While we were waiting on CMS to issue the fiscal year 2026 IPPS Final Rule, they’ve given us the 2026 MIPS Proposed Rule. Not exactly beach reading for your summer vacation, so we’ve digested it here.
Overall, the MIPS proposed rule reflects CMS’ stated goals:
- Alignment (e.g., CEHRT requirements align with ONC),
- Stability (no major changes), and
- Feedback (CMS is requesting your input).
In other words, “Steady as She Goes.”
The proposed 2026 Medicare Physician Fee Schedule (PFS) rule maintains the 75-point performance threshold for MIPS. It also proposes:
- A new mandatory payment model for heart failure and low back pain
- Expanded telehealth flexibilities
Here’s the URL if you want to dive into those proposals.
This blog will focus specifically on MIPS and CQM reporting changes.
Proposed New Quality Measures
Removed Quality Measures:
No eCQMs are slated for removal. Just MIPS CQMS:
- 185 Colonoscopy Interval for Patients with a History of Adenomatous Polyps – Avoidance of Inappropriate Use
- 264 Sentinel Lymph Node Biopsy for Invasive Breast Cancer
- 290 Assessment of Mood Disorders and Psychosis for Patients with Parkinson’s Disease
- 322 Cardiac Stress Imaging Not Meeting Appropriate Use Criteria: Preoperative Evaluation in Low-Risk Surgery Patients
- 419 Overuse of Imaging for the Evaluation of Primary Headache
- 424 Perioperative Temperature Management
- 443 Non-Recommended Cervical Cancer Screening in Adolescent Females
- 487 Screening for Social Drivers of Health
- 498 Connection to Community Service Provider
- 508 Adult COVID-19 Vaccination Status
Cost Measures
New cost measures will be introduced, but with a two-year “information-only feedback period” before they affect performance scores. This gives clinicians time to evaluate their score(s) and make performance improvements before a new cost measure affects their MIPS score (and reimbursement!).
MVP Rollout
CMS proposes updates to all 21 existing MVPs and introduces 6 new MVPs for 2026:
- Diagnostic Radiology
- Interventional Radiology
- Neuropsychology
- Pathology
- Podiatry
- Vascular Surgery
Additionally:
- Practices will self-attest to their specialty composition (single specialty or multispeciality group that meets small practice requirements) during MVP registration.
- Multispeciality small practices can report an MVP as a group
- Subgroup reporting remains optional in 2026
Promoting Interoperability
MIPS 2025 change:
Since the CDC is the main clearinghouse for Electronic Case Reporting (eCR) and they have paused clinician onboarding, CMS is removing the eCR requirement for 2025 MIPS. eCR reporting was previously required for all clinicians not in ACOs or qualifying for an exemption.
2026 Proposed Changes:
- Security Risk Analysis measure will require an additional attestation confirming that clinicians conducted risk management activities, as outlined under the HIPAA Security Rule.
- SAFER Guide: Clinicians must use the updated 2025 Safety Assurance Factors for EHR Resilience (SAFER) Guide in place of the 2016 version for their self-assessments under the High Priority Practices measure.
- A new bonus measure has been added to promote interoperability, providing for public health data exchange using the Trusted Exchange Framework and Common Agreement (TEFCA).
How Dynamic Health IT Can Help
If you’ve made it to the end of this blog, you know that MIPS (and especially CQM reporting) is always a moving target. Partner with DHIT to transform your CQM reporting from a complex burden into a painless process.
