2026 Medicare Physician Fee Schedule Proposed Rule

CMS recently published the CY 2026 Physician Fee Schedule (PFS) Proposed Rule which included proposals for the Quality Payment Program (QPP). CMS proposed updates to MIPS Value Pathways (MVPs) and Merit-based Incentive Payment System (MIPS). For the full text of the rule, see the Federal Register.

Physician Fee Schedule (PFS) Proposed Rule which included proposals for the Quality Payment Program (QPP)

MIPS Value Pathways (MVPs)

CMS continues to transform MIPS through MVPs. Beginning with the 2026 performance year, CMS has proposed 6 new MVPs, along with modifying the 21 previously finalized MVPs.

The 6 newly proposed MVPs are:

• Diagnostic Radiology
• Interventional Radiology
• Neuropsychology
• Pathology
• Podiatry
• Vascular Surgery

CMS is proposing that beginning with 2026 performance year, groups would attest to their specialty composition (whether they’re a single specialty or multispecialty group that meets the definition of a small practice) during the MVP registration process. This eliminates CMS making the determination for them. CMS is also proposing that multispecialty groups that are small practices (15 or fewer clinicians) would be able to register to report an MVP as a group and would not be required to register as subgroups if they did not want to report as individuals. In other words, beginning with 2026 performance period, an MVP participant would be defined as an individual MIPS eligible clinician, a single-specialty group, a multispecialty group that meets the requirements of a small practice, a subgroup or an APM entity.

Traditional MIPS

For 2026 MIPS reporting, the MIPS score will continue to be based on the four performance categories and their corresponding weights. CMS is proposing to continue using a performance threshold of 75 points through the CY 2028 performance period/2030 MIPS payment year.

Quality

For the 2026 performance period, CMS is proposing changes to the quality measures inventory resulting in a total of 190 quality measures (this does not include QCDR measures which are approved outside of the rulemaking process).

• Addition of 5 quality measures, including 2 eCQMs
• Removal of 10 quality measures
• Substantive changes to 32 existing quality measures

CMS is proposing that 19 quality measures receive topped out measure benchmarks for the CY 2026 performance period. The one eCQM this would apply to is CMS157 Oncology: Medical and Radiation – Pain Intensity Quantified. For topped out measures, the following benchmarks are applied:

For the administrative claims-based quality measures, CMS is proposing to update the benchmarking methodology to align with the benchmarking methodology for cost measures beginning with the CY 2025 performance period/2027 MIPS payment year. The median performance rate for a measure would be set at a score derived from the performance threshold. In prior years, administrative claims-based quality measures were scored against performance period benchmarks.

Cost

CMS is not proposing any changes to the cost measure inventory for the CY 2026 performance period. However, CMS is proposing to modify the Total Per Capita Cost (TPCC) measure, specifically its candidate event and attribution criteria.

CMS is also proposing that beginning with the CY 2026 performance period, new cost measures will have a 2-year informational-only feedback period. During this 2-year informational-only feedback period, MIPS eligible clinicians, groups, virtual groups and subgroups would receive feedback on the new cost measure(s) but it would not contribute to their score.

Improvement Activities

For CY 2026 performance year, CMS is proposing to add 3 new improvement activities, modify 7 existing improvement activities and remove 8 existing improvement activities. CMS is also proposing to remove the Achieving Health Equity (AHE) subcategory for improvement activities and replace it with Advancing Health and Wellness (AHW) subcategory to replace it.

Promoting Interoperability

Beginning with CY 2026, CMS proposed modifications to the Security Risk Analysis measure and the SAFER Guides measure.

For the Security Risk Analysis measure, CMS proposes requiring MIPS eligible clinicians to attest “yes” to having conducted security risk management in addition to the existing measure requirement to attest “yes” to having conducted security risk analysis. Under the proposed modified measure, MIPS eligible clinicians would be required to attest that they have implemented policies and procedures to assess and manage security risks to electronic protected health information (ePHI) related to the use of EHRs, in accordance with the HIPAA Security Rule’s risk analysis and risk management requirements.

For the SAFER Guides measure, CMS proposes requiring MIPS eligible clinicians to attest “yes” to completing an annual self-assessment of the High Priority Practices SAFER Guide published in January 2025.

Beginning with the CY 2026 EHR reporting period, CMS is proposing adding an optional bonus measure to the Public Health and Clinical Data Exchange objective for MIPS eligible clinicians that submit health information to a public health agency (PHA) using the Trusted Exchange Framework and Common Agreement (TEFCA). Under this proposal, a MIPS eligible clinician would be able to earn 5 bonus points under the Public Health and Clinical Data Exchange objective if they attested that they are in active engagement Option 2 (Validated Data Production) with a PHA to submit electronic production data for one or more of the measures under the Public Health and Clinical Data Exchange objective using TEFCA. To attest “yes” for the Public Health Reporting Using TEFCA optional bonus measure, MIPS eligible clinicians must be a signatory to a TEFCA Framework Agreement.

CMS is proposing to adopt a measure suppression policy for the MIPS PI performance category and the Medicare PI Program. For CY 2025/2027 MIPS payment year and for the CY 2025 EHR reporting, CMS is proposing to suppress the Electronic Case Reporting measure for the MIPS PI performance category and the Medicare PI Program for eligible hospitals and CAHs due to CDC’s temporarily pausing the onboarding of healthcare organizations for production of eCR data. However, MIPS eligible clinicians, eligible hospitals and CAHs would still be required to report the eCR measure, in which they would attest “Yes” or “No” as well as the level of active engagement or claim an applicable exclusion, but the measure would not be scored. If this proposal is finalized as proposed, the 25 points attributed to the Public Health and Clinical Data Exchange objective would apply to the measures in the objective that are required and not suppressed.

Should you have questions or need help with your MIPS/MVPs reporting, please contact us.