Traditional MIPS reporting has reached its final days. On July 14th, 2026, CMS issued a proposed rule for the CY 2027 Physician Fee Schedule. In that proposed rule was the most significant quality reporting disruption to Medicare quality reporting since MIPS began; the agency plans to sunset traditional MIPS at the end of the 2028 performance period with all eligible clinicians transitioning to MIPS Value Pathways (MVP) by 2029.
The time for practices that are still reporting under the legacy method is now running. Below we have the language from the proposed rule that defines this new direction as well as what your billing team will need to do prior to when the comment window will close.
Quick Answer
- Traditional MIPS ends at the 2028 performance year. Clinicians will report under one of two options starting in 2029 (APM or MVP).
- Two additional MVPs are proposed; Diabetes Disease and Hypertension. This would bring the total number of MVPs to thirty.
- A new MIPS Core Measures reporting option has been introduced with consideration for a small practice exemption.
- The public comment period ends on September 14, 2026. CMS plans to release a final rule in the Fall of 2026.
What's Happening to MIPS
MIPS provided clinicians with four categories (Quality, Cost, Improvement Activities, Promoting Interoperability) from which they could select measures. While the use of these categories allowed clinicians to choose their own measures for reporting purposes, it was the flexibility offered by those categories that CMS is seeking to phase-out.
This proposed rule will end the option for clinicians to report using the traditional method after the CY 2028 performance period. This will affect how clinicians are paid in the 2030 MIPS performance year. The only reporting mechanism available to clinicians who do not report through the APM Performance Pathway will be an MVP developed specifically for their specialty.
MVPs were first introduced by CMS in 2023 as optional alternatives. The rate of adoption has been very low; therefore, CMS is making the transition to MVPs mandatory for all practices.
What's New in the CY 2027 Proposal
Beginning with three new Medical Value Packages (MVP) now under consideration; one specifically for patients with diabetes; one specifically for hypertensive patients; and one developed for clinicians working in hospitals. In addition to these three, there have been 27 MVPs previously completed. The overall number of MVPs will therefore be 30 and based on CMS projections, will cover about 98% of all medical specialties.
CMS is proposing that MIPS core measure requirements will apply both to MIPS reporters and to MVP reporters in 2027. As such, small practice physicians who do not wish to participate in MIPS or MVP reporting may receive an exemption from the MIPS core measure requirements but it is still unclear what specific criteria will be used by CMS to determine which physicians qualify as "small" practices.
Additionally, virtual groups will be able to submit MVPs beginning in CY 2029. This represents closure of a long-standing issue of frustration experienced by many of the smaller and independent physician groups that form virtual groups in order to meet MIPS reporting threshold requirements.
Regarding payment, the proposed conversion factor for 2027 is $33.1693 for Qualifying Alternative Payment Model (APM) participants and $32.8409 for all other eligible providers. Both figures represent a decrease of 1.19% and 1.68%, respectively, compared to the 2026 conversion factors.
What This Means for Your Billing Team
Billing teams with workflows based on traditional MIPS measure selections have approximately 2 years to transition to alternative value-based payment (MVP) scoring. This is particularly short of time for multispecialty groups that are already trying to navigate multiple MVP alternatives for each provider.
The reason why this matter goes well beyond regulatory compliance relates to the way that MVP scoring bundles together quality, cost and interoperability data by a particular specialty. As such, how a team measures performance from one year to another will begin to differ greatly among specialties. For example, there will no longer be similar scoring for a cardiologist versus an orthopedist within the same billing operation.
In addition, practices should now be developing which of the 30 proposed MVPs best fit their specialty profile. Some practices will discover a direct correlation. Other practice’s that include many different types of specialists will likely require reporting on multiple MVPs among different providers.
Again, the type of change described above is precisely when the importance of clean medical coding and accurate documentation becomes most apparent. The new MVP scoring provides significantly more benefit for accurate medical coding at the code level as compared to prior models. With fewer measures available for reporting, it is much easier for a group to offset lower scores through other areas.
Impact on Patients and Payers
Patients may not realize it is happening but the quality metrics associated with MVP's will impact how CMS adjusts payments based on those metrics; ultimately affecting how practices are paid for their services.
Commercial payers who follow what CMS does will eventually tie their own commercial quality measures to the new MVP structures. If a practice can be prepared for reporting under the MVP model before all other practices have made this transition they will also be better positioned once most commercial payers move to the same structure as CMS.
What Should Your Practice Do Now?
Comments are due by September 14, 2026. Regardless whether your practice comments or not, there is preparatory work internally that has to be done anyway.
Preparations prior to the final rule
1. Determine your applicable MVPs
Compare the 30 proposed pathways with your specialty mix and Identify those which are applicable to each individual provider in your group.
2. Audit your current MIPS reporting method
If you currently report through traditional MIPS, begin building an interim timeline for transitioning to MIPS alternative payment models (apms) as soon as possible rather than waiting until the final rule is issued.
3. Review documentation practices tied to Core Measures
Verify your coding staff collect all the necessary data points required by the Core Measures being implemented.
4. Check small-practice status
If you may qualify for the new exemption from participation in MIPS based on the number of eligible clinicians within your practice, compile supporting documentation prior to receiving notice of the final rule from CMS.
5. Prepare to read the fall final rule
The proposed date and threshold adjustments occur regularly as a result of the transition from proposed to final version.
Because so many denial management service practices are familiar with just how much an adjustment in scoring will impact the timing for payment; they should be able to relate this concept to their own situation. Be proactive in dealing with these changes as opposed to simply reacting when the last rule is finalized.
Frequently Asked Questions
Traditional MIPS is supposed to be phased out as of the CY 2028 performance period when CMS plans on having MVPs become the mandatory reporting method for that time forward.
There will be thirty total MVPs - twenty-seven previously approved and finalized + three new ones related to diabetic disease, hypertension, and hospital based care.
Yes - those who do not participate in an APM Performance Pathway must transition into using an MVP; however, those currently enrolled in a MIPS APM can remain in their current status.
No. This is still being proposed along with core measures; thus, it may change by the time the Final Rule comes out later in the year.
The proposed MIPS system is going away. As has been the case for some time, billing teams will no longer have to deal with MIPS as we have come to know them. Although two years may seem like ample time until you are tasked with creating specific measure maps across all specialties within a multiple provider group, start developing those maps today. To connect the dots regarding your existing reporting, as well as areas of concern prior to the due date, Human Medical Billing would be happy to assist you. Please contact us through our Contact Us page and we'll give you a better idea of how vulnerable your practice is.
Contact Human Medical Billing to schedule a compliance readiness review or learn more about our end-to-end billing and regulatory support services.
