You Already Performed 

Review your practice operations from earlier in the year to determine whether you have already completed an activity that qualifies as an Improvement Activity. Many common workflows—such as care coordination, patient communication processes, or population management efforts—may meet IA specifications if properly documented. 
 
If you can identify a qualifying activity and have supporting evidence, you can still attest for 2025. 

Option 2: Use the CMS MIPS Feedback Survey (IA_EPA_5) 

CMS is currently offering an opportunity that may qualify as a completed Improvement Activity, even at the end of the year. 
 
CMS is requesting input from clinicians who have reviewed their 2024 MIPS final performance feedback on the QPP website. If you participate, your feedback will help CMS refine how performance data is presented in the future. 

Click Here to Take the Survey 
This option can be especially valuable for practices that missed the October IA start date and need a compliant way to meet the IA requirement before the end of the performance year. 

IA Highlights 

• IA_EPA_1 (24/7 Access to Clinicians with Real-Time Record Access) is retired. This was one of the most widely used activities, so you’ll need to select and document a new IA for at least 90 consecutive days in 2025. 
• At least 50% of your MIPS-eligible clinicians must actively perform the chosen IA. 
• Documentation is essential—you must retain proof to support your activity in the event of a CMS audit. 
• CMS has eliminated weighting for Improvement Activities.
  • Large practices: 2 activities (any level) 
  • Small practices: 1 activity (any level) 

Ongoing MIPS Education and Support 

We greatly appreciate the trust you place in us to support your MIPS reporting process. Over the years, we have guided practices through the EMR processes, shared helpful resources, and provided insights to help you successfully manage your MIPS reporting. 

As a reminder, we do not offer personalized MIPS consulting services at this time. 

We are available to help you understand the EMR functionality and available tools. If you’re looking for more in-depth, tailored guidance or performance analysis beyond what our team can provide, we encourage you to explore Verana Health’s MIPS Advisory Services.

As we close out the year, we want to extend our heartfelt thanks for your continued trust, partnership, and loyalty. It’s been our privilege to support your practice, and we look forward to bringing you even greater value as we fully transition to Optivate in the new year. From all of us, we wish you a joyful, restful, and truly happy holiday season. We’re excited for all that 2026 will bring—and grateful to be on this journey with you.