CMS proposes to end traditional MIPS reporting after the 2028 performance period, so from 2029 every clinician outside the APM Performance Pathway would report through one of 30 MIPS Value Pathways (MVPs). The proposal keeps the performance threshold at 75 points and the payment adjustment range at -9.0% to +9.0%.
CMS published the rule (CMS-1848-P) in the Federal Register on July 16, 2026, at 91 FR 43842. The 60-day comment period closed on September 14, 2026. The figures below come from HFMA's summary of the Quality Payment Program section and from ASCRS's July 15, 2026 rule summary.
When traditional MIPS reporting would end
CMS would keep traditional MIPS open beside MVPs through the 2028 performance period, which pays out in 2030. By then clinicians will have had six years of voluntary MVP reporting, which began with the 2023 performance period. Starting with the 2029 performance period (2031 payment year), clinicians who do not report through the APM Performance Pathway must pick an MVP.
The portfolio has 27 MVPs today. CMS proposes three more: diabetic disease, hypertension and hospitalist. CMS says the 30 MVPs would cover 98.0% of specialties, based on the specialty clinicians report for themselves. Virtual groups could report MVPs from the same 2029 start date.
The APM Performance Pathway weights stay different from MIPS. It counts quality at 50.0%, improvement activities at 20.0% and promoting interoperability at 30.0%, with cost at 0.0%.
| Item | Proposed figure |
|---|---|
| Last performance period with traditional MIPS | 2028 (2030 payment year) |
| MVPs required for non-APM clinicians | 2029 performance period (2031 payment year) |
| MVPs today / proposed additions | 27 / 3 |
| Specialty coverage of the 30 MVPs | 98.0% |
| Comment period | 60 days, closed September 14, 2026 |
Source: HFMA, CY 2027 Physician Fee Schedule Proposed Rule Summary Part III, August 2026.
Quality category: 180 measures and a core measure rule
For the 2027 performance period, CMS proposes an inventory of 180 quality measures. Of these, 177 are open to traditional MIPS and 3 are for MVPs only. The proposal removes 20 measures, adds 10 for 2027 and one more for 2028, and makes 43 substantive changes to existing measures.
The rule also swaps the current requirement to report one outcome or high priority measure for a requirement to report one MIPS core measure. ASCRS lists five core measures: Q012, Q141, Q304, Q385 and Q501. A clinician who has no applicable core measure can attest to that instead.
Traditional MIPS scores the best six measures, and an MVP scores the best four. A clinician who skips the core measure without an attestation gets zero achievement points on one quality measure. Small practices are exempt from the core measure rule. The quality data completeness threshold stays at 75.0% for 2027 and 2028, according to ASCRS.
The cost category carries 35 measures for the 2026 performance period, 33 episode-based and 2 population-based. CMS proposes no new cost measures and no removals. It updates only the codes behind the care episodes.
Promoting interoperability and improvement activities
Promoting interoperability is 25.0% of the MIPS score. For the 2027 performance period, CMS proposes to remove the security risk analysis measure. It would also make the electronic prior authorization measure optional for 2027, worth 10 bonus points, and required again from the 2028 performance period.
The current optional bonus is 5 points. It applies when a practice reports one or more of four public health measures: syndromic surveillance, public health registry, clinical data registry, and public health reporting through TEFCA. The 10-point electronic prior authorization bonus is for the 2027 performance period only.
Improvement activities are 15.0% of the score. CMS proposes to add 6 activities, modify 5 and remove 11. The six additions fall under care coordination and under advancing health and wellness.
CMS also asks for comment on FHIR-based digital quality reporting. For MSSP ACOs, it describes a two-year transition that begins with the 2028 performance period. Reporting through FHIR would be required by the 2030 performance period for measures that have FHIR specifications.
What CMS projects for payment adjustments
The category weights stay at 30.0% quality, 30.0% cost, 15.0% improvement activities and 25.0% promoting interoperability. CMS holds the 75-point threshold through the 2028 performance periods, so practices have a fixed target for the next three years of scoring.
MIPS must be budget neutral. CMS projects that adjustments redistribute about $332 million under the baseline model and about $330 million under the proposed policies. For the 2027 payment year, CMS estimates a median positive adjustment of 0.83% and a median negative adjustment of -2.62%.
| Projection for the 2027 payment year | Baseline model | Proposed policies |
|---|---|---|
| Clinicians with a positive adjustment | 84.6% | 86.6% |
| Clinicians with a negative adjustment | 9.9% | 8.0% |
| Dollars redistributed | $332 million | $330 million |
Source: HFMA, CY 2027 Physician Fee Schedule Proposed Rule Summary Part III, August 2026. Percentages are shares of MIPS-eligible clinicians in CMS's model.
The APM track and conversion factors
Qualifying APM participants received a lump-sum incentive of 1.88% of estimated covered professional charges for the 2026 payment year. No incentive is available for the 2027 payment year. For the 2028 payment year the incentive is 3.1%.
The thresholds to qualify rise for the 2027 QP performance period (2029 payment year). The payment amount method moves from 50.0% to 75.0%, and the patient count method moves from 35.0% to 50.0%. CMS estimates that between 517,800 and 530,900 eligible clinicians will become qualifying participants for the 2026 QP performance period, and they would be excluded from MIPS.
The proposed conversion factor update is +0.75% for qualifying APM participants and +0.25% for everyone else, according to ASCRS. A budget neutrality adjustment adds 0.53%. The expiry of the one-year 2.5% increase from 2026 subtracts 2.5%.
Sources
- HFMA, CY 2027 Physician Fee Schedule Proposed Rule Summary Part III: Quality Payment Program, August 2026
- ASCRS, 2027 Medicare Physician Fee Schedule Proposed Rule Released, July 15, 2026
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