Your 2026 MIPS Score Will Hit Your 2028 Payments: Why Traditional MIPS Is Running Out of Road

Healthcare practice management team reviewing performance data together

For many medical groups, MIPS reporting still feels like an annual submission task: choose measures, collect data, send the report, and move on.

That approach is becoming less reliable.

Your 2026 MIPS performance score will affect Medicare payments in 2028. At the same time, the Centers for Medicare & Medicaid Services is proposing a broader shift away from traditional MIPS and toward MIPS Value Pathways, or MVPs.

The result is a planning issue for every MIPS-eligible group practice:

  • Reporting something does not necessarily produce a strong score.
  • A missed case minimum or data completeness requirement can reduce performance.
  • A measure that does not fit your specialty may create work without meaningful value.
  • Traditional MIPS may be available only through the 2028 performance year under the current proposal.

The goal is not to create unnecessary urgency. It is to help your practice connect compliance work with revenue integrity, operational accountability, and measurable practice outcomes.

Why 2026 Reporting Affects 2028 Payments

MIPS uses a delayed payment structure. The performance year comes first, and the resulting payment adjustment is applied approximately two years later.

That means:

2026 performance year → 2028 payment year

For the 2026 performance year, the MIPS performance threshold is 75 points.

  • A final score below 75 points may result in a negative adjustment.
  • A score of exactly 75 points results in a neutral adjustment.
  • A score above 75 points may qualify for a positive adjustment.

MIPS payment adjustments are budget-neutral. Positive adjustments are funded by negative adjustments from other participating clinicians. The potential range is roughly -9% to +9%, although the exact positive adjustment depends on the distribution of scores and the scaling factor.

The adjustment applies to covered professional services under the Medicare Physician Fee Schedule. The Centers for Medicare & Medicaid Services explains the payment mechanics through its MIPS Payment Adjustments guidance.

For practice owners, the important point is simple: your 2026 reporting decisions are connected to your 2028 Medicare revenue.

Healthcare professionals reviewing charts and operational reports in a collaborative meeting

The Four MIPS Categories in Plain Terms

Traditional MIPS combines four performance categories. Each category evaluates a different part of practice operations.

1. Quality

Quality measures evaluate clinical care processes and outcomes. Depending on your specialty, measures may address preventive care, chronic disease management, screening, patient safety, or care coordination.

Your practice can influence Quality through:

  • Accurate clinical documentation
  • Consistent workflows
  • Appropriate measure selection
  • Reliable patient outreach
  • Complete data capture
  • Timely follow-up on gaps in care

For 2026, Quality accounts for 30% of the traditional MIPS score.

2. Promoting Interoperability

Promoting Interoperability evaluates how eligible clinicians use certified electronic health record technology to exchange information and support patient care.

Your practice can influence this category through:

  • Electronic health record configuration
  • Patient access workflows
  • Health information exchange
  • Security risk analysis
  • Timely reporting and attestation
  • Staff training

Promoting Interoperability accounts for 25% of the traditional MIPS score in 2026.

3. Improvement Activities

Improvement Activities measure structured efforts to improve clinical or operational processes.

Examples may include:

  • Care coordination programs
  • Patient safety initiatives
  • Behavioral health integration
  • Emergency preparedness
  • Health equity activities
  • Engagement with underserved populations

Your practice controls much of this category, but documentation matters. Completing an activity without preserving the required evidence can create a reporting problem later.

Improvement Activities account for 15% of the 2026 traditional MIPS score.

4. Cost

Cost measures evaluate Medicare spending related to attributed episodes or patient care. CMS calculates many Cost measures from claims data rather than from a practice’s direct submission.

Your practice does not control every factor in the Cost category. However, clinical decisions, referral patterns, care coordination, avoidable emergency department utilization, and follow-up processes can influence the underlying cost picture.

Cost accounts for 30% of the 2026 traditional MIPS score.

This is why MIPS should not be managed as a reporting department issue alone. Clinical, administrative, technology, billing, and compliance workflows all affect the final result.

Why “We Report Something” Is Not the Same as Scoring Well

A practice can submit data and still fall short of its revenue and compliance goals.

Common problems include:

  • Selecting measures that do not match the specialty or patient population
  • Failing to meet a measure’s case minimum
  • Falling below data completeness requirements
  • Using an electronic health record configuration that does not capture the needed fields
  • Submitting improvement activity documentation without sufficient evidence
  • Waiting until the March submission window to resolve data problems
  • Failing to review the preliminary score
  • Treating every clinician in a group as if they had the same workflow

MIPS performance depends on the details behind the submission. A measure may appear appropriate but produce limited value if the practice does not have enough eligible cases. Another measure may be clinically relevant but difficult to document consistently across providers.

The practice needs a process for checking performance during the year, not just preparing a file at the end.

Small Practice Flexibilities Still Matter

Small practices with 15 or fewer clinicians retain important flexibilities for the 2026 performance year.

These include:

  • A 3-point floor for Quality measures that miss case minimums or data completeness requirements
  • 6 bonus points for submitting at least one Quality measure
  • The ability for small multispecialty practices to report an MVP as a group without the mandatory subgroup registration that larger practices face

These flexibilities can reduce risk, but they do not replace planning. A small group still needs to understand which measures apply, what data the electronic health record can produce, and whether the submission supports the practice’s broader clinical goals.

A practice should also confirm its eligibility and reporting requirements through the Quality Payment Program.

The Strategic Shift Toward MIPS Value Pathways

MIPS Value Pathways organize reporting around a specialty, clinical condition, or defined care model. The intent is to make reporting more connected to the work a practice already performs.

The CY 2027 Physician Fee Schedule proposed rule would:

  • Keep the 75-point performance threshold
  • Replace the outcome or high-priority measure requirement with a mandatory MIPS core measure
  • Exempt small practices from the mandatory core measure requirement
  • Require other practices to attest when no core measure applies
  • Add three new MVPs: Diabetic Disease, Hypertension, and Hospitalist
  • Increase the total number of MVPs to 30
  • Modify all 27 existing MVPs
  • Sunset traditional MIPS after the 2028 performance year

These changes remain proposals as of early October 2026. The final rule has not been released, so practices should not treat the proposed requirements as final.

The transition still creates a clear planning signal. Groups should begin asking:

  • Which MVP best reflects our specialty and patient population?
  • Does our electronic health record capture the necessary data?
  • Which providers should report together?
  • What clinical and administrative workflows need to change?
  • Can our billing, compliance, and reporting teams review performance throughout the year?

The Centers for Medicare & Medicaid Services provides additional information about the proposed changes through its CY 2027 Physician Fee Schedule proposed rule summary.

Practice leadership team reviewing compliance and performance planning

A Practical Checklist for the 2026 Reporting Year

Use this checklist to move from annual submission activity to active performance management.

Confirm your reporting position

  • Verify MIPS eligibility for each clinician.
  • Confirm whether your practice reports individually, as a group, or through another pathway.
  • Review small-practice flexibilities if your group has 15 or fewer clinicians.
  • Identify any exclusion, exception, or special status that applies.

Build a measure plan

  • Select Quality measures that match your specialty and patient population.
  • Confirm case minimums and data completeness requirements.
  • Review Promoting Interoperability requirements before the reporting period closes.
  • Document Improvement Activities as they occur.
  • Understand how Cost measures may reflect referral and care coordination patterns.

Review your systems

  • Check electronic health record measure configuration.
  • Confirm that required clinical fields are captured consistently.
  • Align charge capture, documentation, and quality workflows.
  • Assign ownership for data validation and submission.
  • Create a schedule for internal reviews.

Prepare before the submission window

  • Do not wait until the March submission period to identify missing data.
  • Reconcile provider-level and group-level information.
  • Review measure performance before final submission.
  • Check your preliminary score when available.
  • Use targeted review or correction opportunities when appropriate.

For practices that need operational support across reporting, documentation, billing, and compliance, Healthcare Business Connection’s Revenue Cycle Management services can support full-cycle or targeted workflow reviews. Our Compliance and Training services can also help make expectations visible and actionable for staff.

“We needed a clearer connection between what our staff documented, what our systems captured, and what we submitted. Once those responsibilities were visible, our reporting process became much easier to manage.”

  • HBC client practice administrator

What the Traditional MIPS Phase-Out Means for Planning

If the proposed rule becomes final, traditional MIPS would remain available through the 2028 performance year and sunset after that year. MVPs or the APM Performance Pathway would become the primary reporting routes beginning with the 2029 performance year.

That does not mean every practice needs to redesign its reporting program immediately. It does mean that continuing to repeat the same measures out of habit is not a long-term strategy.

A stronger approach is to:

  1. Protect the 2026 reporting year and the 2028 payment year.
  2. Review the proposed MVP options that fit your practice.
  3. Identify gaps in documentation, electronic health record configuration, and staff ownership.
  4. Connect MIPS reporting with revenue cycle management and compliance processes.
  5. Use performance data to improve care workflows, not simply to complete a submission.

The most useful MIPS process is one that supports both compliance and practice performance. When reporting aligns with clinical work, administrative ownership, and revenue integrity, your group gains better visibility into the decisions affecting its future.

Book a free 15-minute back-office checkup with instant scheduling to review where your MIPS reporting, compliance, and revenue workflows may need stronger coordination.