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 swing runs from a 9 percent penalty to a small bonus, applied claim by claim, for a full year. On $2 million in annual Medicare revenue, the downside alone is $180,000.

CMS finalized the rules for 2026 MIPS reporting in the CY2026 Physician Fee Schedule Final Rule on November 5, 2025. It was billed as a stability year, and structurally it is: the performance threshold, the category weights, and the eligibility criteria all carried over. But the measure inventory moved, the benchmarks reset, six new MIPS Value Pathways arrived, and multispecialty groups lost the ability to report an MVP at the group level. Stability at the program level, and plenty of motion in the details that decide your score.

This guide covers the full 2026 MIPS reporting cycle: eligibility, the four performance categories, scoring, reporting pathways, and every deadline between now and the payment adjustment. We publish it in July deliberately. Half the performance year is gone, and several of the moves that protect a score are still available. Several are not. We flag both.

What Is MIPS Reporting?

MIPS reporting is the annual process of collecting and submitting 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 four categories: Quality, Cost, Promoting Interoperability, and Improvement Activities. The final score is compared to a performance threshold, and the result adjusts Medicare Part B payments two years later.

That two-year lag is the part practices most often misjudge. The adjustment on your 2026 claims right now was set by your 2024 score. Nothing you do this year changes your 2026 or 2027 reimbursement. What 2026 MIPS reporting controls is 2028. Practices that treat MIPS as a January-through-March submission task are managing the paperwork. The score was built during the performance year, by decisions made months before the submission window opens.

Who Must Report MIPS in 2026

Eligibility did not change for 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 are exempt but may opt in for a payment adjustment, or report voluntarily with no adjustment. Clinicians in their first year of Medicare enrollment are excluded, as are those who reach Qualifying APM Participant (QP) status through an Advanced APM. For 2026, the two determination segments run October 1, 2024 through September 30, 2025 and October 1, 2025 through September 30, 2026.

Two operational notes that trip practices every year. First, eligibility is determined at the TIN/NPI level, so a clinician who works across multiple practices can be required to report at one and not another. Second, status can change mid-year: QP determinations are updated on snapshots throughout 2026, and CMS finalizes eligibility in December. Check the QPP Participation Status Tool now, and check it again in December before you lock a submission plan. For the full mechanics, including the opt-in decision and the segment rules that decide the edge cases, see our MIPS eligibility guide.

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

The structure held. The performance threshold stays at 75 points, and CMS has finalized that level through the 2028 performance year. Category weights are unchanged. The low-volume threshold is unchanged. The maximum penalty remains 9 percent.

The details moved:

• Quality inventory. CMS added 5 quality measures (including 2 eCQMs), removed 10, and made substantive changes to 30 more. If your 2025 measure set included a removed or revised measure, your selection math changed whether or not your clinical performance did.
• Benchmark and scoring mechanics. A defined set of measures in specialty sets with limited measure choice now scores under new topped-out measure benchmarks, and CMS revised the scoring methodology for administrative claims measures to align with cost measure benchmarking. Same performance rate, different points. Check the 2026 quality benchmarks before assuming last year’s mix still works.
• High-priority definition narrowed. CMS removed health equity from the definition of a high-priority measure, refocusing the designation on outcomes, safety, appropriate use, patient experience, and care coordination.
• Improvement Activities refresh. Three activities added, 7 modified, 8 removed. The Achieving Health Equity subcategory was retired and replaced with Advancing Health and Wellness.
• Promoting Interoperability tightened. The Security Risk Analysis measure now requires a second attestation, confirming you have implemented security measures to address identified vulnerabilities. The SAFER Guides attestation moves to the 2025 edition of the guides. A new optional bonus measure, Public Health Reporting Using TEFCA, joins the Public Health and Clinical Data Exchange objective.
• Cost held steady. No cost measures added or removed; the inventory stays at 35. CMS refined Total Per Capita Cost attribution and finalized a 2-year, informational-only feedback period for any cost measures adopted in future years.
• MVPs expanded. Six new MVPs bring the total to 27, and all previously existing MVPs were updated. More on the pathways below, including the registration rule change for multispecialty groups.

The Four Performance Categories in 2026

Quality: 30% of the score

Select 6 measures, at least one of them an outcome measure (or another high-priority measure if no outcome measure applies to you), and collect data for the full 12 months. To be scored against national benchmarks, a measure needs 75 percent data completeness and at least 20 eligible cases. For registry, QCDR, and eCQM reporting, completeness counts patients across all payers, not just Medicare; the Medicare Part B claims collection type is the exception, measured on Medicare patients only. Each scored measure earns 1 to 10 points against its benchmark.

Small practices get real accommodations here: a 3-point floor on any measure reported with at least one eligible case, 6 bonus points added to the Quality score for submitting at least one measure, and access to the Medicare Part B claims collection type that larger groups cannot use.

Measure selection is where the category is won. 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, and that is exactly the problem. 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. Meet them and you are scored on data most practices have never looked at.

The national median cost score is about 42 percent. Half of all clinicians sit below it, most without visibility into why, even though CMS publishes the episode-level data that would explain it. Thirty percent of the score, decided by numbers nobody at the practice is watching, is the single largest blind spot in 2026 MIPS reporting. It is fixable mid-year, because the episodes accumulating right now are the ones you will be scored on. We built our MIPS Cost analytics for precisely this.

Promoting Interoperability: 25% of the score

Report EHR-based measures for a minimum of 180 continuous days within 2026, using certified EHR technology, with the certification in place by December 31, 2026. The category spans four objectives: 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, including the new TEFCA measure, can add up to 5 bonus points.

Two attestations deserve attention in 2026: the Security Risk Analysis measure now requires confirming that you implemented security measures for the vulnerabilities you found, and the SAFER Guides attestation references the 2025 guides.

A timing note that matters as of this writing: July 5, 2026 was the last day to begin a 180-day performance period that ends inside the calendar year. If your certified EHR has been live all year, you are fine; any 180-day window with complete data works. If you are mid-implementation and cannot produce 180 continuous compliant days, your realistic path is a PI hardship exception, due December 31, 2026. When PI is reweighted to zero, its 25 points move elsewhere: Quality typically rises to 55 percent of the final score, and for small practices the split becomes Quality 40 percent and Improvement Activities 30 percent. Either way, the stakes on measure selection go up. Small practices, hospital-based clinicians, non-patient-facing clinicians, and several other special statuses are reweighted automatically.

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. The last day to start a 90-day window is October 3, 2026.

The category is the easiest 15 points on the board and still gets fumbled two ways: practices attest to activities they cannot document when audited, or they wait past October and run out of calendar. Pick the activities now, run them, and keep the evidence. 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 points, the performance threshold, your adjustment is zero. Below 75, penalties scale linearly down to the maximum: score 18.75 or lower and the full 9 percent penalty applies to every Part B claim you bill in 2028. Above 75, bonuses scale up, but they are funded entirely by the penalty pool, because MIPS is budget-neutral by statute.

That budget neutrality is the number most practices have not priced in. For the 2026 payment year, based on 2024 performance, the mean final score was 82.7 and a perfect score of 100 earned a positive adjustment of just 1.05 percent, the smallest in program history. Most clinicians clear the bar, so the bonus pool is thin.

Run that on $2 million of Medicare revenue and the asymmetry is stark: the ceiling this cycle was about $21,000. The floor was negative $180,000, every year the failure repeats. And the failures are not evenly distributed: 27 percent of small practices took a penalty in the 2024 payment year.

So the honest framing of 2026 MIPS reporting is defense with a modest upside. The return on doing it well is not the bonus. It is never writing a six-figure check to budget neutrality, and holding a submission that survives an audit. That is a solvable problem, and it is cheaper to solve in July than in February. We break down the full mechanics, including exactly what the 9 percent applies to and who gets caught, in our MIPS penalty guide.

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 is an advantage if someone is doing the selection analysis and a liability if no one is.

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. There are 27 MVPs for 2026, including six new ones covering diagnostic radiology, interventional radiology, neuropsychology, pathology, podiatry, and vascular surgery. MVP reporting remains optional in 2026, but it requires registration between April 1 and November 30, 2026, and CMS has signaled through a formal Request for Information that it is eyeing the 2029 performance year for sunsetting traditional MIPS entirely. Every new MVP for a specialty is an early warning that the pathway is becoming that specialty’s practical default. Our MVP overview covers the transition timeline.

One rule changed for 2026: multispecialty groups can no longer register to report an MVP as a single group. They must register and report at the subgroup, individual, or APM Entity level, with one exception: multispecialty groups holding small practice status (15 or fewer clinicians) may still register as a group. Groups now self-attest their specialty composition during MVP 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 ACO participation as the exit from MIPS reporting altogether, that math has its own guide: see our MSSP ACO overview.

One more boundary worth knowing: the Ambulatory Specialty Model launches January 1, 2027, and ASM participants will be exempt from MIPS during the model. If you are on the preliminary participant list, your 2026 MIPS cycle may be your last for a while, but 2026 still counts 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. Items above the line have already passed.

The submission window is a hard stop. There is no late submission in MIPS, and a missed window scores the categories you failed to submit at zero. For the expanded timeline, including what each date decides and what to do if one already slipped, see our MIPS reporting deadlines guide.

It’s July. Here’s Where You Should Stand.

A mid-year position check, in the order we run it for our own clients:

1. Re-verify eligibility. QP determinations refresh this month from the March 31 snapshot, and again in the fall. Confirm every TIN/NPI combination you plan to report.
2. Pull six months of quality performance. Calculate your rates on your intended measures against the 2026 benchmarks, not the 2025 ones. If a measure is underperforming or was revised in the final rule, you can still change the mix: registry-reported measures are selected at submission, but only measures with a full year of underlying data will hold up. July is the last comfortable month to redirect documentation workflows.
3. Look at your cost position. The episodes that will be scored are accumulating right now, and the drivers are visible in claims months before CMS scores them. This is the category where mid-year action moves the most dollars.
4. Settle Promoting Interoperability. Confirm your CEHRT status and pick your 180-day window from data you already have. If you cannot produce one, start the hardship exception application rather than hoping.
5. Lock Improvement Activities. Choose the 2 activities (1 if small practice), start them no later than October 3, and file the documentation as you go.
6. Make the MVP call. If an MVP fits your specialty for 2026, register before November 30. Multispecialty groups above 15 clinicians should have their subgroup structure decided well before registration closes.

If you want a second set of eyes on any of this, bring us last year’s QPP feedback report. We will show you the points you left on the table and what they were worth. Talk to us.

How to Submit 2026 MIPS Data

When the window opens on January 4, 2027, 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.

The mechanics are the smallest part of what a registry is for. The difference between registries is what happens before the file transmits: whether anyone validated the data completeness math, priced the measure mix against current benchmarks, caught the reweighting you qualified for, and kept the patient-level evidence that answers an audit. Most registries transmit whatever they are handed. If the data is incomplete, they transmit a low score.

VBCA operates a CMS-approved QCDR and runs MIPS reporting as a strategy, not a deadline: measure selection priced before you commit, all four categories tracked as one number all year, and direct submission with patient-level evidence behind every figure. We also author quality measures ourselves; four are CMS-approved and reportable through our registry today, which matters if the standard inventory scores your specialty poorly.

2026 MIPS Reporting: Frequently Asked Questions

The Bottom Line

2026 MIPS reporting rewards practices that treat it as a year-long financial exercise and quietly taxes the ones that treat it as spring paperwork. The threshold is 75, the downside is 9 percent, the upside is small, and every point comes from decisions with dates attached: measure selection against reset benchmarks, a defensible 180-day PI window, activities started by October 3, an MVP registration by November 30, and a submission that closes March 31, 2027.

We maintain this guide through the performance year and will update it when CMS finalizes 2027 policy this November. For the rule changes coming next, see our analysis of the CY2027 Physician Fee Schedule proposed rule. And if you would rather hand the whole exercise to the people who shape the policy and build the platform, start with a conversation.

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