MIPS Value Pathways

MVPs are an optional reporting pathway within the Quality Payment Program (QPP). CMS has signaled its long-term intent to transition away from traditional MIPS toward MVPs — a shift that could significantly impact how ophthalmologists report and are scored.

Unlike traditional MIPS — where practices can choose to report any applicable quality measure or improvement activity — MVPs require practices to select a specific MVP focused on a specialty, set of medical conditions, or patient population. Each MVP requires reporting on a defined, more narrowly focused subset of quality measures and improvement activities.

CMS has finalized a single, specialty-wide MVP for ophthalmology: the Complete Ophthalmologic Care MVP, which became available for the 2025 MIPS performance year. Currently, MVP reporting is optional. Ophthalmologists can choose to report through traditional MIPS, through the MVP, or through both options simultaneously — with CMS applying the higher final score.

Below is a summary of the key differences between reporting through traditional MIPS and the Complete Ophthalmologic Care MVP.

Quality Traditional MIPS

Report any 6 measures, including all QCDR measures available through the IRIS Registry. Complete Ophthalmologic Care MVP: Report 4 measures from the MVP's more narrowly focused subset of measures.

Improvement Activities Traditional MIPS

Report any one activity (small practice) or two activities (large practice). Complete Ophthalmologic Care MVP: Report one activity from the MVP's more narrowly focused subset of activities.

Cost Traditional MIPS

Scored on any applicable cost measure if case minimums are met. Complete Ophthalmologic Care MVP: Scored on the Cataract Surgery Cost Measure if the case minimum is met.

Promoting Interoperability Both pathways

Report — or claim an exclusion for — all required measures and earn bonus points for reporting optional measures.

The Academy has concerns that a single, specialty-wide MVP does not adequately reflect the breadth of ophthalmic subspecialties and may limit some clinicians' ability to participate successfully in the program. We continue to urge CMS to keep MVP reporting voluntary and preserve flexibility so ophthalmologists can choose the measures and activities that best reflect their practice and patients.

Advocating to keep MVP reporting voluntary. CMS has indicated a long-term goal of transitioning to mandatory MVP reporting, with the 2029 performance year identified as a potential timeline. The Academy is actively urging CMS to keep MVP reporting optional and allow ophthalmologists to report through whichever pathway works best for their practice.

Raising concerns about specialty-wide MVP design. The Academy has expressed concerns that a single, specialty-wide MVP may not provide sufficient relevant measures for all ophthalmic subspecialties, limiting certain clinicians' ability to succeed in the program. We continue to advocate for a more flexible and inclusive MVP framework that reflects the full range of ophthalmology practice.

Supporting members through IRIS® Registry tools. The IRIS® Registry provides flexibility for reporting through traditional MIPS, the Complete Ophthalmologic Care MVP, or both — helping practices choose the approach that best supports their performance.

If you are planning how to submit your MIPS data, consider whether reporting through an MVP or traditional MIPS — or both — is the better option for your practice.

Things to consider:

• Review the measures and activities included in the Complete Ophthalmologic Care MVP to determine whether they are relevant to your practice and whether you can achieve a high score.
• Consider whether reporting through both pathways could improve your overall performance — CMS will apply the higher final score.

IRIS Registry participants can report through traditional MIPS, the Complete Ophthalmologic Care MVP, or both.