The healthcare landscape is in constant evolution, and the Merit-Based Incentive Payment System (MIPS) is no exception. For 2026, the Centers for Medicare & Medicaid Services (CMS) is continuing its deliberate shift away from traditional MIPS reporting and doubling down on a more streamlined and clinically relevant framework: MIPS Value Pathways (MVPs). This transition signals a significant change in how performance is measured and rewarded, and it's crucial for physicians, clinicians, and medical office administrators to understand the implications for their practices.
The overarching goal of these changes is to reduce reporting burdens while encouraging participation in value-based care that is more meaningful to specific specialties and patient populations. Let's delve into the key MIPS changes for the 2026 performance year and what your practice can do to prepare.
The most significant change for 2026 is the continued expansion and emphasis on MVPs. While still optional for now, CMS is clearly positioning MVPs as the future of MIPS. Unlike the traditional MIPS framework where participants could choose from a wide array of measures, MVPs are pre-packaged sets of measures and activities tailored to specific specialties or conditions. This approach aims to provide a more cohesive and relevant assessment of performance.
For 2026, CMS has introduced six new MVPs, including:
Diagnostic Radiology
Interventional Radiology
Neuropsychology
Pathology
Podiatry
Vascular Surgery
In addition to these new pathways, 21 existing MVPs have been updated to reflect the latest clinical guidelines and priorities. This expansion means that more specialists will have a dedicated and clinically relevant reporting option available to them.
A key change for multispecialty groups is that starting in 2026, they will no longer be able to register as a group to report an MVP. Instead, they will need to report at the individual, subgroup, or APM Entity level.
In a move to provide some stability amidst these changes, CMS has maintained the MIPS performance threshold at 75 points for the 2026 performance year. This means that clinicians will need to achieve a score of 75 to avoid a negative payment adjustment.
Beyond the significant focus on MVPs, there are also important updates within the four MIPS performance categories:
Quality: The quality measure inventory continues to be refined. For 2026, five new quality measures have been added, 30 have been substantively changed, and 10 have been removed. It is crucial for practices to review these changes to ensure they are reporting on the most appropriate and up-to-date measures.
Cost: The total number of cost measures will remain at 35 for the 2026 performance year. A notable update is to the Total Per Capita Cost (TPCC) measure, which has been adjusted to limit its attribution to highly specialized groups based solely on the billing of advanced care practitioners. Furthermore, CMS has finalized a two-year informational-only feedback period for any new cost measures. This will allow clinicians to see their performance on new measures without it impacting their MIPS final score, providing valuable time to adapt.
Improvement Activities: The Improvement Activities category has also seen some adjustments. Three new activities have been added, seven have been modified, and eight have been removed. One notable change is the replacement of the "Achieving Health Equity" subcategory with "Advancing Health and Wellness."
Promoting Interoperability: For the Promoting Interoperability category, there are a few key updates for 2026. Practices will now be required to use the updated 2025 edition of the High Priority Practices SAFER Guide. Additionally, there is a new opportunity to earn up to five bonus points for practices that report their 2026 MIPS data through a Trusted Exchange Framework and Common Agreement (TEFCA) participant.
With these changes on the horizon, proactive preparation is key to a successful MIPS reporting year. Here are some steps your practice can take now:
Familiarize Yourself with MVPs: Even if you are not planning to report via an MVP in 2026, it is essential to understand this evolving framework. Review the available MVPs to see if there is one relevant to your specialty.
Review Measure Changes: Carefully examine the changes to the quality measures and improvement activities to ensure your practice is aligned with the latest requirements.
Assess Your Promoting Interoperability Readiness: Ensure you are prepared to meet the updated requirements for the SAFER Guide and consider the potential benefits of reporting through a TEFCA participant.
Engage Your Team: Open communication with your clinicians and administrative staff is crucial for a smooth transition. Ensure everyone understands the upcoming changes and their roles in the reporting process.
The MIPS landscape is undoubtedly complex, but the shift towards more clinically relevant and streamlined reporting through MVPs offers a promising future for value-based care. By staying informed and taking proactive steps to prepare, your practice can navigate these changes successfully and continue to deliver high-quality care to your patients.