2026 Medicare Physician Fee Schedule Final Rule

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

2026 Medicare Physician Fee Schedule (PFS) Final Rule

MIPS Value Pathways (MVPs)

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

The 6 newly added MVPs are:

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

CMS finalized 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 also finalized that multispecialty groups that are small practices (15 or fewer clinicians) will be able to register to report an MVP as a group and 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 is 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 finalized continuing to use a performance threshold of 75 points through the CY 2028 performance period/2030 MIPS payment year.

Quality

For the 2026 performance period, CMS finalized changes to the quality measures inventory resulting in a total of 190 quality measures, of which 187 are available in traditional MIPS and 3 are available only in MVPs (this does not include QCDR measures which are approved outside of the rulemaking process).

• Addition of 5 quality measures
  • Including 2 eCQMs:
    • Q514: Diagnostic Delay of Venous Thromboembolism in Primary Care
    • Q515: Screening for Abnormal Glucose Metabolism in Patients at Risk of Developing Diabetes
• Removal of 10 quality measures
• Substantive changes to 30 existing quality measures

Further, CMS has removed health equity from the definition of a high priority measure. High-priority measures are 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”.

CMS finalized that 19 quality measures will receive topped out measure benchmarks for the CY 2026 performance period. In 2026, the one eCQM this applies 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 updated 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 will 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 did not make any changes to the cost measure inventory for the CY 2026 performance period. However, CMS revised the Total Per Capita Cost (TPCC) measure, particularly adjusting the criteria for its candidate event and attribution. This aims to reduce instances where TPCC is attributed to highly specialized groups based solely on billing of advanced care practitioners.

CMS also finalized 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 will receive feedback on the new cost measure(s) but it would not contribute to their score.

Improvement Activities

For CY 2026 performance year, CMS finalized removing the Achieving Health Equity (AHE) subcategory for improvement activities and replacing it with Advancing Health and Wellness (AHW) subcategory.

CMS finalized the following updates to the Improvement Activities inventory:

• addition of 3 new improvement activities:
  • IA_PM_27: Improving Detection of Cognitive Impairment in Primary Care
  • IA_PM_28: Integrating Oral Health Care in Primary Care
  • IA_PSPA_34: Patient Safety in Use of Artificial Intelligence (AI)
• modifications of 7 existing improvement activities:
  • IA_AHE_1, IA_AHE_3, IA_AHE_6, IA_AHE_7, and IA_AHE_10: reassigned out of the AHE subcategory to other subcategories
  • IA_PM_13 reassigned to the AHW subcategory
  • Several modifications to IA_BMH_1
• removal of 8 existing improvement activities
  • IA_AHE_5, IA_AHE_8, IA_AHE_9, IA_AHE_11, IA_AHE_12, IA_PM_6, IA_PM_26, IA_ERP_3

Promoting Interoperability

Beginning with CY 2026, CMS finalized modifications to the Security Risk Analysis measure and the SAFER Guides measure. For the Security Risk Analysis measure, CMS finalized 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 this modified measure, MIPS eligible clinicians are 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 finalized 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 finalized the addition of 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). A MIPS eligible clinician will 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 finalized a measure suppression policy for the MIPS PI performance category and the Medicare PI Program to allow CMS to suppress a measure for circumstances outside the control of MIPS eligible clinicians and eligible hospitals/CAHs meeting the requirements of the MIPS PI performance category or the Medicare Promoting Interoperability Program, respectively. A suppressed measure will receive the maximum available points or full credit if the suppressed measure is reported. For CY 2025 reporting/2027 MIPS payment year and for the CY 2025 EHR reporting, CMS finalized the suppression of 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 are still 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. Failure to report the suppressed eCR measure will result in a PI score of zero.

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