What the proposed transition from traditional MIPS to MVP-based reporting could mean for physician practices, quality teams, multispecialty groups, and health IT leaders.
If your practice currently participates in MIPS, the CMS CY 2027 Medicare Physician Fee Schedule proposed rule gives you a defined timeline for preparing for a major change in Medicare quality reporting.
CMS is proposing to end traditional MIPS after the CY 2028 performance period. If finalized, clinicians who are not participating in a MIPS Alternative Payment Model (APM) would transition to MIPS Value Pathways (MVPs) beginning with the CY 2029 performance period.
The transition is not just a 2029 issue. For the CY 2027 performance period, CMS is proposing three new MVPs, revisions to all 27 existing MVPs, and new MIPS Core Measures. The proposal also includes changes to Promoting Interoperability, Improvement Activities, APM policies, and other Quality Payment Program (QPP) provisions.
For practice administrators, quality leaders, clinicians, and IT teams responsible for MIPS reporting, the immediate question is not simply what CMS is changing. It is what those changes mean for your reporting workflow, measure selection, technology, and preparation for the 2029 transition.
This guide breaks down the proposed changes and the practical steps MIPS practices can take now.
This guide is primarily for organizations that already participate in MIPS or manage MIPS reporting, including:
If your organization does not participate in MIPS, many of these changes may not directly affect your current reporting obligations.
The proposed rule has four major implications for practices:
Traditional MIPS would sunset after the CY 2028 performance period under the proposal.
CMS proposes three new MVPs for the 2027 performance period.
All 27 previously finalized MVPs would be revised.
CMS proposes new Core Measure requirements beginning in 2027.
There are also proposed changes to Promoting Interoperability, Improvement Activities, APM policies, and Medicare physician payment.
The Merit-based Incentive Payment System (MIPS) adjusts Medicare Part B payments based on clinician performance across four categories:
Traditional MIPS has historically given clinicians a broad inventory of measures and activities from which to select.
MIPS Value Pathways, or MVPs, take a more focused approach. An MVP connects measures and activities around a particular specialty, clinical condition, or patient population.
CMS describes MVPs as the next evolution of MIPS reporting, with the proposed rule establishing MVPs as the primary reporting option following the sunset of traditional MIPS.
For practices, this means MIPS reporting would become more closely connected to the clinical areas in which their clinicians practice.
This is the central structural change in the proposed rule.
CMS proposes to sunset traditional MIPS after the CY 2028 performance period. Until then, clinicians would continue to have existing reporting options, including traditional MIPS, MVPs, and the APM Performance Pathway (APP), where applicable.
If finalized as proposed, beginning with the CY 2029 performance period, clinicians who are not participating in a MIPS APM would report through MVPs. Clinicians participating in a MIPS APM would continue using the APP.
If your practice currently uses traditional MIPS, 2027 and 2028 should be treated as transition years.
Your practice should begin determining:
The proposed timeline gives practices time to make these changes before traditional MIPS is scheduled to sunset.
CMS proposes adding three new MVPs for the CY 2027 performance year:
If finalized, these additions would bring the proposed MVP inventory to 30 pathways, consisting of 27 existing MVPs with proposed revisions plus the three new pathways.
These new pathways may be particularly relevant to primary care, hospital medicine, endocrinology, cardiology, and other practices whose patient populations align with diabetes or hypertension care.
Practices should review the proposed measure specifications rather than assuming that their current reporting strategy will remain the best fit.
CMS is not simply adding new pathways. The proposed rule would also revise all 27 previously finalized MVPs.
The proposed revisions include changes such as:
If your practice already reports an MVP, do not assume your 2027 measure set will be identical to your current one.
Your quality team should review:
CMS proposes introducing MIPS Core Measures beginning with the 2027 performance period.
Under the proposal:
Which applicable Core Measure belongs in our reporting strategy, and can our EHR or registry capture the required data?
Multispecialty organizations face an additional operational consideration.
CMS's current QPP guidance states that, beginning in 2026, multispecialty groups that are not small practices and intend to report an MVP must report as subgroups or individuals. Small multispecialty practices retain the ability to report an MVP as a group without forming subgroups.
This means MVP planning can involve more than selecting a pathway.
For a multispecialty organization, the practice may need to map:
Your organization should determine:
CMS is also proposing changes to the Promoting Interoperability (PI) performance category.
CMS proposes removing the Security Risk Analysis measure from the MIPS PI scoring calculation.
This would not eliminate the underlying HIPAA security requirements. Those obligations remain separate from MIPS reporting.
Electronic prior authorization is another important area for practices to monitor.
CMS's current policy makes the Electronic Prior Authorization measure an optional bonus measure for MIPS-eligible clinicians in CY 2027, with the measure scheduled to become mandatory beginning with CY 2028.
For practices, this makes health IT planning part of the broader MIPS strategy.
Your team should understand:
CMS proposes changes to the Improvement Activities inventory for 2027.
The proposal includes new, modified, and removed activities, with proposed options addressing areas such as artificial intelligence, social drivers of health, and advance care planning.
For practices, the important issue is not simply how many activities are added or removed.
It is whether your existing Improvement Activities strategy will continue to fit the MVP and clinical areas selected by your organization.
Your team should therefore reassess Improvement Activities alongside Quality measures rather than treating the two categories as completely separate workstreams.
The MIPS changes are occurring alongside proposed updates to the Medicare Physician Fee Schedule.
CMS's CY 2027 proposal includes changes to physician payment policies in addition to the QPP changes discussed above.
For practices, the important point is that MIPS reporting strategy and Medicare reimbursement planning should not be viewed as completely separate issues.
Rather than assuming a specific financial outcome, practices should model how different MIPS performance scenarios could affect their Medicare revenue.
The proposed transition to MVPs has also generated debate among healthcare stakeholders.
CMS's stated rationale is that MVPs can move MIPS away from fragmented reporting toward more clinically meaningful, specialty-focused quality measurement.
Physician organizations have raised concerns about administrative burden, subgroup reporting, and the proposed sunset of traditional MIPS.
Because this remains a proposed rule, those concerns are part of an ongoing regulatory process, and provisions may change before CMS issues the final rule.
Practices should not wait until 2029 to begin preparing.
Document how each eligible clinician currently participates in the QPP.
Identify whether clinicians are reporting through:
Review the proposed MVPs and identify pathways that align with your clinicians.
For each potential MVP, evaluate:
If you operate a multispecialty organization, determine how subgroup reporting affects your MIPS strategy.
Map your TIN, subgroups, clinicians, MVPs, measures, and data sources to identify potential reporting gaps.
Ask your EHR, qualified registry, or QCDR vendor:
Do not automatically carry your current measure strategy into 2027. Review proposed changes and determine whether your existing measures remain available and appropriate.
Pay particular attention to the proposed Core Measure requirement, and evaluate how to maximize your MIPS quality score.
If traditional MIPS remains available through 2028 as proposed, practices have time to use these performance years to prepare for the eventual MVP transition.
This could include:
The CY 2027 proposed rule was released on July 14, 2026, and the public comment period closed September 14, 2026. CMS will issue a final rule after the proposed-rule process.
Practices should monitor the final rule for changes to the MVP transition timeline, Core Measures, Promoting Interoperability, Improvement Activities, subgroup reporting, and Medicare payment policies.
Proposed introduction of 3 new MVPs (bringing total to 30), revisions to all 27 existing MVPs, new MIPS Core Measure requirements, and initial optional phase for Electronic Prior Authorization. Practices should map clinicians and test workflows.
Proposed final performance period for traditional MIPS. Electronic Prior Authorization measure scheduled to become mandatory in Promoting Interoperability. Final trial period to transition remaining clinicians to MVPs or APMs.
Proposed complete sunset of traditional MIPS. Non-APM clinicians are required to report via MVPs. Multispecialty groups must report via subgroups or individuals.
CMS has proposed sunsetting traditional MIPS after the CY 2028 performance period. Because this is a proposed rule, the timeline must be confirmed in the final rule.
CMS proposes adding three new MVPs: Diabetic Disease, Hypertension, and Hospitalist.
A Core Measure is a designated quality measure within an MVP that CMS proposes requiring clinicians to report as part of their MVP quality measure selection, unless an exemption or attestation applies.
Yes, under the proposed rule, small practices would be exempt from the Core Measure requirement.
Under current QPP guidance, starting in 2026, multispecialty groups that are not small practices and choose to report an MVP must report as subgroups or individuals.
The CMS CY 2027 proposed rule signals a clear direction toward structured, clinical-specialty reporting via MVPs. By starting early, auditing current baselines, mapping clinicians to pathways, and engaging IT vendors, your practice can turn this transition into a smooth, manageable process well ahead of the proposed 2029 deadline.
Medical Office Force AI assistant
For more information, write to contact@medicalofficeforce.com
Share Your Thoughts
No comments yet — be the first to comment!