By Amy Ardisana, Director of Registry Account Management, MRO
LinkedIn: Amy Ardisana
LinkedIn: MRO
The Centers for Medicare & Medicaid Services has released the 2026 Physician Fee Schedule Proposed Rule, proposing several changes to the Quality Payment Program (QPP) and its reporting frameworks. Unlike previous years marked by extensive regulatory overhauls, CMS has proposed a limited number of policies, emphasizing its commitment to program stability while continuing the strategic transformation of healthcare quality measurement.
For healthcare organizations navigating these evolving frameworks, these changes represent both strategic opportunities and operational considerations that will shape quality reporting approaches for years ahead.
CMS Proposals 2026: Strategic QPP Stability Through 2028
CMS is maintaining the MIPS performance threshold at 75 points through the 2028 performance period, affecting payments through 2030. This multi-year commitment allows practices and ACOs to plan quality improvement investments with confidence.
The three reporting pathways remain intact: Traditional MIPS, MIPS Value Pathways (MVPs), and the APM Performance Pathway (APP). For ACOs participating in the Medicare Shared Savings Program, the APP continues as the only quality reporting mechanism. However, CMS has made clear that MVPs represent the future of interoperability and digital measures.
Traditional MIPS Changes: Key CMS Proposals for 2026
Quality Category Refinements
The quality category maintains its 30% weight, but the measure inventory receives a thoughtful refresh. CMS proposes five new quality measures, including two eCQMs, while removing ten existing measures and substantially updating 32 others.
The most significant shift involves high-priority measures. CMS proposes removing health equity from this definition, narrowing focus to core clinical domains like outcomes, safety, and care coordination. For specialties with limited measure options, CMS will continue applying alternative benchmarks for 19 topped-out measures.
CMS also proposes to revise the scoring methodology for claims-based measures, aligning it with cost measure benchmarking by using median-based scoring and standard deviations to determine performance thresholds.
Cost Category
The cost category exemplifies CMS’s stability-focused approach. The inventory of 35 cost measures remains unchanged, with proposed modifications only to the Total Per Capita Cost (TPCC) measure.
CMS proposes a two-year informational-only feedback period for any future cost measures. During this time, clinicians would see performance feedback without the measure contributing to their MIPS final score—giving practices time to understand and adapt before any financial impact. These refinements aim to improve fairness and provide more transparency for future cost scoring.
Improvement Activities
For Improvement Activities, CMS is adding three activities, modifying seven, and removing eight. More significantly, they’re eliminating the Achieving Health Equity (AHE) subcategory and replacing it with Advancing Health and Wellness (AHW), signaling a broader strategic shift toward wellness and prevention.
Promoting Interoperability Enhancements
The Promoting Interoperability category maintains its 25% weight while introducing technical updates focused on data security. The Security Risk Analysis measure now requires additional attestation confirming clinicians conducted risk management activities under the HIPAA Security Rule.
Clinicians would be required to use the updated 2025 SAFER Guides for their self-assessments under the High Priority Practices measure.
A new bonus measure encourages public health data exchange using the Trusted Exchange Framework and Common Agreement (TEFCA), supporting broader interoperability goals.
In response to operational barriers, CMS proposes to suppress the Electronic Case Reporting measure for the 2025 performance period due to CDC delays in onboarding new providers and public health agencies.
To proactively address similar issues in the future, CMS also proposes a new measure suppression policy. This would allow CMS to suppress PI measures when unexpected challenges make compliance infeasible or unfair for clinicians.
MVP Expansion: QPP’s Specialty-Focused Future
The most substantial expansion comes in MIPS Value Pathways, with six new specialty-focused MVPs for 2026: Diagnostic Radiology, Interventional Radiology, Neuropsychology, Pathology, Podiatry, and Vascular Surgery. All 21 previously finalized MVPs would be updated to align with proposed changes.
CMS is updating the MVP table format to stratify quality measures by clinical conditions and episodes of care, creating “Clinical Groupings” that help clinicians identify relevant measures for their practice areas. When applicable, an “Advancing Health and Wellness” and/or “Experience of Care” clinical grouping is included for cross-cutting quality measures. This new stratified format offers a streamlined set of quality measures to aid clinicians in selecting the most clinically relevant measures applicable to their clinical area and identifies when quality and cost measures are linked.
Small multispecialty practices receive significant flexibility in MVP reporting requirements, maintaining group reporting options for practices with 15 or fewer clinicians. CMS proposes to: (1) update the MVP group registration process to add the multispecialty self-attestation requirement; and (2) maintain the MVP group reporting option for multispecialty groups with a small practice designation.
Important: Beginning with CY 2026/2028 MIPS payment year, multispecialty groups will no longer be able to report MVP as a single group and will be required to create Subgroups.
Beginning with the CY 2026 performance period/2028 MIPS payment year, QCDRs and qualified registries must support MVPs that are applicable to the MVP participant on whose behalf they submit MIPS data no later than one year after finalization of the MVP in accordance with current requirements. This proposed modification will provide QCDRs and qualified registries with one year following the effective date of the final rule for programming and system preparation for MVP reporting success and reduce potential withdrawal or termination.
APM Performance Pathway and ACOs Under MSSP: 2026 Updates
Alternative Payment Models receive more sophisticated tracking, with Qualifying APM Participant (QP) status determinations expanding to both individual clinician and APM Entity levels. The calculation methodology expands beyond evaluation and management services to include all Covered Professional Services.
CMS proposes extending the Shared Savings Program’s quality and financial EUC policies to include ACOs impacted by cyberattacks, such as ransomware or malware, starting in performance year 2025 and beyond.
Within the APP Plus measure set, CMS proposes removing Screening for Social Drivers of Health (Quality ID 487) if finalized for removal from the broader MIPS inventory.
Starting in performance year 2027, Shared Savings Program ACOs must use a web-mail-phone approach for the CAHPS for MIPS Survey, replacing the current mail-phone method to improve response rates.
Why CMS Proposals 2026 Matter for QPP Participants
The 2026 QPP changes represent a mature program finding its footing after years of rapid evolution. The emphasis on stability provides an excellent opportunity for practices and ACOs to consolidate quality reporting strategies and invest in sustainable infrastructure improvements.
For ACOs under MSSP, continued emphasis on the APP Plus measure set creates predictable reporting requirements that align with broader CMS quality initiatives. For practices participating in Traditional MIPS and MVPs, stable performance thresholds create an environment where organizations can focus on long-term strategic planning rather than reactive compliance.
The expansion of MVPs to six additional specialties demonstrates CMS’s commitment to clinically relevant quality measurement. These specialty-specific pathways allow targeted quality improvement efforts.
Looking Ahead: Strategic Preparation
The 2026 QPP changes signal program maturity and strategic focus. CMS’s emphasis on stability creates opportunities for practices and ACOs to strengthen quality foundations and prepare for future innovations.
Early adaptation allows organizations to enhance care delivery, optimize reporting efficiency, and achieve better financial outcomes. Use this stability period to build robust quality reporting capabilities.
The above blog post contains research and contextual conclusions provided by Ranu Ray, CMS Research Business Analyst.
This article was originally published on the MRO blog and is republished here with permission.