Applied Policy

Quality Payment Program Provisions in the CY 2027 Physician Fee Schedule Proposed Rule

Quality Payment Program Provisions in the CY 2027 Physician Fee Schedule Proposed Rule

On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) issued its proposed calendar year (CY) 2027 Physician Fee Schedule (PFS), which proposes policies for physician payment and other outpatient services covered under Medicare Part B. CMS released a rule overview fact sheet and an official press release outlining key proposals.

Key proposed updates to the Quality Payment Program (QPP) include:

  • MIPS Transformation: Sunset traditional MIPS after the CY 2028 performance period and make MIPS Value Pathways (MVPs) the primary reporting pathway for clinicians outside MIPS Alternative Payment Models (APMs).
  • MVP Updates: Add three new MVPs, incorporates core measures into existing MVPs, and permits virtual groups to report MVPs beginning in CY 2029.
  • Quality, Cost, and Improvement Activities: Establish MIPS core measures, updates episode-based measure codes, and revise the improvement activity inventory.
  • Promoting Interoperability: Align the Certified Electronic Health Record Technology (CEHRT) definition with proposed policies from the Office of the National Coordinator for Health Information Technology (ONC), remove certain attestations and the Security Risk Analysis measure, and update electronic prior authorization reporting.
  • Digital Quality Measurement: Seek feedback on a potential transition to mandatory FHIR-based quality reporting beginning in CY 2030.
  • APP and APP Plus: Update measure specifications, remove two planned APM Performance Pathway (APP) Plus measures, and establish Medicare electronic clinical quality measure (eCQM) reporting for Shared Savings Program ACOs.
  • MIPS Scoring and Benchmarking: Revise core-measure scoring, topped-out measure policies, ACO quality benchmarks, and potential future MVP scoring methodologies.
  • Third-Party Intermediaries: Strengthen participation, auditing, measure-support, disclosure, and termination requirements for Qualified Clinical Data Registries (QCDRs) and qualified registries.
  • MIPS Reweighting: Expand the data CMS may use to identify disaster-affected clinicians and extend the deadline for certain intermediary-failure applications.
  • MVP Public Reporting: Permit public reporting of new MVP improvement activities and Promoting Interoperability measures during their first year.
  • Clinician Star Ratings: Seek comment on using standard-deviation-based methodologies to calculate quality and cost star ratings.
  • Advanced APMs: Limit Qualifying APM Participant (QP)-related benefits to participating TIN/NPI combinations and update QP eligibility, thresholds, and incentive-payment policies.

This proposed rule was published in the Federal Register on July 16, 2026, and comments are due by September 14, 2026.

CMS proposes to Transform MIPS and the MVP Strategy

Pages 886-902[1]

CMS proposes to sunset the traditional MIPS reporting option after the CY 2028 performance period/2030 MIPS payment year, making MVPs the primary reporting pathway for MIPS-eligible clinicians beginning with the CY 2029 performance period. Under this proposal, MIPS-eligible clinicians who do not participate in a MIPS APM would report through an MVP, while clinicians in a MIPS APM would continue to report through the APM Performance Pathway (APP). If finalized as proposed, there would be two reporting options in the QPP: MVPs and the APP.

CMS previously finalized the creation of MVPs as a MIPS reporting option intended to provide a more cohesive participation experience by aligning activities from the four MIPS performance categories around a certain specialty, medical condition, or patient population. Traditional MIPS reporting will be available to clinicians through CY 2028 performance period/2030 MIPS payment year.

Additionally, CMS proposes:

  • To adopt three new MVPs for the CY 2027 performance period, including Diabetic Disease, Hospitalist, and Hypertension. 
  • To include virtual groups in MVP reporting beginning in the CY 2029 performance period/2031 MIPS payment year.
  • To modify all 27 existing MVPs by incorporating the applicable MIPS core measures discussed below, adding measures that expand relevant clinical concepts and specialties, addressing public maintenance requests, and removing measures and activities proposed for elimination or replacement.

CMS Proposes Several Updates to the MIPS Quality, Cost, and Improvement Activities Performance Categories

Pages 915-954

CMS proposes several updates to the MIPS quality, cost, and improvement activities performance categories, including:

  • To update the operational list of care episode and patient condition groups and codes to reflect changes to service and diagnosis codes that define care episodes and patient condition groups, as identified through the annual maintenance of episode-based measures.
  • To add six new improvement activities to the Care Coordination and Advancing Health and Wellness performance categories, modify five existing improvement activities currently specified for the performance category, and remove 11 improvement activities currently specified for the performance category beginning with the CY 2027 performance period/2029 MIPS payment year.
  • To establish a MIPS core-measure designation and, beginning with the CY 2027 performance period, replace the existing requirement to report an outcome or high-priority measure under traditional MIPS and MVPs with a requirement to report an applicable MIPS core measure.

To establish a measure set inventory of 180 MIPS quality measures including 20 measure removals, 10 measure additions for CY 2027, one addition for CY2028, and 43 substantive changes to existing measures.

CMS is  not proposing any new MIPS cost measures nor removing or substantially changing any MIPS cost measures for the CY 2027 performance period/2029 MIPS payment year.

Promoting Interoperability Performance Category

Pages 955-1023

CMS proposes to update the MIPS Promoting Interoperability measure inventory to reduce burden while continuing to advance CMS’s goal of meaningful use of CEHRT.

First, CMS proposes to modify and update the definition of CEHRT to align with the definition included in ONC’s HTI-5 proposed rule.[2] The proposal to update the definition of CEHRT in the QPP is not contingent on any final action taken by ONC.  

To reduce administrative burden, CMS proposes removing the required ONC Direct Review and the optional ONC-Authorized Certification Bodies (ACB) Surveillance Attestation beginning with the CY 2026 performance period/2028 MIPS payment year. While CMS is removing these, the agency states that it will work with ONC to support the ONC Health IT Certification Program to continue to support mechanisms important for mitigating issues with health IT.

CMS also proposes the following changes to the Promoting Interoperability measure inventory:

  • Remove the Security Risk Analysis measure beginning with the CY 2027 performance period/2029 MIPS payment year to reduce reporting burden, as MIPS eligible clinicians are already covered entities under the HIPAA Security Rule and removal would not weaken cybersecurity requirements.
  • Adding a new Electronic Prior Authorization for Prescription Drugs measure to improve the timeliness and transparency of medication access. The measure would assess MIPS eligible clinicians’ use of standards-based electronic prior authorization and CMS proposes it would initially require an attestation of a “Yes” or “No” response.
  • Make the existing Electronic Prior Authorization measure optional for the CY 2027 performance period and require reporting beginning with the CY 2028 performance period. CMS also proposes revising the measure description from “using CEHRT” to “using data from CEHRT” to clarify that clinicians must use certified health IT when necessary to support electronic prior authorization. Beginning in CY 2028, CMS proposes further revising the measure to require the use of applicable Health IT Modules.

Proposed scoring for the optional CY 2027 Electronic Prior Authorization measure, including the availability of bonus points, is discussed separately in the MIPS scoring section below.

Request For Information: Fast Healthcare Interoperability Resources®-Based Digital Quality Measurement

Pages 908-914

CMS is requesting feedback on a future transition to FHIR-based digital reporting for QPP. Specifically, CMS is looking for information on overall transition timeline and approach, any factors affecting readiness for FHIR-based reporting, key milestones, and any technical assistance needed by organizations and whether this would vary across different environments.[3] Any future transition would occur through notice and comment rulemaking, but CMS is seeking input on a potential 2-year transition period, beginning with the CY/FY 2028 performance period and becoming mandatory in CY/FY 2030 performance period. CMS anticipates that the transition would begin with a limited set of measures and then expand overtime. 

CMS Proposes Targeted Updates to the APM Performance Pathway and APP Plus Measure Sets

Pages 902-907

CMS proposes several changes to the APP and APP Plus quality measure sets beginning with the CY 2027 performance period. The APP is available to MIPS eligible clinicians participating in MIPS APMs and is the required quality reporting pathway for Medicare Shared Savings Program ACOs, while APP Plus is an optional, expanded measure set aligned with CMS’s Adult Universal Foundation.

CMS proposes specification updates to three existing measures addressing diabetes control, depression screening and follow-up, and hospital-wide readmissions. CMS also proposes removing two measures previously scheduled for addition to APP Plus—Initiation and Engagement of Alcohol and Other Drug Dependence Treatment and Adult Immunization Status—citing operational challenges, stakeholder concerns, and the resources ACOs are devoting to digital quality measurement and data aggregation.

As revised, the CY 2027 APP Plus measure set would include eight measures addressing diabetes control, cancer screening, depression screening, blood pressure control, patient experience, hospital readmissions, and admissions among patients with multiple chronic conditions. [4] CMS also proposes establishing a new Medicare electronic clinical quality measure collection type for Shared Savings Program ACOs reporting APP Plus beginning with the CY 2027 performance year. Proposed scoring and benchmarking policies for Medicare CQMs and the new Medicare eCQM collection type are discussed separately below.

CMS Proposes New Scoring Policies for MIPS Core Measures

Pages 1024-1048

CMS proposes several changes to MIPS quality scoring, benchmarking, and Promoting Interoperability policies:

  • Core measure reporting: As discussed above, CMS proposes to require clinicians—other than those in small practices—to report an applicable MIPS core measure beginning with the CY 2027 performance period/2029 MIPS payment year. Clinicians without an applicable core measure could attest to that fact. Otherwise, failure to report a core measure would result in zero achievement points for one measure. Small practices would be exempt, and a voluntarily reported core measure would count only if it is among the practice’s highest-scoring measures.
  • Topped-out measures: CMS proposes to exempt MIPS core measures that have been topped out for at least two consecutive years from the standard seven-point cap and instead score them from one to 10 points using the topped-out benchmark methodology. CMS would extend this policy to 17 topped-out measures used by specialties or MVP participants with limited measure options and publish the annually updated list on the QPP website.
  • Medicare CQM and eCQM benchmarks: For the APP and APP Plus measures discussed above, CMS proposes to continue using flat benchmarks for all Medicare CQMs reported by Shared Savings Program ACOs beginning with the CY 2026 performance period/2028 MIPS payment year. Flat benchmarks would also apply to measures reported through the new Medicare eCQM collection type beginning with the CY 2027 performance period/2029 MIPS payment year.
  • Electronic prior authorization bonus: In connection with the Electronic Prior Authorization measure described above, CMS proposes that clinicians could earn 10 bonus points in the Promoting Interoperability category for the CY 2027 performance period by attesting that they used certified technology to submit at least one electronic prior authorization request for a non-drug medical item or service through a payer’s Prior Authorization API.
  • Future MVP scoring: As CMS prepares for full MVP implementation beginning with the CY 2029 performance period, the agency seeks comment on whether clinician scores should be normalized within each MVP, whether normalization should occur at the final-score or performance-category level, and whether a revised methodology should be tested before full implementation.

CMS Proposes to Update Requirements for Third-Party Intermediaries

Pages 1050-1064

CMS proposes several updates to requirements for QCDRs and qualified registries, including:

  • Requiring performance feedback to be provided at the same participation level at which data are submitted, such as the individual, group, subgroup, virtual group, or APM Entity level.
  • Requiring intermediaries with fewer than 10 participants to audit all participants and, when a participant has fewer than five patient records, to audit all available records.
  • Requiring intermediaries that did not submit MIPS data during the prior year to submit a participation plan describing how they intend to encourage future submissions.
  • Requiring QCDRs and qualified registries to support at least six quality measures, including one MIPS core measure, beginning with the CY 2027 performance period.
  • Prohibiting changes to costs, services, and other information after the intermediary’s qualified posting is published in the QPP Resource Library.
  • Allowing CMS to terminate intermediaries that fail to submit data and cannot document contracts with participants expected to report during the applicable performance period.

CMS also proposes to clarify that health IT vendors may not submit MIPS data as third-party intermediaries beginning with the CY 2025 performance period unless they separately qualify as a QCDR or qualified registry. Health IT vendors could continue providing technology that enables clinicians and groups to submit their own data.

CMS Proposes to Update MIPS Reweighting Policies

Pages 1064-1069

CMS proposes two changes to MIPS performance category reweighting:

  • Automatic extreme and uncontrollable circumstances: Beginning with the CY 2027 performance period/2029 MIPS payment year, CMS would use the most current and reliable location data available—not solely Provider Enrollment, Chain and Ownership System (PECOS) addresses—to identify clinicians affected by disasters or public health emergencies. CMS may use service-location ZIP codes from claims data in addition to, or instead of, PECOS information.
  • Third-party intermediary submission failures: Beginning with the CY 2025 performance period/2027 MIPS payment year, CMS would extend the deadline from November 1 to December 31 for clinicians to request reweighting when a third-party intermediary failed to submit quality measure, improvement activities, or Promoting Interoperability data for reasons outside the clinician’s control. Clinicians would still need documentation of a written agreement showing that the intermediary was responsible for submitting the data.

CMS Proposes to Expand Public Reporting of MVP Performance Information

Pages 1070-1076

CMS proposes to remove the current restriction that prevents first-year public reporting of new improvement activities and Promoting Interoperability measures included in an MVP. Under the proposal, eligible performance information for these measures and activities would be publicly reported on Medicare’s Compare Tool during their first year in the program, consistent with CMS’s broader MIPS public reporting policies.

CMS Seeks Comment on Revisions to Clinician Star Ratings

CMS requests feedback on replacing the current equal-ranges methodology used to assign star ratings for administrative claims quality measures with a standard-deviation-based approach. CMS also seeks comment on applying a similar approach to cost measures and on potential unintended consequences, with possible rulemaking in the CY 2028 PFS.

Advanced APMs

Pages 1077-1093

CMS proposes several updates to Advanced APM policies intended to better align financial incentives with actual participation, clarify QP determinations, and incorporate recent statutory changes. Key proposals include:

  • Apply QP and Partial QP status only to the clinician’s TIN/NPI combinations participating in the Advanced APM. Under the proposal, the higher QP conversion factor, APM Incentive Payment, and Partial QP MIPS opt-out would not extend to the clinician’s services billed through nonparticipating TINs.
  • Make a technical correction clarifying when termination from an Advanced APM disqualifies clinicians from QP status before the entity bears financial risk. CMS also proposes that APMs without an operationally practicable Participation List would not be used for QP determinations or MIPS APM scoring.
  • Codify the statutory 3.1 percent APM Incentive Payment for payment year 2028 and restructure the regulations to more clearly list the applicable payment percentages by year. CMS would also update the definition of APM Incentive Payment to avoid listing specific payment years.
  • Issue conforming regulatory updates to reflect statutory QP and Partial QP thresholds under the Medicare and All-Payer Combination Options. The thresholds would increase in payment year 2027, decrease temporarily in payment year 2028, and generally return to the higher levels beginning in payment year 2029.

[1] All page numbers listed are from the unpublished proposed rule.

[2] 90 FR 60970

[3] Detailed questions are outlined on page 912-914 of the unpublished proposed rule.

[4] See Table C-BC2 on page 907 of the unpublished proposed rule.