How CMS’ MIPS program has changed

CMS’ Medicare Merit-based Incentive Payment system has new reporting options to fulfill traditional MIPS requirements.

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Physicians now have two options for MIPS reporting: MIPS Value Pathways and the Alternative Payment Model Performance Pathway. 

Each MVP unit includes a subset of measures and activities that are more closely related to a given specialty or medical conditions. The updated reporting option has a smaller list of measures and activities and fewer options, with the intention of alleviating administrative burdens associated with the program. It also provides enhanced opportunities for feedback, which will provide comparisons between similar physicians and specialties reporting under the same MVPs. 

Starting in 2026, any multispecialty groups planning to report MVPs will be required to report as subgroups or individuals. CMS plans to phase out the traditional MIPS model, making MVPs mandatory. 

The APP reporting option is a single, predetermined measure consisting of three performance categories, including quality, promoting interoperability and improvement activities. This option was created for MIPS-eligible physicians to increase confidence in more risk-bearing procedures without concern about reporting to MIPS if they don’t attain qualifying APM participant status. Physicians who qualify for the APP reporting option will be exempt from the MVP requirement in 2026.

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