2026 MIPS Guide
MIPS (Merit-based Incentive Payment System) is one of two ways Medicare Part B clinicians participate in the Quality Payment Program (QPP), created under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). Each year, eligible clinicians choose one of three participation tracks:
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- Traditional MIPS — report individually or as a group across four performance categories
- MIPS Value Pathways (MVPs) — a streamlined, specialty-aligned reporting option CMS is actively expanding (21 MVPs are available for the 2026 performance year)
- Advanced Alternative Payment Models (APMs) — an alternate track for clinicians in qualifying value-based payment arrangements
Who Is a MIPS-Eligible Clinician in 2026?
You’re required to report MIPS if you bill Medicare Part B and exceed all three elements of the Low-Volume Threshold (LVT) in both 12-month segments CMS uses to determine eligibility:
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- More than $90,000 in Medicare Part B allowed charges for covered professional services, and
- More than 200 Medicare Part B beneficiaries, and
- More than 200 covered professional services billed to Medicare Part B
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- Submit measure and activity data for the Quality, Improvement Activities, and Promoting Interoperability categories (CMS calculates your Cost score automatically from claims — no submission needed)
- Your combined performance produces a Final Score from 0–100
- That score determines a positive, neutral, or negative payment adjustment, applied two years later to your Medicare Part B reimbursements.
What Is MIPS in Healthcare?
MIPS (Merit-based Incentive Payment System) is the CMS program that determines Medicare Part B payment adjustments for eligible clinicians based on a composite performance score across four categories: Quality, Cost, Improvement Activities, and Promoting Interoperability. Depending on that score, a clinician or group receives a payment bonus, a payment penalty, or no adjustment at all.
Because scoring rules, measure sets, and benchmarks change every performance year, and because eligibility and Mips reporting decisions carry real financial and reputational stakes for a practice, many groups choose to work with a MIPS consultant to manage measure selection, data submission, and score optimization rather than navigate it alone.
Traditional MIPS Performance Threshold
Traditional MIPS is the original reporting framework of the Merit-based Incentive Payment System, scoring clinicians and groups across all four MIPS categories (Quality, Improvement Activities, Promoting Interoperability, and Cost).
CMS has locked the MIPS performance threshold at 75 points through the 2028 performance year, providing rare multi-year stability after several years of annual increases. To avoid a negative payment adjustment, clinicians and groups reporting Traditional MIPS in 2026 must score at least 75 points — the same threshold that applied in 2022, 2023, 2024, and 2025.
There is no additional “exceptional performance” bonus available (that bonus pool was retired after the 2022 performance year), so every point above 75 now maps directly to a proportionally larger positive adjustment on a linear sliding scale — meaning score optimization matters more, not less, even with a stable threshold.
MIPS Payment Adjustment Scale (Current Rules, Stable Through 2028)
| Final MIPS Score | Payment Adjustment | What It Means |
| 75.01 – 100 points | Positive adjustment, scaled up to the maximum (CMS estimates ~4.69% at a perfect 100 score) | You outperformed the threshold — reward scales with how far above 75 you land |
| 75 points | 0% (neutral) | You hit the threshold exactly — no bonus, no penalty |
| 18.76 – 74.99 points | Negative adjustment between 0% and -9%, scaled linearly | You missed the threshold — penalty scales with how far below 75 you land |
| 0 – 18.75 points | Maximum -9% penalty | You scored below one-quarter of the threshold — full penalty applies |
How Can You Report MIPS? Individual, Group, or Subgroup
Clinicians can report MIPS in one of three ways:
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- Individual — a single NPI tied to a single TIN, scored entirely on that clinician’s own performance
- Group — two or more clinicians sharing a TIN, where every eligible clinician under that TIN is included in one combined submission and every NPI in the group receives the same final score. A TIN cannot be split into multiple separate groups for reporting.
- Subgroup (new for the 2026 performance year) — available specifically for multispecialty groups reporting an MVP. Rather than registering the whole TIN as one group, a defined subset of clinicians within it can report together at the subgroup level.
MIPS 2026 Key Deadlines to Track
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- Ongoing: 2026 performance year data collection (Jan 1 – Dec 31, 2026)
- December 2026: CMS publishes final MIPS eligibility determinations for the year
- March 31, 2027: Final deadline to submit 2026 performance year data for Traditional MIPS
- 2028: Payment adjustments based on 2026 performance take effect
Traditional MIPS vs. MVPs vs. APM: Which Track Fits Your Practice?
| Traditional MIPS | MVPs | Advanced APM | |
| Measure selection | Choose freely across all 4 categories | Smaller, specialty-aligned bundle set by CMS | Determined by your APM model’s own requirements |
| Reporting burden | Highest — most flexibility, most work | Reduced — CMS narrows your choices | Varies by model, generally lowest MIPS-specific burden |
| Best fit for | Practices wanting full control over measure selection | Specialty practices wanting a simpler, pre-built pathway | Practices already in or eligible for a qualifying value-based payment arrangement |
| 2026 status | Available to all eligible clinicians | 21 MVPs available; multispecialty groups must register at the subgroup, individual, or APM Entity level (no longer as a full group) | Requires separate qualification through a CMS-approved APM |
2026 MIPS Reporting Performance Categories
MIPS Healthcare annually assigns a 100-point performance scale to eligible Medicare Part B clinicians, resulting in a Composite Performance Score. The Composite Performance Score, determined by the reported measures and categories, will serve as the foundation for the payment adjustment.
There are four scalable categories of MIPS,
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- Quality
- Promoting Interoperability
- Cost
- Improvement Activities
1. Quality Measure (30%)
For the 2026 performance year, CMS finalized 5 new quality measures, substantive changes to 30 existing measures, and the removal of several topped-out measures. Data completeness remains locked at 75% of eligible encounters through the 2028 performance period — the same requirement introduced for 2024–2025, now confirmed stable.
MIPS quality measure adjustments have also expanded the definition of “high priority measure” to include health equity-related measures.
For historical context, the 2023 performance period — the last major overhaul before the current measure set — included 198 total quality measures, comprising:
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- Changes to 76 existing quality indicators
- The addition of nine new quality measures (one a new administrative claim measure)
- 11 quality measures removed
- Additions/removals of quality measures across multiple specialty sets
| 2023 Quality Measure Changes (Historical Reference) | Collection Type |
| #485 Psoriasis – Improvement in Patient-Reported Itch Severity | MIPS Clinical Quality Measure (CQM) |
| #486 Dermatitis – Improvement in Patient-Reported Itch Severity | MIPS CQM |
| #487 Screening for Social Drivers of Health | MIPS CQM |
| #488 Kidney Health Evaluation | Electronic CQM (eCQM) and MIPS CQM |
| #489 Adult Kidney Disease: Angiotensin Converting Enzyme (ACE) Inhibitor or Angiotensin Receptor Blocker (ARB) Therapy | MIPS CQM |
| #490 Appropriate Intervention of Immune-Related Diarrhea and/or Colitis in Patients Treated with Immune Checkpoint Inhibitors | MIPS CQM |
| #491 Mismatch Repair (MMR) or Microsatellite Instability (MSI) Biomarker Testing Status in Colorectal Carcinoma, Endometrial, Gastroesophageal, or Small Bowel Carcinoma | MIPS CQM |
| #492 Risk-Standardized Acute Cardiovascular-Related Hospital Admission Rates for Patients with Heart Failure under the Merit-based Incentive Payment System | Administrative Claims* |
| #493 Adult Immunization Status | MIPS CQM |
| Quality Measures Removed from Traditional MIPS | Collection Type |
| #110: Preventive Care and Screening: Influenza Immunization | Medicare Part B Claims, eCQM, |
| #111: Pneumococcal Vaccination Status for Older Adults | Medicare Part B Claims, eCQM, MIPS CQM |
2. Promoting Interoperability (25%)
In order to improve the MIPS Healthcare interoperability Category, CMS is implementing several improvements.
2026 updates: CMS finalized a new measure suppression policy for Promoting Interoperability — when a measure is suppressed (as it did for electronic case reporting due to the CDC’s onboarding pause), you still must attest Yes/No/Excluded, but you automatically receive full credit. CMS also now requires practices to attest that Security Risk Assessment activities were conducted in accordance with the HIPAA Security Rule, and to use the updated 2025 edition of the High Priority Practices SAFER Guide.
The following changes have been made:
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- Requiring and updating the Query of Prescription Drug Monitoring Program (PDMP) measure in the Electronic Prescribing Objective.
- Extending the Query of PDMP measure to cover Schedule III and IV medications in addition to Schedule II opioids.
- Adding a new Health Information Exchange (HIE) Objective option, Enabling Exchange under the Trusted Exchange Framework and Common Agreement (TEFCA) measure (requiring a yes/no response), as an optional accomplish the goal.
- Consolidating the present choices for active involvement from three to two levels for the Public Health and Clinical Data Exchange Goal, and requiring active engagement reporting for the measurements under the objective.
- Continuing to reweight the PI category for some types of MIPS-qualified non-physician providers.
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- Nurse practitioners
- Clinical nurse specialist
- Physician assistants
- Certified registered nurse anesthetists
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- Physical therapists
- Qualified speech-language pathologists
- Qualified audiologists
- Clinical psychologists
- Occupational therapists
- Registered dietitians or nutrition professionals
| PI Objective | Measure | Maximum Points |
| Electronic Prescribing | e-Prescribing | 10 points |
| Query of PDMP | 10 points | |
| Health InformationExchange | Support Electronic Referral Loops by Sending Health Information | 15 points |
| Support Electronic Referral Loops by Receiving and Reconciling Health Information | 15 points | |
| OR | ||
| Health Information Exchange Bi-Directional Exchange* | 30 points | |
| OR | ||
| Participation in TEFCA | 30 points | |
| Provider to Patient Exchange | Provide Patients with Electronic Access to Their Health Information | 25 points |
| Public Health and Clinical Data Exchange | Report the following 2 measures:Immunization Registry ReportingElectronic Case Reporting | 25 points |
| Report one of the following measures:Syndromic Surveillance ReportingPublic Health Registry ReportingClinical Data Registry Reporting | 5 points (bonus) |
3. Cost Category (30%)
For the 2026 performance year, CMS maintains 35 cost measures, requiring no data submission — CMS calculates your score entirely from Medicare claims. Your performance on each measure is compared to a national benchmark and scored from 1–10 points; your Cost category score is the average across all measures for which you have enough attributed cases to be scored. MIPS Healthcare score calculation
A notable 2026 change: CMS updated the Total Per Capita Cost (TPCC) attribution methodology to stop attributing cost responsibility to specialty groups based solely on the billing of nurse practitioners, physician assistants, and clinical nurse specialists — a fix aimed at specialty practices that were being unfairly penalized under the prior rule.
If you don’t meet the minimum case threshold for a given cost measure, that measure simply isn’t scored — it won’t lower your Cost category average. If none of your measures meet the case minimum, CMS reweights Cost to 0% and redistributes that weight across the other three categories.
4. Improvement Activities (15%)
CMS continues to refine the Improvement Activities inventory each year. For the 2026 performance year, CMS added 3 new activities, modified 7 existing ones, and removed 8. Notably, CMS retired the “Achieving Health Equity” subcategory and replaced it with a new “Advancing Health and Wellness” subcategory — if you previously reported activities under the old category name, confirm your selected activities are still listed under the current inventory before attesting.
| 2023 Improvement Activity Changes (Historical Reference) | Retired Improvement Activities |
| IA_AHE_10 Adopt Certified Health Information Technology for Security Tags for Electronic Health Record Data (Medium) | IA_BE_7 Participation in a QCDR, that promotes the use of patient engagement tools |
| IA_AHE_11 Create and Implement a Plan to Improve Care for Lesbian, Gay, Bisexual, Transgender, and Queer Patients (High) | IA_BE_8 Participation in a QCDR, that promotes collaborative learning network opportunities that are interactive |
| IA_EPA_6 Create and Implement a Language Access Plan (High) | IA_PM_7 Use of QCDR for feedback reports that incorporate population health |
| IA_ERP_6 COVID-19 Vaccine Achievement for Practice Staff (Medium) | IA_PSPA_6 Consultation of the Prescription Drug Monitoring program |
| IA_PSPA_20 Leadership engagement in regular guidance and demonstrated commitment to implementing practice improvement changes | |
| IA_PSPA_30 PCI Bleeding Campaign |
Work With MIPS Consultants Who Know the 2026 Rules
Every performance year brings new measures, new thresholds, and new ways to lose points under the Merit-based Incentive Payment System that you didn’t know applied to you. NeoMD‘s MIPS consultants work across EHR and practice-management platforms to manage measure selection, data submission, and score optimization for the 2026 performance year and beyond — regardless of your specialty or reporting track (Traditional MIPS, MVPs, or APM).
What sets NeoMD MIPS reporting support apart:
NeoMD stood best among competitors’ revenue cycle management companies due to the following cores;
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- Our experts work hard to reduce your front-end denials by 20%.
- Claim first level acceptance ratio; 95-97%
- We have consistently increased the collection rate for our clients because of the faster increase in the accuracy of fees and collection.
- Refunds adjustment and Payment posting to improve the cash flow.
- Offer Medical Billing Services that are easily scalable at all times.
- Offer Provider & Staff Productivity Analysis
- Offering state-of-the-art medical billing services for small practices, medium-sized, and large ones.
- Offer internal Medical Billing audits to uncover loopholes
- Provide Fortnightly financial and performance reporting so you can course-correct mid-year, not after the deadline
- Deliver customized Revenue Cycle Management Services to unearth operation shortcomings.
- Provide in-depth MIPS Healthcare Reporting services that are of high quality and error-free.
