2026 MIPS Value Pathways: What You Need to Know
New value pathways and changes reflect an emphasis on streamlining healthcare management
The Centers for Medicare & Medicaid Services (CMS) revealed updates to the MIPS Value Pathways (MVPs) program as part of their finalized rules for 2026. The program launched in 2023 and was designed to help break down silos and build alignment across performance category scores and reporting.
What are MIPS Value Pathways?
MIPS Value Pathways (MVPs) are updated sets of measures and activities that physicians and clinics can follow to satisfy MIPS reporting requirements.
Here is some key information regarding the MVPs program:
- Like MIPS, MVPs include four performance categories: Quality, Cost, Promoting Interoperability, and Improvement Activities.
- Quality and Improvement Activity measures are scored at the MVP level, meaning your practice would choose measures from a CMS list related to your value pathway.
- The Promoting Interoperability category is specialty-agnostic.
- Population health measures are also part of a foundational, specialty-agnostic layer. For the 2026 reporting year, CMS will assign the highest-scoring population health measure available for each MVP participant, if applicable.
- Multispecialty groups that aren’t small practices are required to report as subgroups or individuals in 2026.
These changes are intended to contribute to a larger evolution in approach. Under MVPs, quality measures must be reported in relation to cost and improvement measures. This is designed to help ensure scoring represents a meaningful and cohesive picture of a clinic’s performance.
Are MIPS Value Pathways required?
Although MVP participation is optional at this time, it’s important to familiarize yourself with it. Starting in 2026, multispecialty groups (that aren’t small practices) intending to report MVPs will be required to report as subgroups or individuals. CMS plans to sunset traditional MIPS through future rulemaking, at which point MVPs will become mandatory unless the clinician is eligible to report the Alternative Payment Model (APM) Performance Pathway (APP).
Once the transition to MVPs is complete, practices may experience a shift in how they collect, track, and report their performance data. CMS recommends early adoption of MVP reporting so this future change doesn’t cause disruptions to your practice workflow.
How to report for MVPs
If you choose to report for an MVP, you will be required to register with CMS. The registration window for performance year 2026 will open on April 1, 2026, but be sure to keep an eye on the CMS website for official registration deadlines. If your group would like to administer the CAHPS for MIPS Survey for the 2026 performance period, you must register between April 1 and June 30, 2026.
Reporting requirements include the same four performance categories that MIPS has always included, plus a foundational layer that includes population health measures.
With MVPs, you’ll likely have fewer measures to report, and all MVPs are designed with a specific specialty or medical condition in mind. For example, orthopedic providers who report the Improving Care for Lower Extremity Joint Repair MVP must attest to four of the seven available quality measures (at least one must be an outcome measure) and at least one of 10 improvement activity (IA) measures. CMS uses administrative claims data to calculate performance in the Cost category. It will calculate all available population health measures for an MVP participant and apply the highest-scoring measure to their Quality category score.
Read on to get an overview of how MVPs may impact your practice and how you can prepare for the future of value-based care today.
The evolution of MIPS Value Pathways
MIPS was created to shift incentives away from fee-for-service payment models toward higher-quality care at lower costs.
Within the MVP framework, CMS intends to create tighter alignment between measures and activities for different specialties or conditions. By considering population health and interoperability as foundational to the evolution of healthcare, MVPs may be able to promote the objectives of the industry as a whole while ensuring the differences in specialty-specific care don’t slip through the cracks.
The focus on specialty-specific priorities and workflows within our EMA® and gGastro® EHRs can assist with data collection and create other efficiencies:
- Purpose-built workflows may speed up documentation with fewer clicks and taps for providers, helping to support accuracy and return physician focus to the patient.
- Automation helps streamline downstream tasks and promote consistency of data across workflows.
- Built-in traditional MIPS reporting alongside MVPs facilitates an all-inclusive view of submission options.
- Data collection presented in intuitive dashboards helps assist with tracking MVP scores for Quality, Promoting Interoperability, and Improvement Activities performance categories.
New value pathways
For the 2026 performance year, CMS has added six new MVPs and modified 21 existing MVPs.
New MVPs
- 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 EMA EHR. gGastro users can report the gastroenterology care MVP. As additional measures are finalized, our teams will assess them and make them available in our EMA and gGastro EHRs, when appropriate.
Modified 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
If you’re interested in helping CMS shape the future state of MIPS, they have also created guidelines to develop candidates for new value pathways. These guidelines mirror the components of current MVPs.
Quality performance category
CMS has issued the following important requirements for the Quality category for the 2026 performance year:
- Select and submit four quality measures.
- At least one measure must be an outcome measure, or a high-priority measure if an outcome measure is unavailable or not applicable. This can include an outcome measure calculated by CMS through administrative claims, if available in the MVP.
The higher of the two available population health measures will be calculated for you and assigned to your quality score by CMS based on administrative claims data.
Improvement Activities performance category
CMS has issued the following important requirements for the Improvement Activities category for the 2026 performance year:
- Clinicians, groups, and subgroups, regardless of special status, must attest to one activity.
- Clinicians may still choose to report IA_PCMH.
Promoting Interoperability performance category
CMS has issued the following important requirements for the Promoting Interoperability category for the 2026 performance year:
- You must submit the same Promoting Interoperability measures required under traditional MIPS, unless you qualify for reweighting. Find out if you qualify for reweighting here.
- CMS finalized suppression of PI_PHCDRR_3: Electronic Case Reporting for the CY 2025 performance period. Attestation is still required.
- CMS modified PI_PPHI_1: Security Risk Analysis and PI_PPHI_2: High Priority Practices Guide of the Safety Assurance Factors for EHR Resilience (SAFER) Guides measures.
- CMS introduced a new optional bonus measure under the Public Health and Clinical Data Exchange Objective, PI_PHCDRR_6: Public Health Reporting Using Trusted Exchange Framework and Common Agreement (TEFCA).
For further clarification on the Promoting Interoperability category modifications in effect for 2026, refer to the final rule published via the Federal Register.
Cost performance category
CMS has issued the following important requirements for the Cost category for the 2026 performance year:
- CMS calculates performance exclusively on the cost measures included in the MVP using administrative claims data.
- CMS finalized a two-year informational-only feedback period for new cost measures, allowing clinicians to receive feedback on their scores and find opportunities to improve performance before a new cost measure affects their MIPS final score.
- CMS finalized updates to the Total Per Capita Cost (TPCC) measure.
Preparing for MIPS Value Pathways
Physicians who underwent the transition to MIPS processes may recognize the value of preparing for MVPs now. Any change in rules and reporting may present a challenge to your business and its bottom line. With advanced preparation, you may be able to mitigate the risks of transitioning to new value pathways and maintain continuity in your practice’s day-to-day operations. We offer additional regulatory and compliance resources, such as webinars and guides, as well as helpful articles for current ModMed clients in our ModMed Communities platform.
If you need additional MIPS support, we encourage our clients to take advantage of our MIPS advising. With our MIPS Advisory Services for EMA and gGastro clients, you’ll get a MIPS Advisor who knows both your EHR and your practice. They’ll monitor your performance and work with you to achieve your goals.
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.
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