2026 MIPS Reporting: Requirements, Deadlines, and What the Score Is Worth

The data your practice collects between January 1 and December 31, 2026 will set your Medicare Part B payment adjustment for all of 2028. The range runs from a 9 percent penalty to a small bonus, applied claim by claim for the full year.

CMS finalized the rules for 2026 MIPS reporting in the CY2026 Physician Fee Schedule Final Rule on November 5, 2025. Most of the program’s structure carried over from 2025, while the measure inventory, the benchmarks, and the MVP rules changed enough to move scores. This guide covers eligibility, the four performance categories, scoring, the reporting pathways, and every remaining deadline. As of September 23, 2026, the performance year has about three months left, and the fourth-quarter checklist lists what can still be changed before it closes.

What Is MIPS Reporting?

MIPS reporting is the annual submission of performance data to CMS under the Merit-based Incentive Payment System, the largest track of the Quality Payment Program. Eligible clinicians are scored from 0 to 100 across Quality, Cost, Promoting Interoperability, and Improvement Activities, and the final score adjusts Medicare Part B payments two years later. Practices most often misjudge that lag: 2024 scores set the adjustment on 2026 claims, and 2026 reporting controls 2028. Most of the score is settled during the performance year, months before the submission window opens.

Who Must Report MIPS in 2026

You are required to participate if, during both segments of the MIPS determination period, you exceed all three elements of the low-volume threshold:

• More than $90,000 in Medicare Part B allowed charges for covered professional services
• More than 200 Medicare Part B patients
• More than 200 covered professional services

Exceed one or two elements but not all three and you may opt in or report voluntarily. First-year Medicare enrollees and Qualifying APM Participants (QPs) are excluded. The determination segments run October 1, 2024 through September 30, 2025 and October 1, 2025 through September 30, 2026, and eligibility is set per TIN/NPI, so a clinician can be required at one practice and exempt at another. QP determinations from the June 30 APM snapshot post in October, and final eligibility, including the August 31 snapshot, posts in December; check the QPP Participation Status Tool at both points. The opt-in decision and edge cases are in our MIPS eligibility guide.

What Changed for 2026 MIPS Reporting (and What Didn’t)

The performance threshold stays at 75 points, and CMS has finalized that level through the 2028 performance year. Category weights, the low-volume threshold, and the 9 percent maximum penalty are also unchanged. The changes sit one level down, in the inventories and scoring rules:

• Quality inventory. CMS added 5 quality measures (including 2 eCQMs), removed 10, and made substantive changes to 30 more. A removed or revised measure in your 2025 set changes your selection math even if your clinical performance did not change.
• Benchmark and scoring mechanics. Some measures in specialty sets with limited choice now score under new topped-out benchmarks, and administrative claims measures are now benchmarked the way cost measures are. Check the 2026 quality benchmarks before assuming last year’s mix still works.
• High-priority definition narrowed. Health equity is no longer part of the definition of a high-priority measure.
• Improvement Activities refresh. Three activities added, 7 modified, 8 removed; the Achieving Health Equity subcategory became Advancing Health and Wellness.
• Promoting Interoperability tightened. The Security Risk Analysis measure adds a second attestation that you implemented security measures for the vulnerabilities you found, the SAFER Guides attestation moves to the 2025 edition, and a new optional bonus measure, Public Health Reporting Using TEFCA, joins the Public Health and Clinical Data Exchange objective.
• Cost held steady at 35 measures. CMS refined Total Per Capita Cost attribution and set a 2-year, informational-only feedback period for cost measures adopted in future years.
• MVPs expanded and registration changed. New pathways were added, every existing MVP was updated, and multispecialty groups lost group-level registration. Details are under reporting pathways.

With the threshold fixed, the points that move in 2026 come mostly from two places: measure selection under the reset benchmarks, and data completeness. Those are where we see practices lose ground in a year like this one.

The Four Performance Categories in 2026

Quality: 30% of the score

Select 6 measures, at least one an outcome measure (or another high-priority measure if no outcome measure applies), and collect a full 12 months of data. A measure needs 75 percent data completeness and at least 20 eligible cases to be scored against its benchmark, where it earns 1 to 10 points. Registry, QCDR, and eCQM completeness counts patients across all payers; only the Medicare Part B claims collection type is measured on Medicare patients alone.

Most of the category is decided by measure selection. A perfect performance rate on a topped-out measure caps at 7 points, and benchmarks reset every year, so the same clinical performance can earn fewer points than it did in 2025. Start from the 2026 MIPS quality measures list and the specialty measure sets, then price each candidate measure against its current benchmark before committing.

Cost: 30% of the score

You submit nothing for Cost. CMS calculates it from claims across 35 measures: Medicare Spending Per Beneficiary, Total Per Capita Cost, and 33 episode-based measures, each with its own case minimum. Miss every case minimum and the category reweights to Quality. The national median cost score is about 42 percent, and most clinicians below it cannot say why, even though CMS publishes the episode-level data that would explain it. Our MIPS Cost analytics show which episodes and which spending drive the number.

Promoting Interoperability: 25% of the score

Report EHR-based measures for at least 180 continuous days in 2026 using certified EHR technology in place by December 31, 2026. The four objectives are e-Prescribing, Health Information Exchange, Provider to Patient Exchange, and Public Health and Clinical Data Exchange, where Electronic Case Reporting and Immunization Registry Reporting are required (exclusions available) and four optional measures can add up to 5 bonus points.

The last day to begin a 180-day period inside the year was July 5, 2026. If your certified EHR has been live all year, any 180-day window with complete data works; if not, the realistic path is a PI hardship exception, due December 31, 2026. Small practices, hospital-based clinicians, non-patient-facing clinicians, and several other special statuses are reweighted automatically. When PI drops to zero its weight shifts mostly to Quality (the FAQ below has the percentages), which raises the stakes on measure selection.

Improvement Activities: 15% of the score

Attest to 2 activities from the 2026 inventory, or 1 if you hold small practice, rural, HPSA, or non-patient-facing status, each performed for at least 90 continuous days in 2026. For group reporting, at least half the clinicians in the TIN must perform the activity during the same period.

Practices lose these points in two ways: they attest to activities they cannot document when audited, or they start too late for 90 days to fit inside the year. CMS expects documentation to be retained for six years.

How 2026 MIPS Scoring Turns Into Dollars

The four category scores combine into a final score from 0 to 100. At 75 the adjustment is zero; below it, penalties scale linearly to the full 9 percent at 18.75 points or lower. Bonuses above 75 are funded entirely by the penalty pool, because MIPS is budget-neutral by statute, and because most clinicians clear the bar the pool is thin. For the 2026 payment year, based on 2024 performance, the mean final score was 82.7 and a perfect 100 earned just 1.05 percent, the smallest bonus in program history.

On $2 million of Medicare revenue, that bonus was worth about $21,000. The full penalty on the same revenue is $180,000, and it recurs every year the score stays at the floor. Small practices carry a disproportionate share of the downside: 27 percent of them took a penalty in the 2024 payment year. For most practices, then, 2026 reporting is mainly about staying above 75 with a submission that survives an audit. Our MIPS penalty guide covers what the 9 percent applies to and which practices tend to get caught.

Three Ways to Report: Traditional MIPS, MVPs, and the APP

Traditional MIPS is the default pathway described above: you choose your 6 quality measures from the full inventory and report all four categories independently. It offers the most selection flexibility, which helps only if someone at the practice is doing the selection analysis.

MIPS Value Pathways (MVPs) are pre-assembled, specialty-specific reporting packages: 4 quality measures from a focused list, 1 improvement activity, the standard PI measures, and MVP-relevant cost measures (the FAQ below lists the 2026 additions). MVP reporting is optional in 2026 but requires registration by November 30. CMS's proposed 2027 rule would end traditional MIPS after the 2028 performance year, leaving MVPs as the only option in 2029. Comments closed September 14, 2026, the final rule is expected around November 1, and our CY2027 proposed rule analysis walks through the rest of it. The MVP overview covers the transition timeline.

Multispecialty groups can no longer register an MVP as a single group; they register at the subgroup, individual, or APM Entity level unless they hold small practice status (15 or fewer clinicians). Groups also self-attest their specialty composition during registration.

The APM Performance Pathway (APP) applies to clinicians in MIPS APMs, most commonly Medicare Shared Savings Program ACOs, which report a fixed quality measure set on behalf of participants. If you are weighing an ACO as a way out of MIPS reporting, see our MSSP ACO overview.

The Ambulatory Specialty Model launches January 1, 2027, and its participants are exempt from MIPS reporting in the years they must meet ASM’s requirements. CMS published the final 2027 participant list in September 2026, and clinicians on it still report MIPS for 2026 in full. Check your status on our ASM page.

2026 MIPS Reporting Deadlines

All dates reflect the current QPP timeline and are subject to change.

Categories not submitted by March 31 score zero. What each date decides, and what to do if one already slipped, is in our MIPS reporting deadlines guide.

A Fourth-Quarter Checklist for 2026 MIPS Reporting

Roughly in date order, the way we work through it with our own clients:

1. Start Improvement Activities by October 3. A 90-day window that starts later cannot finish inside 2026. File the documentation as you go.
2. Read your 2025 feedback report. CMS released 2025 final scores on September 21, 2026, and targeted review closes 30 days after the 2027 payment adjustments come out, about a month after the scores. The report also shows where 2026 is likely to lose points.
3. Price nine months of quality data against the 2026 benchmarks. Registry-reported measures are selected at submission, so the mix can still change, but only measures with a full year of underlying data will hold up.
4. Look at your cost position. Episode drivers show up in claims long before CMS scores them, and episodes attributed through December 31 still count.
5. Re-check eligibility for every TIN/NPI combination after the October QP update and the December final determination.
6. Make the MVP call before November 30. Multispecialty groups above 15 clinicians need their subgroups set up before they can register.
7. Settle Promoting Interoperability. Confirm CEHRT status and pick the 180-day window from data you already have. If no compliant window exists, file the hardship exception before December 31.

Send us the six quality measures you plan to report for 2026 with your year-to-date rates. We will price each one against the 2026 benchmarks and tell you which to swap while there is still data to swap to. Send the measure list here.

How to Submit 2026 MIPS Data

Data reaches CMS one of three ways: you sign in to qpp.cms.gov and attest or upload files directly, your EHR submits eCQMs on your behalf, or a CMS-approved registry or Qualified Clinical Data Registry (QCDR) submits for you. Registries differ in what happens before the file transmits: whether anyone checked the data completeness math, priced the measure mix against current benchmarks, caught a reweighting you qualified for, and kept the patient-level evidence an audit asks for. Most transmit whatever they are handed.

VBCA operates a CMS-approved QCDR and runs MIPS reporting as a year-round strategy, with measure selection priced before you commit and patient-level evidence behind every submitted figure. Four of our own quality measures are CMS-approved and reportable through the registry, which helps when the standard inventory scores your specialty poorly.

2026 MIPS Reporting: Frequently Asked Questions

Keep going: MIPS reporting deadlines for 2026 · The MIPS penalty, explained · MIPS eligibility: do you have to report?