CMS 2027 MIPS Proposed Rule: MVP Changes, New Measures, and What Your Practice Needs to Do

Who Is This CMS 2027 MIPS Rule Most Relevant To?

This guide is primarily for organizations that already participate in MIPS or manage MIPS reporting, including:

• Physician practices currently reporting traditional MIPS
• Practices already reporting through an MVP
• Multispecialty groups managing MIPS across different specialties
• Primary care and hospital medicine practices evaluating the proposed new MVPs
• Practice administrators and quality leaders responsible for QPP performance
• IT and EHR leaders supporting quality reporting and interoperability workflows
• Organizations evaluating longer-term MIPS and APM participation strategies

If your organization does not participate in MIPS, many of these changes may not directly affect your current reporting obligations.

What Is Changing for MIPS Practices?

The proposed rule has four major implications for practices:

There are also proposed changes to Promoting Interoperability, Improvement Activities, APM policies, and Medicare physician payment.

MIPS vs. MVPs: What Is the Difference?

The Merit-based Incentive Payment System (MIPS) adjusts Medicare Part B payments based on clinician performance across four categories:

• Quality
• Cost
• Improvement Activities
• Promoting Interoperability

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.

1. Traditional MIPS Would Sunset After 2028

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.

What Does This Mean for Your Practice?

If your practice currently uses traditional MIPS, 2027 and 2028 should be treated as transition years.

Your practice should begin determining:

• Which MVP best aligns with each specialty
• Which clinicians could report under the same MVP
• Which measures your EHR, registry, or QCDR can support
• Whether subgroup reporting affects your organization
• What technology or workflow changes your vendors will need to support

The proposed timeline gives practices time to make these changes before traditional MIPS is scheduled to sunset.

2. CMS Proposes Three New MVPs for 2027

CMS proposes adding three new MVPs for the CY 2027 performance year:

• Diabetic Disease
• Hypertension
• Hospitalist

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.

3. All 27 Existing MVPs Would Be Revised

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:

• Adding MIPS Core Measures
• Expanding measure coverage
• Removing or replacing measures
• Updating specialty and clinical alignments
• Renaming the Rehabilitative Support for Musculoskeletal Care MVP as the Rehabilitative Support MVP

What This Means for Practices Already Using MVPs

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:

• Proposed measure additions
• Proposed measure removals
• New Core Measures
• Changes to Improvement Activities
• Changes affecting data collection
• Potential EHR or registry workflow changes

4. CMS Proposes a New MIPS Core Measure Requirement

CMS proposes introducing MIPS Core Measures beginning with the 2027 performance period.

Under the proposal:

• Each MVP would include designated Core Measures.
• Clinicians would report at least one applicable Core Measure among their required quality measures.
• Clinicians without an applicable Core Measure could use an attestation process and select an alternative quality measure.
• Small practices would be exempt from the proposed Core Measure requirement.

Which applicable Core Measure belongs in our reporting strategy, and can our EHR or registry capture the required data?

5. Multispecialty Practices Need to Consider Subgroup Reporting

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:

• Which clinicians belong in each subgroup
• Which MVP applies to each subgroup
• How performance data will be aggregated
• How the EHR or registry will support subgroup reporting
• Who owns performance monitoring for each subgroup

6. Promoting Interoperability and Electronic Prior Authorization

CMS is also proposing changes to the Promoting Interoperability (PI) performance category.

Security Risk Analysis

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

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:

• Whether your EHR supports the required electronic prior authorization workflows
• Whether your certified health IT meets applicable requirements
• How prior authorization data is captured
• Which clinicians are subject to the applicable requirements
• What implementation work needs to occur before 2028

7. Improvement Activities Would Also Change

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.

What Could the Proposed Rule Mean for Medicare Payments?

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.

What Are Physician Organizations Saying?

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.

What Should Your Practice Do Now?

Practices should not wait until 2029 to begin preparing.

1. Audit Your Current MIPS Baseline

   Document how each eligible clinician currently participates in the QPP.

   Identify whether clinicians are reporting through:

   • Traditional MIPS
   • An MVP
   • An APM pathway

2. Map Clinicians to Potential 2027 MVPs

   Review the proposed MVPs and identify pathways that align with your clinicians.

   For each potential MVP, evaluate:

   • Applicable specialties
   • Quality measures
   • Core Measures
   • Improvement Activities
   • Cost requirements
   • Available data sources
   • EHR and registry support

3. Evaluate Subgroup Reporting Needs

   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.

4. Engage Your EHR and Registry Vendors

   Ask your EHR, qualified registry, or QCDR vendor:

   • Which 2027 MVPs will you support?
   • Which proposed Core Measures can you capture?
   • How will subgroup reporting work?
   • How will electronic prior authorization workflows be supported?
   • When will updated 2027 specifications be available?

5. Reevaluate Your Quality Measure Strategy

   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.

6. Use 2027 and 2028 as Transition Years

   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:

   • Testing MVP workflows
   • Building specialty-specific dashboards
   • Establishing subgroup structures
   • Validating EHR data
   • Training clinicians
   • Identifying reporting gaps
   • Assigning ownership for each measure

7. Monitor the Final Rule

   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.

2027 to 2029 MIPS Transition Roadmap

Frequently Asked Questions