CMS Quality Reporting Changes in 2026: What Hospitals Need to Know

The year 2026 represents a pivotal moment for hospital quality reporting. CMS is implementing major changes across multiple quality programs, affecting approximately 4,000 hospitals as they navigate expanded eCQM requirements, evolving MIPS and MVP frameworks, and tighter performance thresholds.

If your quality team is already stretched thin managing current reporting obligations, 2026 will demand even more. This guide breaks down exactly what's changing, why it matters, and how to prepare your hospital for CMS 2026 quality program changes without overwhelming your team.

Key CMS Updates Hospitals Can Expect in 2026

CMS has finalized several significant rule changes that will reshape how hospitals approach quality reporting starting in 2026. These aren't minor tweaks; they represent meaningful shifts in reporting requirements, performance expectations, and payment implications. Here's what you need to know about the major categories of change.

Expanded eCQM Requirements

Electronic clinical quality measures (eCQMs) are becoming the backbone of hospital quality reporting, and CMS 2026 updates significantly expand these requirements.

CMS is incrementally increasing mandatory eCQM requirements from six eCQMs in 2024 to eight in 2026, then to nine in 2027, and finally to 11 by 2028. For 2026 specifically, hospitals must report on three mandatory eCQMs plus five self-selected measures for a total of eight.

The newly required eCQMs focus heavily on Hospital Harm (Patient Safety) measures. The newly required eCQMs are Hospital Harm – Hypoglycemia and Hospital Harm – Hyperglycemia. CMS is clearly signaling that patient safety will dominate quality measurement moving forward.

Additionally, hospitals undergoing audits will have their eCQMs assessed for data accuracy, with a minimum acceptable accuracy threshold set at 75%. This means your eCQM data needs to match what's actually in your medical records—no more submitting data you haven't thoroughly validated.

Why this matters: Hospitals with weak EHR workflows or inconsistent documentation will struggle to meet these thresholds. The 75% accuracy requirement isn't aspirational—it's the minimum to avoid penalties.

Adjustments to MIPS + MVP Reporting

For clinicians and medical groups participating in the Merit-based Incentive Payment System (MIPS), 2026 brings both stability and strategic shifts toward MIPS Value Pathways (MVPs).

Performance Threshold Stability: CMS is maintaining the performance threshold at 75 points through the 2028 performance year. While this provides predictability, it also means there's no room for complacency—you need 75 points minimum to avoid penalties.

MVP Expansion: CMS finalized 6 new MVPs for the 2026 performance period related to diagnostic radiology, interventional radiology, neuropsychology, pathology, podiatry, and vascular surgery. This brings the total number of MVPs to 27, providing more specialty-specific reporting pathways.

Subgroup Reporting Changes: Beginning in 2026, multispecialty groups face new requirements. Multispecialty groups with 25-plus clinicians must use subgroup reporting in MVPs starting in 2026, though multispecialty small practices (15 or fewer clinicians) may continue to report at the group level.

Why this matters: MVPs are becoming the primary reporting pathway, CMS continues to expand MVP participation and encourage organizations to evaluate specialty-specific reporting pathways.. Organizations that haven't started planning for MVP adoption should treat 2026 as a transition year.

APP (Alternative Payment Program) Modernization

The Alternative Performance Pathway (APP) and other alternative payment programs are evolving to emphasize population health management and digital quality measures.

Increased Reliance on eCQMs and Digital Submission: APP participants will face similar eCQM expansion as hospital programs, with growing emphasis on automated data collection through APIs and FHIR-based reporting.

Revised Measures for ACOs: CMS is modifying the Shared Savings Program quality performance standard, including removing the health equity adjustment applied to an ACO's quality score beginning in performance year 2026. This represents a significant policy shift that will change how ACOs are evaluated.

Population Health Focus: APP models increasingly require organizations to demonstrate they're managing entire populations effectively, not just individual patient encounters. This means tracking patients across care settings, managing transitions, and preventing avoidable hospitalizations.

Why this matters: ACOs and APP participants need robust data infrastructure that goes beyond what traditional fee-for-service reporting requires. If your systems can't track patients across settings or identify care gaps proactively, you'll struggle with APP requirements.

What These Changes Mean for Your Hospital

Understanding what's changing is one thing, understanding what it means for your daily operations is another. Here's the practical impact:

More Lift for Quality Departments: Expanding from six to eight eCQMs doesn't sound dramatic, but it represents a 33% increase in reporting burden. Your quality team will need more time for data validation, measure selection, and submission management.

Data Aggregation Challenges: As measure counts increase, the complexity of pulling data from multiple systems grows exponentially. You're not just collecting more data—you're managing more interdependencies, more validation checks, and more potential failure points.

Increased Dependency on EHR Performance: The shift toward eCQMs and digital measures makes your EHR the single most critical system for quality reporting. If your EHR can't accurately capture, store, and extract quality data, you're facing major compliance risk.

Higher Penalty Risk: Hospitals that do not submit quality data or do not meet all Hospital IQR Program requirements are subject to a one-fourth reduction in their Annual Payment Update. For an average hospital, this could mean $1-2 million in lost revenue annually.

Shift Toward Interoperability + Automation: Manual processes may become increasingly difficult to sustain as reporting requirements continue to expand. Hospitals need automated data extraction, validation workflows, and submission management to keep pace.

Preparing Your eCQM Reporting Strategy for 2026

Getting ready for expanded eCQM requirements requires more than just knowing the measure specifications; it requires building infrastructure and processes that can scale as requirements grow.

Strengthen Your Data Validation Workflow

Address Chart Abstraction Alignment: With the new 75% accuracy threshold for eCQM validation, the data submitted through eCQMs must accurately reflect the documentation contained within the medical record. Conduct regular audits comparing eCQM output to manual abstraction to identify discrepancies early.

Implement Monthly Data Quality Checks: Don't wait until submission time to discover data problems. Run monthly reports that check:

• Completeness of required data elements
• Logic errors in measure calculations
• Outliers that might indicate coding or documentation issues
• Missing linkages between related data points

Reduce Measure Errors Early: Create feedback loops with clinical staff so they understand how their documentation affects quality measures. When nurses or physicians see specific examples of how incomplete documentation hurts measure performance, they're more likely to fix the underlying issue.

Start Preparation Before Q1 2026

Begin Multi-Quarter Readiness: Quality reporting isn't a Q4 activity anymore. Start working on your 2026 strategy now:

• Q4 2025: Finalize measure selection, validate EHR workflows, train staff
• Q1 2026: Test data extraction and validation processes with real patient data
• Q2-Q3 2026: Monitor performance, identify improvement opportunities, adjust workflows
• Q4 2026: Final data validation and submission preparation

Build Governance Structure: Establish a cross-functional quality committee that meets monthly and includes representatives from:

• Quality/performance improvement
• IT and EHR support
• Clinical documentation improvement
• Nursing leadership
• Physician champions
• Compliance

This governance structure ensures everyone understands their role and accountability for quality reporting success.

Modernizing Your MIPS + MVP Strategy

For clinicians and medical groups, 2026 requires strategic decisions about how to participate in MIPS and whether to transition to MVPs.

Decide Your Path: Stay in MIPS or Move to MVP

Traditional MIPS remains available in 2026, but CMS is clearly signaling it will eventually be phased out. If you stay in traditional MIPS:

• Pros: Familiar workflows, flexibility in measure selection, established vendor support
• Cons: May become obsolete within 2-3 years, less relevant to specialty-specific care

MVPs offer specialty-aligned measures but require more structured reporting. If you move to MVPs:

• Pros: Measures better reflect your actual practice, potentially easier to achieve high scores, future-proof approach
• Cons: More rigid measure sets, subgroup reporting complexity for large groups, and vendor implementation timeline

CMS continues to expand available MVP options and encourage specialty-focused reporting approaches. The expansion to 27 MVPs and the subgroup reporting requirements strongly indicate MVPs will become mandatory for most participants within the next few years. Organizations that start the transition now will be better positioned than those waiting until the last minute.

Engage Clinicians and Departments Early

MVP success requires clinical buy-in. Start conversations with your physicians and advanced practice providers about:

• Which MVP best aligns with your practice patterns
• What data collection burdens the selected measures create
• How measure performance ties to organizational goals and compensation
• What support clinicians need to improve documentation or workflows

Set realistic expectations about performance targets and timeline. Clinicians are more likely to engage when they understand not just the "what" but the "why" behind quality reporting.

How Hospitals Should Prepare for APP Reporting in 2026

For ACOs and organizations participating in Advanced Primary Care models, 2026 preparation focuses on building population health infrastructure.

Strengthen Care Coordination Systems: APP reporting increasingly evaluates how well you coordinate care across settings. Build systems that:

• Track patients after hospital discharge
• Identify care gaps proactively
• Connect primary care with specialists effectively
• Manage transitions between inpatient and outpatient settings

Invest in Population Health Data: You need visibility into your entire patient population, not just those actively receiving care. This requires:

• Registry systems that track patients with chronic conditions
• Risk stratification tools that identify high-risk patients
• Outreach capabilities to engage patients before problems escalate
• Analytics that show population-level trends and opportunities

Focus on Reporting Infrastructure: CMS revised the definition of a beneficiary eligible for Medicare Clinical Quality Measures for ACOs to reduce burden, but reporting remains complex. Invest in systems that aggregate data from multiple sources and format it for CMS submission requirements.

Technology, Interoperability, and EHR Preparedness

The shift toward digital quality measures makes your technology infrastructure more critical than ever.

Mandatory dQM Alignment Prep: Digital quality measures (dQMs) built on FHIR standards are the future of CMS reporting. CMS sought comment on the anticipated approach to FHIR-based eCQM reporting in quality reporting programs, signaling that this transition is coming soon.

API-Driven Data Extraction: Modern quality reporting increasingly relies on APIs that automatically extract data from EHRs rather than manual file generation. Ensure your EHR vendor supports:

• FHIR APIs for quality measure data
• Automated QRDA file generation
• Real-time data validation
• Secure data transmission to CMS systems

Risks During EHR Transitions: If your hospital is planning an EHR implementation or conversion during 2025-2026, quality reporting becomes exponentially more complex. Historical data may be inaccessible, workflows disrupted, and staff overwhelmed. Build extra buffer time into your reporting timelines and consider seeking external support during the transition.

How Medisolv Helps You Stay Ahead of CMS Changes

Medisolv was built specifically to help hospitals navigate the complexity of evolving CMS quality programs. Our platform and advisory services address every challenge mentioned above:

eCQM Reporting Platform:

• Automated data extraction from your EHR for all required measures
• Real-time validation against current measure specifications
• Submission-ready QRDA files that meet CMS technical requirements
• Performance dashboards showing where you stand before submission

MIPS/MVP Reporting Support:

• Flexible reporting for traditional MIPS or any of the 27 MVPs
• Subgroup management for large multispecialty practices
• Measure selection optimization based on your performance data
• Registry-quality data collection and validation

APP and ACO Support:

• Population health analytics and reporting
• Care gap identification and tracking
• Medicare CQM reporting for Shared Savings Program
• Coordination across multiple quality programs

Advisory Services:

• Expert guidance on navigating regulatory changes
• Quarterly compliance reviews to catch problems early
• Strategic planning for measure selection and improvement
• Training for your quality and clinical teams

Submission Management:

• End-to-end support from data collection through submission
• Deadline tracking and automated reminders
• Technical troubleshooting when issues arise
• Validation and reconciliation before submission

Validation + Analytics:

• Data accuracy verification to meet the 75% threshold
• Performance benchmarking against peer hospitals
• Trend analysis to identify improvement opportunities
• ROI calculations showing financial impact of quality improvements

Conclusion

The CMS 2026 quality program changes represent a significant step up in complexity, data requirements, and performance expectations. Between expanded eCQM requirements, evolving MVP frameworks, and new APP reporting standards, hospitals face mounting pressure to deliver accurate, timely quality data while actually improving patient outcomes.

The organizations that will succeed in 2026 are those preparing now—not scrambling in Q4 when submission deadlines loom. Start by:

1. Auditing your current reporting infrastructure and identifying gaps
2. Building cross-functional governance that brings together quality, IT, and clinical teams
3. Investing in technology that automates data collection and validation
4. Engaging clinicians early so they understand their role in quality success
5. Creating realistic timelines with a buffer for unexpected problems

Medisolv has helped hundreds of hospitals navigate complex quality reporting transitions. Our platform and advisory services provide the infrastructure, expertise, and support you need to meet 2026 requirements without overwhelming your team.

Ready to simplify your approach to CMS 2026 quality reporting?