MIPS Value Pathways (MVPs) 2027 Guide for Medical Practices

MIPS Value Pathways in 2027 are still your choice, but that choice now has an end date. The Centers for Medicare & Medicaid Services (CMS) proposes ending traditional MIPS after the 2028 performance period. From 2029, MVPs would be the only MIPS option for clinicians who aren’t in a MIPS Alternative Payment Model (APM), while clinicians in a MIPS APM could keep using the APM Performance Pathway (APP).

That gives you two years, 2027 and 2028, to learn an MVP while the old way still works as a backup.

Most of the 2027 changes in this guide aren’t final yet. CMS shared its proposed rule on July 14 and took public comments until September 14. The final rule was expected around November 1, 2026, but as of November 3 CMS still hadn’t posted it. Whatever CMS finalizes takes effect on January 1, 2027. So every change below says “proposed” or “final,” and you can see at a glance what’s locked in.

The sunset date itself could still move. The American Medical Association (AMA) told CMS in its comment letter that it strongly opposes ending traditional MIPS, and the Patients First Act, a pending bill in Congress, would replace MIPS with a simpler quality program.

Your 2027 work also pays off two years later. CMS ties the 2027 performance period to the 2029 MIPS payment year. In other words, the care you record in 2027 decides whether your Medicare payments go up or down in 2029. Before you plan for that, it helps to see the three ways CMS lets you report.

MVP vs Traditional MIPS vs APP in 2027

An MVP is one of three ways to report MIPS. Think of traditional MIPS as a huge menu where you can pick almost anything, and an MVP as a short menu built around your specialty.

Every item on that menu is a measure. A measure is one specific thing CMS counts to see how your care is going, like how many of your patients with diabetes have a blood sugar level that stays too high. Your MIPS score is built from four groups of measures, and each group checks something different.

Part of your score	What it checks	Example
Quality	How well you care for patients	Patients with diabetes whose blood sugar stays too high
Improvement activities	Projects that make your clinic run better	Offering after-hours or same-day visits
Cost	How much Medicare spends on your patients	Spending per patient compared with similar clinicians
Promoting Interoperability	How you use your electronic health record (EHR) to share information	Sending prescriptions electronically, giving patients online access to their records

With an MVP, you choose a pathway that fits your practice and report fewer quality measures and improvement activities from it. You still report the full Promoting Interoperability measure set, and CMS collects your cost and population health data for you. 

The APP is for clinicians in a MIPS APM, uses a set list of quality measures, and doesn’t score cost.

What you report	Traditional MIPS	MVP	APP
Who uses it	Any clinician who must report	Any clinician who signs up early	Clinicians in a MIPS APM
Quality	6 measures from the full list	4 measures from your MVP	A set list
Improvement activities	Pick from the full list	1 from your MVP	Full credit for now
Cost	CMS scores it	CMS scores your MVP’s cost measures	Not scored
Promoting Interoperability	Full set	Full set	Full set
Sign-up needed	No	Yes	No

The short MVP menu shows up in every category.

 In 2026, MVP users pick 4 quality measures inside their MVP and collect data on them all year. They pick 1 improvement activity from the MVP and do it for at least 90 days in a row. For cost, CMS uses only the cost measures inside your MVP, and you send nothing.

There’s one more piece you never report yourself. CMS scores you on a population health measure in your MVP using claims data, as long as you have enough cases.

All four parts of your score carry the same weight in MIPS and MVPs. In 2026:

• Quality and cost each count for 30%, 
• Improvement activities count for 15%, and 
• Promoting Interoperability counts for 25%. 

Only MVPs allow subgroups, and only traditional MIPS allows virtual groups. That short MVP menu is exactly what CMS plans to rebuild for 2027.

2027 MIPS MVP Changes at a Glance

The number of MVPs would grow from 27 to 30 in 2027. 

CMS proposes three new MVPs called Diabetic Disease, Hospitalist and Hypertension. 

It also wants to update all 27 current MVPs, partly by adding core measure choices to each one, and rename the Rehabilitative Support for Musculoskeletal Care MVP to the Rehabilitative Support MVP.

2027 change	Status	What it means for you
Three new MVPs	Proposed	New options for diabetes, high blood pressure and hospital care
All 27 MVPs updated	Proposed	Check your measure list again
Core measure rule	Proposed	Replaces the outcome measure rule
Quality list cut to 180 measures	Proposed	A measure you use may go away
Improvement activity changes	Proposed	You may need a new activity
Security Risk Analysis measure dropped	Proposed	You still need the review for privacy law
Electronic prior authorization as bonus	Proposed	Becomes required in 2028
No new cost measures	Proposed	Cost scoring stays the same
75-point penalty line	Final through 2028	Same goal as 2026
75% data completeness	Final through 2028	Same goal as 2026
Virtual groups in MVPs	Proposed for 2029	Not an option in 2027

That means some measures you use today could disappear. 

CMS plans 180 quality measures for 2027, down from 190 in 2026. 

It wants to remove 20 measures and make big changes to 43 more. 

Improvement activities are moving toward prevention and new technology. 

The 95 activities from 2026 would gain 6, lose 11 and see 5 changed. The new ones cover using artificial intelligence (AI) to improve care, screening for nutrition and other non-medical needs, advance care planning talks, tracking and reducing diagnosis errors, lifestyle programs for diabetes, and using data to improve how your clinic works. The activities being removed include glycemic screening services, glycemic referring services and Maintenance of Certification Part IV.

Promoting Interoperability gets a little lighter. 

CMS wants to drop the Security Risk Analysis measure starting in 2027, and make electronic prior authorization an optional bonus in 2027 that becomes required in 2028. Keep doing your yearly security review anyway, because that review is required under the Health Insurance Portability and Accountability Act (HIPAA) Security Rule.

How MIPS Core Measures Work in 2027

A MIPS core measure is a new label CMS wants to put on certain quality measures, and one of your MVP measures would have to carry it. 

CMS plans to give the core label to 78 measures. If you report an MVP, one of your 4 quality measures would need to be a core measure from your MVP. If you report traditional MIPS, one of your 6 would need to be a core measure.

This new rule replaces one you probably follow now. CMS wants to drop the rule that you must report an outcome measure, or a high priority measure if no outcome measure fits, and stop using the high priority label.

The scoring has good news too. Some measures that almost everyone scores very well on, called topped out measures, are capped at 7 points today. CMS wants to lift that cap for core measures and score them on a special scale that goes up to 10 points. A measure you already do well on could earn you more. That “not a small practice” line is just one of several breaks smaller clinics get.

MIPS Reporting for Small Practices in 2027

Promoting Interoperability works differently for you.

 CMS sets it to 0% for small practices automatically, so in 2026 your score becomes 40% quality, 30% cost and 30% improvement activities. Be careful here. If you send in complete Promoting Interoperability data anyway, CMS cancels the automatic break and scores what you sent.

You also get more ways to send quality data. 

Small practices can report quality measures through Medicare Part B claims all through the year. If a small practice reports an MVP that has fewer than 4 Part B claims measures, it doesn’t need the usual 4, as long as it reports each of those claims measures.

These breaks matter because small clinics get hit hardest. 

A study of CMS’s newest public data by the AMA found that smaller practices were more likely to receive penalties, especially the maximum penalty, and small practices with a high share of patients on both Medicare and Medicaid were penalized even more often. Practice size also decides whether you can report an MVP as one team or need to split into smaller ones.

MVP Subgroup Reporting and Who Can Report in 2027

Bigger practices with many specialties already follow a special rule. 

Since 2026, a practice with several specialties and 16 or more clinicians can’t report an MVP as one group. It has to form subgroups or let clinicians report on their own. When you sign up as a group, you tell CMS what kind of practice you are, because CMS won’t decide for you. A multispecialty practice with 15 or fewer clinicians can still report an MVP as one group.

A subgroup is just a smaller team inside your practice. 

It needs at least 2 clinicians, and at least one must be eligible for MIPS on their own. CMS says grouping clinicians who use the same electronic health record (EHR) system can make collecting data easier. A subgroup keeps any special status its main practice has, even if the subgroup alone wouldn’t qualify. For Promoting Interoperability, a subgroup sends in the whole practice’s data. Very few practices have tried this so far. Only 16 subgroups took part in the whole country in 2024.

If you work at more than one practice, watch one more proposal. 

CMS wants to apply the APM exemption by tax ID and provider number together, so you’d skip MIPS only at the tax ID where you earned that status. This could reach a lot of clinicians, since about 42,000 clinicians got two or more MIPS scores in 2024 by billing under different tax IDs.

Your practice	How you’d report an MVP	What to watch
Small primary care clinic	As one group	No core measure rule
Small clinic with several specialties	One group or subgroups	One MVP must fit everyone
Large clinic with several specialties	Subgroups by specialty	Each subgroup signs up for its own MVP
Hospital doctor group	Proposed Hospitalist MVP	A choice in 2027, required MVP path proposed for 2029
Clinician in an APM plus a private practice	Private practice may need to report	Proposed exemption stays with the APM tax ID

Once you know how many teams you’ll report as, each team needs the right MVP.

How to Choose the Right MVP for Your Specialty

The right MVP is the one your patients and your EHR can support all year long. You can see every MVP and its measures in the CMS MVP explorer. Here’s how CMS matches specialties with current MVPs.

Specialty	MVP
Primary care	Value in Primary Care
Behavioral health	Quality Care in Mental Health and Substance Use Disorders
Musculoskeletal and rehab	Rehabilitative Support for Musculoskeletal Care
General surgery	Surgical Care
Joint replacement	Improving Care for Lower Extremity Joint Repair
Podiatry	Podiatry
Vascular surgery	Vascular Surgery
Nephrology	Optimal Care for Kidney Health
Urology	Optimal Care for Patients with Urologic Conditions
Pulmonology	Pulmonology Care
Radiology	Diagnostic Radiology or Interventional Radiology
Pathology	Pathology
Neuropsychology	Neuropsychology

This matching comes from CMS’s own 2026 list of specialties and MVP titles.

For some specialists, picking an MVP isn’t the only new Medicare program starting in January.

Check Whether the Ambulatory Specialty Model Applies to You

The Ambulatory Specialty Model (ASM) starts in 2027, and if CMS picks you, you have to join. It runs from January 1, 2027 through December 31, 2031, and holds specialists accountable for the quality and cost of care for heart failure and low back pain. It applies to specialists in randomly selected areas who treat at least 20 of these patients a year. The heart failure track covers general cardiologists, and the low back pain track covers anesthesiologists, orthopedic surgeons, neurosurgeons, physiatrists and pain management physicians.

The payment works differently from MIPS. Payments would change based partly on each doctor’s own results, and the AMA says that will most likely mean a payment cut because of how the model is designed.

Many of the measures may already look familiar. The low back pain track uses body mass index screening, depression screening, a low back function measure, risky medicines in older adults, and a new measure on magnetic resonance imaging (MRI) of the lower spine. Yet only 61% of doctors picked for that track took part in MIPS in 2024, and most of those didn’t report these measures.

How MVP Scores Are Calculated in 2027

Your MVP score works just like a traditional MIPS score. It runs from 0 to 100. In 2026, a score above 75 gets a payment boost, exactly 75 gets no change, and below 75 gets a cut.

Each quality measure has to clear two bars before it can earn full points. 

CMS scores a measure against its benchmark only if you report on at least 75% of the patients who qualify and have at least 20 cases for most measures. Measures that miss these bars get 0 points unless you’re a small practice. That 75% goal stays the same through the 2028 performance year.

Your MVP data also has to be labeled correctly. 

Every MVP submission needs its MVP ID, or CMS counts the data as traditional MIPS. You can’t use one submission for both options, so reporting both means two separate submissions, even when the data is the same. CMS lets you do this, since you can report traditional MIPS in addition to an MVP. When you report both, CMS scores each one and gives you whichever final score is higher.

Not reporting at all hurts far more than a low score.

 In 2024, a score of 18.75 or less meant the biggest cut of 9%, while the biggest boost was only 1.05%. More than 10,000 clinicians who had to report but sent no quality measures, and had no exemption, ended up with an average score of 12.

Help exists if something outside your control gets in the way. 

For 2026, clinicians without the automatic break can apply for a Promoting Interoperability hardship exception by December 31, 2026, for reasons such as decertified EHR technology, poor internet access, disasters or a practice closing. For automatic disaster relief starting in 2027, CMS wants to check your location with the most up-to-date data it can find, instead of only your Medicare enrollment record.

Most clinicians do clear the bar. CMS estimated a middle 2026 score of 89.47, with about 12% of eligible clinicians getting a payment cut. With a small upside and a steep downside, the most useful 2027 question is when to start your MVP.

Should You Switch to an MVP in 2027 or Wait Until 2028

Early MVP results show why a test year helps. 

In 2024, 45% of MVP users got a default score of 75 because CMS could use at most one of their category scores, and many others were scored only on quality and improvement activities. A test year shows you whether your data produces a full, fair score before it counts on its own.

Most practices haven’t switched yet. 

The AMA study found that only 11,167 clinicians used MVPs in 2024, compared with 358,883 in traditional MIPS, and 40% of the groups and individuals using MVPs chose the Emergency Medicine MVP. Starting now puts you ahead of most clinics if MVPs become required.

How you’re scored may change later too. 

CMS is asking for feedback on comparing each clinician only with others using the same MVP, starting in 2029 or through an earlier test run. If that happens, your score would depend on how you do next to your peers in your MVP, so learning it early pays off.

MVP Registration 2027 and Your Reporting Calendar

Only certain people at your practice can sign up. You need the Security Official role in your Quality Payment Program (QPP) account for your practice’s tax ID or APM Entity. When you sign up, you choose how you’ll take part, mark any claims-based measure you want counted as one of your 4, and fill out a separate sign-up if you’ll use the CAHPS survey as one of them.

Promoting Interoperability runs on its own clock. You must collect data for all required measures over at least 180 days in a row, and in 2026 the last day to start was July 5. If that rule stays the same, July 5 would also be the last start day in 2027.

The 2026 cycle shows how the end of the year plays out. Submission for 2026 data closes on March 31, 2027. CMS expects to release final 2026 scores in mid-June 2027 and payment adjustment details in mid-July 2027, and you can ask for a targeted review if you spot a scoring error, until 30 days after the payment details come out. Every one of those dates depends on clean data, and that’s where most MVP problems start.

Build an MVP Data Readiness Plan Before January

An MVP data plan links each measure to the chart field it needs, the person who checks it, and the proof you keep. Always use CMS’s 2027 measure details, since the patients who count and the exceptions can change each year. Here’s an example using a measure many primary care clinics already know, Diabetes Glycemic Status Assessment Greater Than 9% (Quality ID 001), which can be sent as an electronic clinical quality measure, a MIPS clinical quality measure or a Medicare Part B claims measure.

What to track	What to write down
Measure	Quality ID 001
How you report it	EHR measure, MIPS clinical quality measure or claims
Which patients count	From CMS’s 2027 measure details
Chart data needed	Latest blood sugar test result and date
Where the data lives	EHR lab results
Who owns it	One staff member plus a backup
What to check	Qualifying patients with no result, and whether you’re above 75%
Where proof is kept	Folder or report name
Progress	Not started, in progress, checked, ready

Keep your proof for a long time. CMS asks you to save records backing up your quality measures and improvement activities for 6 years.

A simple routine keeps your plan on track. CMS doesn’t require this schedule, but it helps you catch problems early.

• Every month: Look for empty chart fields and big jumps or drops in patient counts.
• Every 3 months: Compare each measure with your goal and fix any gaps.
• Before you submit: Compare a few charts with your report totals, and confirm your MVP ID and core measure are included.
• After you submit: Save your confirmation and read your registry’s feedback. Registries already have to send feedback at least 4 times a year.

Problem	What to check	How to fix it
EHR count doesn’t match report	Filters, dates, exceptions	Compare a few charts by hand
Measure below 75% completeness	Visits missing the data	Fix the workflow and backfill where allowed
Missing chart data	Where staff write it down	Add a required field or check
No core measure fits	Your MVP’s core list	File the attestation
Data counted as traditional MIPS	MVP ID on your file	Resend with the MVP ID before the window closes
Registry missed sending data	Contract and dates	Tell CMS before the deadline

Your EHR company’s plans matter more each year. The 2027 prior authorization bonus would need specific Fast Healthcare Interoperability Resources (FHIR) tools in your certified EHR, and CMS wants to remove five certification requirements from its definition of a certified EHR. CMS is also asking for feedback on moving quality reporting to FHIR over two years starting in 2028, with FHIR required for some measures from 2030. Ask your EHR company how they’ll handle each step, and keep the CMS interoperability guide handy for the certification rules.