2026 Changes to MIPS Reporting Criteria

Each year, the Centers for Medicare and Medicaid Services (CMS) updates the criteria of the Merit-Based Incentive Payment System (MIPS). In 2026, MIPS is expanding emphasis on MIPS Value Pathways (MVPs) and continuing to refine other measures. 

MIPS is not a “check-the-box” compliance exercise. Your score directly impacts Medicare reimbursement, public quality ratings, and how your practice is perceived by referring providers and patients.  

Many specialty practices feel overwhelmed by MIPS because of increasing complexity, evolving criteria, technology gaps, and unclear guidance. This guide breaks MIPS down into practical terms, explains what’s changing in 2026, and outlines a clear, step-by-step approach your practice can take to earn high scores with less burden. 

What’s changing in 2026? Find out here. 

Everything You Need to Know and What Your Practice Can Do to Receive High Scores 

Table of Contents 

What Is MIPS Reporting? 

Who Has to Report MIPS? 

The 4 Categories Of MIPS Criteria 

What Measures Matter Most for Specialty Practices 

2026 MIPS Criteria Changes 

Next Steps on How to Prepare for High MIPS Scores 

Are There Exceptions to MIPS? 

MIPS FAQs 

What Is MIPS Reporting? 

The Merit-Based Incentive Payment System was introduced in 2017 as part of CMS’s broader shift toward value-based care. Instead of reimbursing providers solely based on patient volume, MIPS ties Medicare payment adjustments to performance across several quality and efficiency measures. 

Under MIPS, eligible clinicians receive a composite score based on four performance categories: Quality, Cost, Improvement Activities, and Promoting Interoperability. That score is compared against a national performance threshold. In 2026, the neutral threshold remains 75 points. Practices scoring above that threshold may receive positive payment adjustments, while those scoring below it risk penalties. The further your score is from the threshold, the greater the financial impact. 

What this means for you: 

High MIPS scores can increase reimbursement and strengthen your practice’s reputation. Low scores can reduce revenue and negatively affect public reporting. Preparing early significantly reduces stress and administrative workload. 

Who Has to Report MIPS? 

MIPS applies to eligible clinicians who meet CMS’s participation thresholds based on Medicare billing volume, patient count, and covered services. Practices may report as individuals or as groups, and that decision alone can significantly affect scoring outcomes. 

Failing to understand eligibility rules is one of the most common causes of unnecessary penalties. For many specialty practices, a group reporting strategy allows for more consistent performance and risk mitigation. 

What this means for you: 

Eligibility misunderstandings can cost thousands of dollars. Choosing the right reporting structure is an important strategic decision and not just an administrative task. 

The 4 Categories of MIPS Criteria 

Your MIPS score is a composite of your weighted scores in four categories: Quality (30%), Improvement Activities (15%), Promoting Interoperability (25%), and Cost (30%). 

Traditional MIPS Quality Category 

Quality accounts for 30% of your total MIPS score. To qualify, your practice is required to report on no fewer than six quality measures, including at least one outcome-based or high-priority metric. 

There are more than 100 CMS-approved quality measures to choose from, including such activities as screening for tuberculosis before prescribing biologic therapy, connecting vulnerable patients with community resources, and collaborating with a diabetic patient’s primary care physician. 

Outcome-based measures include such metrics as the percentage of patients who reported improvement in specific symptoms, while high-priority measures include metrics like biopsy reporting time. 

Why it matters: 

Quality drives much of your final score. Selecting specialty-relevant measures – such as diagnostic accuracy, procedure outcomes, or patient follow-up – is essential and can provide a major performance advantage. 

MIPS Value Pathways (MVPs): An Alternative to Traditional MIPS Reporting 

Starting in 2026, practices can choose to report through MIPS Value Pathways (MVPs) instead of Traditional MIPS. MVPs offer a streamlined, specialty-focused set of quality measures, making reporting more relevant and less burdensome. Practices select an MVP aligned with their specialty, report on the required measures, and CMS calculates the rest. MVPs are optional in 2026 but represent the future direction of MIPS reporting. 

Why it matters:

MVPs simplify measure selection, reduce administrative work, and help practices focus on what matters most for their specialty. Early adoption can give your practice a head start as CMS transitions away from Traditional MIPS in future years. 

MIPS Cost Category 

Cost makes up 30% of your total MIPS score, and it’s the only category that doesn’t require any reporting from you. 

This category evaluates your cost efficiency based on Medicare spending, total per-capita costs, and several episode-based measures. 

The Quality Payment Program calculates this score for you using Medicare administrative claims data. 

Why it matters: 

Even though practices do not self-report these measures, Cost is still a substantial part of the final MIPS score and it carries a direct impact on determining reimbursement adjustments. 

MIPS Improvement Activities Category 

This category is meant to encourage innovation and reward healthcare providers for continuous improvement. Improvement Activities account for 15% of your total MIPS score. 

To participate, you need to complete between two and four approved activities in the reporting period. The minimum depends on factors including practice size and whether you are in an urban or rural area. You have to sustain each activity for at least 90 days, and it also needs to be completed by 50% of the providers in the practice. 

There are more than 100 CMS-approved Improvement Activities to choose from, including things such as medication management, research participation, and individual care plan development. 

Why it matters: 

Many of these activities align naturally with specialty workflows and can be high-impact, low-effort score boosters when properly documented. This category also is often easier to optimize than Quality or Cost. 

Promoting Interoperability Category

The MIPS Promoting Interoperability category was originally called the Medicare EHR Incentive, or the Meaningful Use Program. It’s intended to encourage healthcare providers to use technology that enables collaboration across care teams. 

In essence, it measures your ability to electronically exchange patient health data with providers outside your practice. 

Promoting Interoperability accounts for 25% of your total MIPS score. To qualify, you must use a certified electronic health records (EHR) system. Since this category makes up a quarter of your composite score, providers who don’t use a certified EHR are automatically assessed a penalty. 

For those using a certified EHR, your Promoting Interoperability score is calculated according to your performance in four objectives: e-prescribing, health information exchange, provider-to-patient exchange, and public health and clinical data exchange 

Why it matters: 

Promoting Interoperability is an “all or none” category — every required objective and measure must be completed to earn points. Missing documentation or failing to meet any component results in a penalty for the entire category, even if other requirements are met. Technology readiness and thorough documentation are critical for success.  

What Measures Matter Most for Specialty Practices 

Why MIPS Impacts Specialty Practices Differently 

Specialty practices face unique challenges under MIPS. Measure sets are narrower, making it harder to find options that align with your practice’s day-to-day care delivery. Diagnostic pathways are more complex, imaging plays a larger role, and procedural care varies widely, introducing layers of nuance to documentation and coding. Generic reporting approaches often fail to reflect how specialty care is actually delivered. 

What this means for you: 

Choosing the right measures can become a competitive advantage. One-size-fits-all strategies leave points on the table. 

High-Impact Measures by Specialty 

Ophthalmology: High-performing practices focus on imaging-based quality measures, outcomes tied to vision preservation, and efficient diagnostic workflows. Aligning documentation with imaging data is critical. 

Plastic Surgery: Patient experience, complication rates, and post-operative outcomes are key. Improvement Activities tied to care coordination and patient education can significantly boost scores. 

Dermatology: Measures related to biopsy accuracy, appropriate follow-up, and teledermatology utilization are increasingly relevant. Cost control strategies also play an important role. 

Most Common Reasons Specialty Practices Fail 

While many practices deliver excellent care, they can still struggle with MIPS reporting because of operational misalignment. Common issues include incorrect measure selection, incomplete documentation, manual reporting workflows, and EHR systems that are not optimized for MIPS. 

What this means for you: 

Success starts with good clinical care but also requires the right combination of technology, processes, and education. 

2026 MIPS Criteria Changes  

In 2026, CMS continues to focus on outcomes and strongly encourage participation in MIPS Value Pathways. Refinements were made to the Quality, Improvement Activities, and Promoting Interoperability categories, while the Cost category remained stable as indicated by the Quality Payment Program 2026 Final Rule. 

The Rise of MIPS Value Pathways 

MVPs bundle related measures across all four categories into a cohesive pathway centered on specific conditions or specialties. CMS is shifting toward MVPs to simplify reporting and improve measure relevance. Be sure to review this guide from CMS about the newly finalized MVPs and modifications to previously finalized MVPs. 

2026 MIPS Quality Changes 

• 5 measures added, including 2 eCQMs. 
• 10 measures removed. 
• Substantive changes to 30 existing measures. 
• Removed health equity from the definition of a high priority measure. 
• Revised the definition of a “beneficiary eligible for Medicare CQMs” at 42 CFR 425.20. 
• Finalized 19 measures that will receive the previously defined topped out measure benchmarks.

2026 MIPS Cost Changes 

• 15 measures unchanged. 
• Modified the total per capita cost (TPCC) measure candidate event and attribution criteria. 
• Finalized a 2-year informational-only feedback period for new cost measures.

2026 MIPS Improvement Activities Changes 

• 3 new activities added. 
• 7 existing activities modified. 
• 8 activities removed. 
• Replaced the Achieving Health Equity (AHE) subcategory with the new Advancing Health and Wellness (AHW) subcategory.

2026 MIPS Promoting Interoperability Changes 

• Modified the Protect Patient Health Information Objective, Security Risk Analysis Measure to include a second attestation component. 
• Modified the High Priority Practices SAFER Guide measure by requiring the use of the 2025 SAFER Guides. 
• Modified the Public Health and Clinical Data Exchange objective by adopting a new optional bonus measure: the Public Health Reporting Using TEFCA measure. 
• Adopted a measure suppression policy for the MIPS Promoting Interoperability category and the Medicare Promoting Interoperability Program. 
• Suppressed the Electronic Case Reporting measure.

Next Steps on How to Prepare for High MIPS Scores 

Step-by-Step Guide for Success 

1. Assess eligibility and reporting strategy: Determine whether individual or group reporting best aligns with your goals and risk tolerance. 
2. Select specialty-relevant measures: Review CMS measure lists and align with MVPs when appropriate. 
3. Optimize documentation workflows: Standardize templates and automate capture within your EHR. 
4. Analyze baseline performance: Use historical data and benchmarks to identify gaps. 
5. Close gaps early: Train staff and clinicians before reporting begins. 
6. Establish data validation and QA: Audit regularly to catch errors before submission. 
7. Use technology to simplify reporting: 

Tools, Processes, and People Needed 

High-performing practices designate a MIPS lead, maintain a reporting calendar, document SOPs, and rely on technology designed for specialty workflows. Nextech supports this approach with specialty-specific EHR and practice management solutions, built-in reporting tools, and dedicated MIPS consulting expertise. 

Quick Wins from High-Performing Practices 

• Focus on MVPs where appropriate 
• Automate Promoting Interoperability requirements 
• Validate data monthly 
• Monitor performance in real time

Internal Readiness Checklist 

• Eligibility confirmed 
• Measures selected 
• Workflows documented 
• Technology configured 
• QA testing completed 

Are There Exceptions to MIPS? 

Not every clinician is required to participate in MIPS. Exemptions may apply based on Medicare volume, patient count, participation in an Advanced APM, special status, extreme circumstances, or hospital-based practice designation. Understanding exemptions prevents unnecessary reporting and administrative burden. Here are some exceptions: 

• Providers who billed less than $90,000 in the reporting year. 
• Providers who cared for fewer than 200 Medicare patients in the reporting year. 
• Providers who provide fewer than 200 covered services. 
• Providers participating in an APM. 
• Providers who qualify for special status. 
• Providers affected by an extreme and uncontrollable circumstance, such as a natural disaster. 
• Providers who claim a hardship that impacts their ability to use an EHR, such as rural clinicians with poor internet connectivity. 
• Providers who provide 75% or more of their services in hospitals and emergency rooms are exempt from reporting on the promoting interoperability category — they must still report on quality and improvement activities.

Look up your practice to see if you are required to participate. 

MIPS FAQs 

MIPS Success Can Be a Competitive Advantage 

MIPS is about more than reimbursement. It influences public perception, referral relationships, and long-term financial stability. Specialty practices that choose the right measures, optimize workflows, and use specialty-aligned technology can turn MIPS into a strategic advantage rather than an annual burden. 

Ready to simplify MIPS reporting and maximize your score? 

Request a demo to see how Nextech’s specialty-specific EHR, practice management platform, and dedicated MIPS consulting experts help ophthalmology, dermatology, and plastic surgery practices achieve high MIPS scores with less work. 

About the Author

Heather Miller Dongilli has more than 25 years of leadership experience in healthcare operational management, providing comprehensive medical consultation to hundreds of practices. Her expertise includes oversight of revenue cycle management, Medicaid and Medicare compliance, and workflow analysis to increase practice productivity. She has a proven track record in supporting clients in the adoption of electronic health records and providing strategy plans for annual MIPS reporting. 
 
Heather holds a master’s degree in business administration from Rollins College - Crummer School of Business and a second master’s degree in Early Childhood Special from the University of Miami. She completed her undergraduate degree at the University of Tennessee in Special Education.