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Reporting Requirement

Scoring Logic

Quality Reporting Requirements

For the 2026 Performance Year (PY), Clinicians can select from 195 quality measures approved by CMS. Data needs to be collected and submitted for each selected quality measure for the entire 2026 calendar year.

To meet the Quality performance category requirements, a MIPS eligible clinician, group, or virtual group can report:

  • 6 quality measures (including at least one outcome measure or high priority measure in absence of an applicable outcome measure) for the 12-month performance period; OR
  • A defined specialty measure set (if the measure set has fewer than 6 measures, all measures within that set need to be submitted)

Data Completeness

For 2026, the data completeness requirement is 75%. Clinicians need to report performance or exclusion/exception data for at least 75% of patients or encounters that are eligible for the measure’s denominator.

What’s New with Quality in 2026?

  • The quality performance category weight remains 30% for individual MIPS eligible clinicians, groups, and virtual groups participating in traditional MIPS.
  • Minimum criteria for a submission for the quality performance category has been defined as numerator and denominator information for at least one quality measure from the list of MIPS quality measures to be considered a data submission and scored.
  • CMS is making updates at the measure level and specialties may notice shifts in which measures remain available in their sets
  • Measure set updates includes 5 new quality measures, 32 measures have substantive changes, and there were 10 measures removed

PI Reporting Requirements

Promoting Interoperability (PI) in 2026 at a glance:

Performance period
Collect data for a minimum of 180 continuous days in CY 2026. The last 180‑day period begins July 5, 2026.

Required attestations—updated in 2026

  • Security Risk Analysis (SRA) now requires two “Yes” attestations: (1) SRA conducted/reviewed and (2) security risk management activities performed (HIPAA Security Rule). A “No” yields 0 points for PI.
  • SAFER Guide attestation must use the 2025 High Priority Practices SAFER Guide; “No” = 0 points.
  • HIE objective – options (2026)
    Continue to choose one of:
     (a) Send/Receive & Reconcile measures, or
     (b) HIE Bi‑Directional Exchange, or
     (c) Enabling Exchange under TEFCA (new optional pathway carried into 2026, may also earn bonus under Public Health & Clinical Data Exchange).
  • Measure suppression policy (PI)
    CMS maintains a measure suppression policy to address circumstances (e.g., ECR pause) while ensuring full credit when suppression applies.
  • Automatic reweighting (PI) & special statuses—New & Updated for 2026
    PI remains 25% of the final score (standard weighting). CMS automatically reweights PI to 0% for certain special statuses (e.g., ASC‑based, hospital‑based, non‑patient‑facing, small practice); qualifying entities may still report PI if they wish.
  • CMS modified the Public Health and Clinical Data Exchange objective by adopting a new optional bonus measure: the Public Health Reporting Using TEFCA measure. The measure is 1 of 4 available bonus measures under the Public Health and Clinical Data Exchange objective, in which a maximum of 5 points can be earned if reporting one, more than one, or all optional bonus measures.

IA Reporting Requirements

The Improvement Activities (IA) performance category focuses on one of the MIPS strategic goals, to use a patient-centered approach to program development that leads to better, smarter, and healthier care.

Improvement Activities are classified into Care coordination, Beneficiary engagement, and Patient safety sub-categories which MIPS eligible clinicians could select from a list of 95 activities.

MIPS eligible clinicians or groups can attest to the activities performed for a period of minimum 90 continuous days and qualify for a score in IA category. The last start date is Oct 3, 2026.

At least 50% of the clinicians (in the group or virtual group) must perform the same activity during any continuous 90-day period, or as specified in the activity description, within the same performance period.

What’s New with Improvement Activities (IA) in 2026?

  • Addition of 3 new IAs, it includes an MVP-specific improvement activity titled “Practice-Wide Quality Improvement in MIPS Value Pathways”.
  • Modification of 7 existing improvement activities.
  • Removal of 8 existing improvement activities.
  • Removal of the Achieving Health Equity (AHE) subcategory for improvement activities, replacing it with the new Advancing Health and Wellness (AHW) subcategory.

Cost Reporting Requirements

For the 2026 PY, the Cost category is included in the final score and is weighted for 25% of the final score. Cost will be calculated directly by CMS and therefore no submission will be required.

  • The reporting period will be for the full PY in 2026.
  • Individual eligible clinicians or groups will be scored on 35 measures included in the Cost performance category.
  • Addition of 6 new Episode-based measures.
  • New cost measure exclusion policy beginning with the CY 2025 performance period.
  • Cost benchmarks use performance‑period data, not historical data. Beginning in 2026, new cost measures enter a 2‑year informational‑only feedback period before impacting scores.

Reweighting of Performance Categories

For 2026 MIPS PY, CMS has finalized redistribution of the performance category weights.

Reweighting Scenario Quality Cost Improvement Activities Promoting Interoperability
No Reweighting Needed
• Scores for all four performance categories 30% 30% 15% 25%
Reweight One Performance Category
• No Cost 55% 0% 15% 30%
• No Promoting Interoperability 55% 30% 15% 0%
• No Quality 0% 30% 15% 55%
• No Improvement Activities 45% 30% 0% 25%
Reweight Two Performance Categories
• No Cost and no Promoting Interoperability 85% 0% 15% 0%
• No Cost and no quality 0% 0% 15% 85%
• No Cost and no Improvement Activities 70% 0% 0% 30%
• No Promoting Interoperability and no Quality 0% 50% 50% 0%
• No Promoting Interoperability and no Improvement Activity 70% 30% 0% 0%
• No Quality and no Improvement Activity 0% 30% 0% 70%

Automatic Reweighting Rules for 2026

PI is automatically reweighted to 0% for clinicians, groups, virtual groups, or APM Entities with these special statuses:

  • Ambulatory Surgical Center (ASC)-based
  • Hospital-based
  • Non-patient facing
  • Small practice

These clinicians may still choose to report PI, which overrides automatic reweighting.

MIPS Value Pathways (MVPs)

Merit-Based Incentive Payment (MIPS) Background

The Centers for Medicare and Medicaid Services (CMS) introduced the Quality Payment Program in 2015 with two tracks: MIPS and Advance Payment Model (APM).

In MIPS, performance-based payment adjustments are made for the services provided to Medicare patients based on a Final Score. Performance is measured across 4 areas – Quality, Improvement Activities (IA), Promoting Interoperability (PI) and Cost.

As MIPS has evolved, clinicians and stakeholders have consistently noted that traditional MIPS can be complex, burdensome, and not always aligned with specialty‑specific care.

What are MVPs?

MIPS Value Pathways (MVPs) are CMS’s redesigned reporting framework that emphasizes specialty‑aligned, condition‑focused, and clinically meaningful reporting.

Rather than selecting measures from large, loosely related inventories, MVPs link measures and activities across Quality, IA, PI, and Cost that pertain to a clinician’s specialty, clinical focus, or episode of care. MVPs were first introduced for reporting in 2023, expanded in 2024–2025, and continue to expand significantly in 2026.

In 2026, CMS:

  • Finalized 6 new MVPs (Diagnostic Radiology, Interventional Radiology, Neuropsychology, Pathology, Podiatry, Vascular Surgery).
  • Modified all 21 existing MVPs to update measures and activities for clinical relevance.

MVPs align with CMS’s broader strategy to transition MIPS over time toward more meaningful and consistent measurement.

How are MVPs going to make reporting more meaningful?

Traditional MIPS can overwhelm clinicians with choices and category‑specific scoring rules. MVPs aim to simplify reporting by:

  • Reducing the number of measures clinicians must evaluate.
  • Ensuring measure relevance by tying measures to specialty or clinical focus.
  • Providing more actionable, comparable performance data for clinicians, patients, and caregivers.
  • Supporting the transition to digital quality measurement.

For multispecialty groups, MVPs introduce subgroup reporting, allowing each specialty within the practice to be evaluated on measures meaningful to their work.

NOTE: Beginning in 2026, multispecialty groups may no longer report MVPs as a whole group unless they qualify as a multispecialty small practice (≤15 clinicians).

This design better reflects true clinical performance and avoids penalizing specialties based on irrelevant measures.

Who can report MVPs?

For MIPS 2026, the following entities may report an MVP:

  • Individual MIPS eligible clinicians
  • Single‑specialty groups
  • Subgroups (required for multispecialty groups unless they are small practices)
  • APM Entities (in situations where the MVP is compatible with APP or APM rules)

Key 2026 changes:

  • Multispecialty groups must use subgroups when reporting MVPs, unless they meet the small practice special status, in which case they may still register as a full group.
  • Groups must self‑attest to their specialty composition during MVP registration; CMS will no longer determine this automatically.

What are the reporting requirements of an MVP?

Quality Reporting Requirements

4 quality measures, including 1 outcome measure (or, if an outcome measure is not available, 1 high priority measure, included in the MVP, excluding the population health measure).

IA Reporting Requirements

An MVP Participant must report one of the following: two medium-weighted improvement activities; one high-weighted improvement activity; or participation in a certified or recognized patient-centered medical home (PCMH) or comparable specialty practice.

Foundation Layer Reporting Requirements:

PI Reporting Requirements

The entire set of Promoting Interoperability measures, as a part of the foundation layer, are included in all MVPs.

Population Health Measures

CMS is removing the requirement to select a measure during registration. CMS will calculate these measures through administrative claims and will be scored as part of the quality performance category.

Quality

IA

Cost

4 quality measures, including 1 outcome measure

For MVP reporting, clinicians, groups, and subgroups (regardless of special status) must attest to 1 activity.

CMS calculates performance exclusively on the cost measures included in the MVP using administrative claims data.

no submission required

First steps to prepare for MVP reporting

MIPS Value Pathways (MVPs) continue to expand in the 2026 performance year. Understanding how MVPs have evolved will enable clinicians to select the reporting option that best aligns with their specialty, supports meaningful measurement, and increases the opportunity for positive payment adjustments.

Below are the MVPs available for reporting in 2026, including the 6 newly added MVPs.

  • Adopting Best Practices and Promoting Patient Safety within Emergency Medicine
  • Advancing Cancer Care
  • Advancing Care for Heart Disease
  • Advancing Rheumatology Patient Care
  • Complete Ophthalmologic Care
  • Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes
  • Dermatological Care
  • Focusing on Women’s Health
  • Gastroenterology Care
  • Improving Care for Lower Extremity Joint Repair
  • Optimal Care for Kidney Health
  • Optimal Care for Patients with Urologic Conditions
  • Patient Safety and Support of Positive Experiences with Anesthesia
  • Prevention and Treatment of Infectious Disorders Including Hepatitis C and HIV
  • Pulmonology Care
  • Quality Care for Patients with Neurological Conditions
  • Quality Care for the Treatment of Ear, Nose, and Throat Disorders
  • Quality Care in Mental Health and Substance Use Disorders
  • Rehabilitative Support for Musculoskeletal Care
  • Surgical Care
  • Value in Primary Care

New MVPs Finalized for the 2026 Performance Year:

  • Diagnostic Radiology
  • Interventional Radiology
  • Neuropsychology
  • Pathology
  • Podiatry
  • Vascular Surgery

1. Identify an MVP relevant to your specialty or clinical focus.
Review whether you already report the Quality measures included in that MVP and how your prior‑year performance on those measures compares.

2. Review the MVP’s Improvement Activities (IAs).
Many practices may already be performing required IAs; confirm alignment and documentation.

3. Check compatibility with your workflow and health IT systems.
Remember that all PI measures are mandatory for MVP reporting unless a PI exception or automatic reweighting applies. Ensure CEHRT capabilities meet 2026 PI requirements.

4. Register for your 2026 MVP ➡ April 1, 2026 – November 30, 2026