CMS has released the 2026 PFS Proposed Rule. In this rule, CMS has proposed several changes to the Quality Payment Program (QPP) and the reporting frameworks. In a notable shift from previous years, CMS is proposing a limited number of policies, emphasizing their commitment to program stability while continuing the strategic transformation of healthcare quality measurement.
The three reporting paths under the QPP are Traditional MIPS, MIPS Value Pathways (MVPs), and Alternative Payment Model (APM) Performance Pathway (APP).
CMS proposed changes to each of those reporting frameworks, but in this ruling, it's clear that their primary focus for 2026 is maintaining program stability. After years of significant changes and additions to the QPP, this proposed rule represents a more measured approach, with CMS stating they want to keep their "focus on stability in the program."
CMS continues to signal that MVPs represent the future of MIPS reporting. With 6 new specialty-specific MVPs proposed (Diagnostic Radiology, Interventional Radiology, Neuropsychology, Pathology, Podiatry, and Vascular Surgery), CMS is expanding options for specialists while maintaining their long-term vision. Notably, CMS states they "anticipate that we may be ready to fully transition to MVPs by CY 2029," though they stopped short of proposing a sunset date for Traditional MIPS.
The push toward Electronic Clinical Quality Measures (eCQMs) continues on. CMS explicitly calls eCQMs the "gold standard" collection type that underlies their digital quality measure strategic roadmap. For ACOs, the agency is maintaining the restriction to eCQMs, MIPS CQMs, or Medicare CQMs only, with no return to traditional or the CMS Web Interface.
Perhaps one of the most significant philosophical shifts was CMS's proposal to remove "health equity" from the definition of high-priority measures. Additionally, they're proposing to eliminate the "Achieving Health Equity" subcategory from Improvement Activities, replacing it with "Advancing Health and Wellness." This change, while subtle, signals a broader strategic realignment in how CMS approaches equity initiatives within the QPP framework.
In a move that will provide certainty for providers, CMS proposes to maintain the 75-point performance threshold through the CY 2028 performance period. This three-year commitment to threshold stability represents the kind of predictability providers have requested.
Recognizing the unique challenges faced by smaller practices, CMS is proposing significant flexibility for multispecialty small practices (15 or fewer clinicians) in MVP reporting. These practices would be able to report MVPs as a group without being required to form subgroups – a substantial administrative relief.
CMS is updating several Promoting Interoperability measures to reflect current technology standards, including requiring the use of 2025 SAFER Guides instead of the 2016 version and introducing a new optional bonus measure for Public Health Reporting Using TEFCA (Trusted Exchange Framework and Common Agreement).
There were several other changes they proposed to the program. Here is a slideshow that highlights the key changes in 2026 that you should know about.
As CMS works toward their anticipated 2029 full transition to MVPs, the 2026 proposed rule serves as a bridge year – maintaining stability while laying groundwork for future transformation.
Healthcare organizations should view this proposed rule as an opportunity to solidify their quality reporting strategies, invest in the technological infrastructure needed for digital quality measurement, and prepare for the increasingly specialty-focused future that MVPs represent.
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