2026 MIPS Updates: What You Need to Know
Are you up to speed on 2026 MIPS rules and requirements?
The Centers for Medicare and Medicaid Services (CMS) has released their 2026 Final Rule with updates to their Quality Payment Program (QPP) Merit-based Incentive Payment System (MIPS) program. Familiarizing yourself with these 2026 MIPS updates now could help you stay on top of your progress and prepare you for reporting your practice’s performance this year.
The MIPS categories — Quality, Cost, Promoting Interoperability, and Improvement Activities — remain the same this year, but each of the categories has updates that were issued in the 2026 CMS MIPS Final Rule.
Here, we’ll review some of the basic rules and this year’s key changes that may impact you.
2026 MIPS and MVPs: The basics
What score do I need to get to avoid a penalty?
You must submit a score of at least 75 out of 100 points in order to avoid a penalty of up to 9% on your 2028 Medicare reimbursements.
Can I get a positive adjustment on my reimbursements?
If you score 75 or above, you may be eligible for a positive payment adjustment on your 2028 Medicare reimbursements. The amount paid out will be scaled to meet budget neutrality.
Do I need to register for MVP reporting?
MIPS Value Pathway (MVP) reporting is not mandatory, but if you choose to report an MVP, you’ll need to register with CMS to do so. MVP registration opens April 1, but be sure to keep an eye on the CMS website for official registration deadlines. If your group plans to administer the CAHPS for MIPS Survey for the 2026 performance period, you must register between April 1 and June 30, 2026.
What is the weight of each MIPS category?
The weight of each 2026 MIPS category is as follows:
- Quality: 30%
- Cost: 30%
- Promoting Interoperability: 25%
- Improvement Activities: 15%
Take the time to prepare your practice for upcoming changes now. ModMed users can sign up for our MIPS Advisory Services to get extra MIPS support.
What’s new this year with MVPs?
MVPs are a predetermined subset of measures and activities related to a specialty or medical condition. It’s important to understand MVPs, since CMS plans to sunset traditional MIPS in the future and make reporting MVPs mandatory for nearly all participants.
For the 2026 performance year, CMS has added six new and modified 21 existing MVPs for a total of 27 available MVPs in 2026.
NEW MVPs for the 2026 performance year
- Diagnostic Radiology
- Interventional Radiology
- Neuropsychology
- Pathology
- Podiatry
- Vascular Surgery
In the 2026 performance period, ModMed plans to support the new podiatry and urology MVP within our EMA® EHR, in addition to continuing support for the dermatology, ophthalmology, orthopedics, and ENT MVPs. gGastro® users can report the gastroenterology care MVP. As additional measures are finalized, our teams will assess them and make them available in EMA and gGastro, when appropriate.
To see the full list of available MVPs in 2026, download the 2026 Finalized MVPs Guide.
What are the rules for MVP group registration?
Starting in the 2026 performance year, groups will now attest to their specialty composition (i.e., whether they are a single specialty group or a multispecialty group that meets the requirements of a small practice) during the MVP registration process. In previous years, CMS determined this on their behalf.
How should I register my multispecialty group?
In the 2026 MIPS Final Rule, CMS added an exception for multispecialty group registration. Starting this year, multispecialty groups that meet the requirements of a small practice (i.e., practices that have 15 or fewer clinicians) can report as a subgroup, if preferred, or as a group.
What are the 2026 changes for each MIPS category?
Quality performance category
Here’s what you need to know about the Quality performance category for the 2026 reporting year, including updated measures, submission requirements, and more.
NEW + UPDATED quality measures
CMS added five new measures, removed 10, and updated 30 existing measures — for a total of 190 quality measures for the 2026 performance period.
NEW quality measures
- Q512: Prevalent Standardized Kidney Transplant Waitlist Ratio (PSWR)
- Q513: Patient Reported Falls and Plan of Care
- Q514: Diagnostic Delay of Venous Thromboembolism in Primary Care
- Q515: Screening for Abnormal Glucose Metabolism in Patients at Risk of Developing Diabetes
- Q516: Hepatitis C Virus (HCV): Sustained Virological Response (SVR)
REMOVED quality measures
CMS announced the removal of quality measure Q508: Adult COVID-19 Vaccination Status, along with nine other measures, for the 2026 performance period. For a full list of the new, updated, and removed quality measures and their descriptions, download the 2026 Final Rule fact sheet.
NEW measures qualifying for topped-out measure benchmarking
For the 2026 year, CMS has identified 19 quality measures that will receive topped-out measure benchmarks. Previously, CMS announced a new method of benchmarking to apply to a subset of topped-out measures — measures that belong to specialty sets and MVPs with limited measure choice and a high proportion of topped-out measures, in areas that lack measure development.
Refer to the CMS fact sheet for a more detailed explanation of the topped-out benchmarking policy and the full list of these measures available in 2026.
UPDATED list of high-priority quality measures
This year, CMS has removed health equity measures from its list of high-priority measures. A high-priority measure is now defined as an outcome (including intermediate outcome and patient-reported outcome), appropriate use, patient safety, efficiency, patient experience, care coordination, or opioid quality measure.
You can find more information about the 2026 quality measures, submission policies, benchmarking, and scoring details here.
Cost performance category
Here’s what you need to know about the Cost performance category for the 2026 reporting year.
UPDATED TPCC measure
There are 35 cost measures for the 2026 performance period. CMS did not add or remove any cost measures this year, but they modified the Total Per Capita Cost (TPCC) measure.
What is the TPCC measure?
TPCC is a population-based cost measure that assesses the overall cost of care delivered to a patient with a focus on the primary care they receive from their providers. This year, CMS modified the TPCC measure candidate event and attribution criteria to:
- Exclude any candidate events initiated by an advanced care practitioner Taxpayer Identification Number-National Provider Identifier (TIN-NPI) if all other non-advanced care practitioner TIN-NPIs in their group are excluded based on the specialty exclusion criteria.
- Require the second service used to initiate a second candidate event to be an E/M service or other related primary care service provided within 90 days of the initial candidate event service by a TIN-NPI within the same TIN
- Require the second service used to initiate a candidate event be provided by a TIN-NPI that has not been excluded from the measure based on specialty exclusion criteria.
Review the full description of the TPCC measure and this modification on the CMS website.
New informational-only feedback policy
CMS announced a new two-year informational-only feedback policy for all new cost measures, beginning with the 2026 performance period. There are no new cost measures this year, but in future years, when new cost measures are announced, MIPS eligible clinicians, groups, virtual groups, and subgroups will receive informational-only scoring feedback on any new cost measure or measures for the first two years. The new measure will begin contributing to their final score starting the third year it’s available.
Improvement Activities performance category
Here’s a breakdown of the new and updated improvement activities and submission requirements for reporting the Improvement Activities (IA) performance category in 2026.
NEW + UPDATED improvement activities
CMS has added three new improvement activities, removed eight, and modified seven, for a total of 104 available activities for the 2026 performance period.
NEW 2026 improvement activities
- Improving Detection of Cognitive Impairment in Primary Care
- Integrating Oral Health Care in Primary Care
- Patient Safety in Use of Artificial Intelligence (AI)
REMOVED improvement activities
- MIPS Eligible Clinician Leadership in Clinical Trials or CBPR
- Create and Implement an Anti-Racism Plan
- Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols
- Create and Implement a Plan to Improve Care for Lesbian, Gay, Bisexual, Transgender, and Queer Patients
- Practice Improvements that Engage Community Resources to Address Drivers of Health
- Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B
- Use of Toolsets or Other Resources to Close Health and Health Care Inequities Across Communities
- COVID-19 Clinical Data Reporting with or without Clinical Trial
Additionally, CMS has replaced the Achieving Health Equity (AHE) subcategory for improvement activities with the new Advancing Health and Wellness (AHW) subcategory.
Activity submission requirements and weighting policy
All IA submissions must include a “yes” response for at least one improvement activity to be eligible for scoring. Any IA submissions that do not include the “yes” response for at least one activity will be marked null and will not be scored.
To satisfy the IA category for the 2026 performance year, participants must report as follows:
- MVPs: required to report one activity
- MIPS small practices: required to report one activity
- MIPS large practices: required to report two activities
There is no weighting applied to improvement activities — all activities are worth equal point values.
Promoting Interoperability performance category
CMS announced updates to the Promoting Interoperability (PI) performance category for the 2026 MIPS reporting year.
NEW modification to the Protect Patient Health Information Objective, Security Risk Analysis measure
Previously:
MIPS participants were required to attest “yes” or “no” to having conducted or reviewed a security risk analysis in accordance with the HIPAA Security Rule.
New in 2026:
In addition to the above required attestation, MIPS participants will also be required to attest “yes” or “no” to having conducted security risk management as required under the risk management component of the HIPAA Security Rule.
A “no” attestation to this measure will result in a total score of zero points for the PI performance category.
NEW High Priority Practices SAFER Guide measure
In 2026, MIPS participants will attest “yes” or “no” to completing an annual self-assessment using the High Priority Practices Guide within the 2025 SAFER Guides, rather than the 2016 SAFER Guides required in previous years.
A “no” response will result in a total score of zero points for the PI performance category.
NEW optional bonus measure
This year, CMS added a new optional bonus measure, the Public Health Reporting Using TEFCA measure, under the Public Health and Clinical Data Exchange objective, bringing the total available bonus measures to four.
Bonus measures available in 2026:
- Syndromic Surveillance Reporting
- Public Health Registry Reporting
- Clinical Data Registry Reporting
- Public Health Reporting Using TEFCA
These measures are entirely optional, and participants can receive up to five maximum bonus points to their PI score by reporting one, more than one, or all of the optional bonus measures.
NEW measure suppression policy
CMS announced a new PI measure suppression policy, allowing for certain measures to be suppressed if they meet certain criteria.
It’s important to note that if CMS suppresses a measure, you will still be required to report that measure, but it will no longer be assessed and scored based on performance. Instead, a simple “yes” attestation will be required to receive maximum points or full credit for that measure.
If you plan on taking the Automatic Small Practice Hardship (SPH) and/or the Extreme and Uncontrollable Circumstances Exception (EUCE), don’t submit ANY data under the PI category. Any data submission, even scores of zero, will trigger CMS to score you in the PI category.
Since CMS requires a 180-day minimum PI performance period, the final date you can begin your 2026 PI performance period will be July 5, 2026.
ModMed’s EMA and gGastro EHRs meet the necessary ONC certification criteria required for submitting PI data for the 2026 performance year.
Managing change
ModMed offers a range of solutions and resources that can help make these MIPS changes easier for your practice:
- Our award-winning1, ONC-certified EMA EHR records your MIPS measures as you document and offers a built-in, easy-to-read scorecard with your estimated MIPS performance.2
- ModMed users can submit their MIPS data directly to CMS through the Modernizing Medicine Qualified Registry. We also offer interfaces with several third-party registries for seamless data transfer, including Patient360, Healthmonix, IRIS, DataDerm, AQUA, RegistryClearinghouse, Reg-ent, GIQuIC, and a number of academy registries.
- Get personalized guidance from our team of Certified MIPS Health Professionals (CMHPs) who can help you track your progress and meet your 2026 MIPS goals. Discover what our MIPS Advising Services for EMA and gGastro have to offer.
Find out how ModMed solutions can help you navigate MIPS in 2026
For more information on all the MIPS and MVP updates announced in the 2026 Quality Payment Program Final Rule, download the 2026 QPP Final Rule Fact Sheet and the 2026 Finalized MVPs Guide.
1 2026 Black Book™
2 Subject to satisfaction of data completeness and similar requirements.
This blog is intended for informational purposes only and does not constitute legal or medical advice. Please consult with your legal counsel and other qualified advisors to ensure compliance with applicable laws, regulations, and standards.
