CMS Just Proposed an Expiration Date for Traditional MIPS. If It Holds, You Have Two Performance Years Left.
CY 2027 PFS Proposed Rule (CMS-1848-P) — What the Shared Savings Program proposals mean for ambulatory practices
For a decade, the answer to "how do we report MIPS?" has been the same for most ambulatory groups: pick six quality measures, make sure one of them is an outcome or high-priority measure, attest to your improvement activities, submit your Promoting Interoperability data, and hope the cost category doesn't surprise you.
In the CY 2027 Physician Fee Schedule proposed rule, released July 14 and published in the Federal Register on July 16, 2026, CMS proposes to end that.
Two things happen at once in this rule. One is a date. The other is a rebuild of how quality measures get selected/scored and that one lands in 2027, not 2029.
The date: CMS proposes to sunset traditional MIPS after CY 2028
CMS states it plainly: it proposes to sunset the traditional MIPS reporting option after the CY 2028 performance period. Beginning with the CY 2029 performance period, MVPs would be the only MIPS reporting option for clinicians who don't participate in a MIPS APM. Clinicians in MIPS APMs continue through the APP and APP Plus.
Count the runway. CY 2026 is in progress. CY 2027 and CY 2028 are the last two years of traditional MIPS. That is two performance periods to select an MVP, test it against your actual denominators, and resolve subgroup strategy if you're a multispecialty group. Practices need to plan before it becomes the only option rather than an option.
The MVP inventory grows to 30 for CY 2027: 27 existing plus three new ones. These include Diabetic Disease, Hypertension, and Hospitalist. Every one of the 27 existing MVPs is proposed for modification, partly to add measures that capture additional applicable specialties. If you evaluated an MVP two years ago and concluded none of them fit your specialty mix, that may no longer be the case.
Two related signals worth reading: CMS proposes to let virtual groups report an MVP beginning CY 2029, and it issues an request for information on normalizing MVP scores against peers reporting the same MVP. This is to answer the question whether normalization should happen at the final score or the performance category level, and whether to start in CY 2029 or pilot it earlier. Score normalization would change the competitive math of MVP selection substantially. It is worth a comment.
Key takeaways
CY 2027 and CY 2028 are proposed as the last two years traditional MIPS is available.
MVPs become the only option for non-APM clinicians starting CY 2029.
The MVP inventory grows to 30, with all 27 existing MVPs modified (re-evaluate even ones you previously ruled out.)
Should it be implemented, MVP score normalization could change the competitive math of which MVP to pick.
The rebuild: "high priority" is gone, replaced by MIPS core measures
The rebuild: "high priority" is gone, replaced by MIPS core measures
CMS proposes to eliminate the high priority measure designation entirely. This means outcome, intermediate outcome, patient-reported outcome, appropriate use, patient safety, efficiency, patient experience, care coordination, and opioid measures all lose the HP label. High-priority status is no longer a criterion for keeping a measure in the inventory.
In its place: a requirement to report at least one MIPS core measure. CMS proposes 78 measures for core designation. In traditional MIPS, one of your six measures must be a core measure. In an MVP, one of your four.
The mechanics matter:
Small practices are exempt from the core measure requirement and from the associated self-attestation process.
Clinicians with no applicable core measure can self-attest to that fact.
A non-small practice that reports no core measure and files no valid attestation scores 0 out of 10 points on one required measure.
There is also a benchmark sweetener attached. Beginning CY 2027, a MIPS core measure that has been topped out for two or more consecutive periods would receive a defined benchmark scored across the full 1–10 point range rather than the usual 7-point cap. Seventeen measures are proposed for topped-out benchmarks in CY 2027, down from 19.
Our read: for most ambulatory groups this is not a scoring problem, it is an inventory problem. You need to know today which of your submitted measures appear on the 78-measure core list, and whether the one you'd rely on is also one of the 20 measures being removed.
Key takeaways
High priority status disappears as a measure designation entirely, replaced by a 78-measure core list.
Every practice needs at least one core measure in its set or a valid self-attestation on file.
Failing both costs a full 10 points on a required measure.
Check your current measure set against the core list before the final rule, not after.
Twenty measures out, ten in
The quality inventory drops from 190 to 180. CMS itemizes the additions as two new measures focused on prevention and chronic disease management, four current QCDR measures adopted as MIPS CQMs, and five new orthopedic functional improvement PRO-PMs replacing seven existing functional status change measures. One of the two new measures based on a timely-follow-up-on-abnormal-screening-mammogram eCQM is proposed for a one-year delay to CY 2028. Twenty measures come out.
The removals are not evenly distributed. Some specialties lose a single measure. Others lose a measure set:
Orthopedics, PT, and rehab lose the entire functional status change family — Q217 knee, Q218 hip, Q219 lower leg/foot/ankle, Q220 low back, Q221 shoulder, Q222 elbow/wrist/hand, and Q478 neck. Five new functional improvement PRO-PMs (currently QCDR measures from Limber/Patient360) replace seven.
Cardiology loses Q006 and Q007 (CAD antiplatelet and beta-blocker therapy) and Q326 (AFib chronic anticoagulation).
Gastroenterology loses Q320 (appropriate follow-up interval for normal colonoscopy).
ENT loses Q332 (adult sinusitis antibiotic choice) and gains an age-related hearing loss audiometric evaluation measure.
Anesthesia loses Q430 and Q463 (PONV/POV combination therapy) and gains two measures — Patient-Reported Experience with Anesthesia, and Intraoperative Hypotension Among Non-Emergent Noncardiac Surgical Cases.
Primary care loses Q483, the Person-Centered Primary Care Measure PRO-PM.
Four current QCDR measures are proposed for adoption as MIPS CQMs. That is a real change in status: measures that previously required a QCDR relationship become available through any qualified registry.
Forty-three existing measures get substantive changes on top of all this.
Promoting Interoperability: three requirements come off, one big one goes on
CMS proposes to remove the Security Risk Analysis measure beginning CY 2027, reasoning that MIPS eligible clinicians are already covered entities under the HIPAA Security Rule. It also proposes to remove the required ONC Direct Review attestation and the optional ONC-ACB Surveillance attestation, both retroactive to the CY 2026 performance period.
Say the quiet part out loud: removing the SRA from MIPS does not remove the SRA from HIPAA. If your compliance program treats the MIPS attestation as the reason you do a risk analysis, you have a gap opening on January 1, 2027.
Going the other direction, electronic prior authorization becomes optional and bonus-eligible in CY 2027 and required in CY 2028 — and CMS proposes a second, new measure required beginning CY 2028, Electronic Prior Authorization for Prescription Drugs. CMS also proposes to modify the CEHRT definition to align with the certification criteria ASTP/ONC has proposed to remove in the HTI-5 proposed rule — among them family health history, patient health information capture, automated numerator recording and measure calculation, and the CQM filter.
That is an eighteen-month vendor conversation, not a reporting-season task.
Cost: nothing new, which is its own kind of news
In CY2027, CMS states there are no proposed cost measure inventory updates. There are no new episode-based measures, no removals, no substantive changes. Only the operational list of care episode and patient condition codes gets refreshed for non-substantive maintenance.
Cost stays at 30% of the traditional MIPS final score and remains the category practices can least directly influence. A stable year here is a good year to build the internal cost-feedback loop you've been deferring.
Improvement Activities: 95 down to 90, and MOC Part IV is gone
Six new activities in, eleven out, five modified. The new inventory includes the first MIPS improvement activity built around clinician use of artificial intelligence to improve patient care, alongside activities on diagnostic performance, non-clinical needs screening, advance care planning, data-driven workflow improvement, and lifestyle approaches to diabetes remediation.
The removal that will affect the most attestations is IA_PSPA_2, participation in Maintenance of Certification Part IV. This was one of the most widely used activities in the program. Also out: four care coordination activities (IA_CC_10, 11, 12, and 16), plus IA_BE_15, IA_PM_2, IA_PM_19, IA_PM_20, IA_BMH_5, and IA_EPA_4.
If MOC Part IV has been carrying your IA attestation, you need a replacement selected before January.
The FHIR Information Request is the real 2030 story
CMS is not proposing a FHIR mandate. It is asking about one, and the rules it describes are specific enough to plan for already. They have posted a two- year transition beginning with the CY 2028 performance period, maintaining existing reporting options while supporting FHIR-based reporting for selected measures. This will be followed by mandatory FHIR-based reporting for applicable measures beginning CY 2030, with prior electronic reporting approaches retired for those measures.
Any of that requires future rulemaking. But if you are signing a multi-year EHR or registry contract this fall, FHIR bulk data and quality measure export readiness belongs in it.
If you work through a registry or QCDR, read the intermediary section
Several proposed changes tighten the ground under third-party intermediaries:
Performance feedback must be provided to individual clinicians, groups, virtual groups, subgroups, and APM entities expanded from "clinicians and groups."
If an intermediary submits data for fewer than 10 participants, the data validation audit sample must include all of them.
If the standard 25% patient record sample yields fewer than 5 records, the sample must include all records.
Participation plans are required if the intermediary did not submit data in the year preceding the self-nomination period and those intermediaries must document to CMS that they have contracted with participants who will submit MIPS data, or face termination.
The qualified posting may not be updated for the public even when updated information is provided to CMS.
The practical effect is consolidation pressure on small and niche registries. Ask your vendor now whether they will self-nominate for PY 2027 and whether they will carry a core measure applicable to your specialty.
One related change belongs to you, not your vendor. If a third-party intermediary fails to submit your data for reasons outside your control, you may request reweighting. CMS proposes to move the deadline for notifying CMS from November 1 to December 31 of the data submission year, beginning with the CY 2025 performance period / 2027 MIPS payment year. That is two extra months, reaching back to data you are submitting now.
One thing that does not change: the performance threshold stays at 75 points through the CY 2028 performance period, and data completeness remains at 75%. The bar is stable. What you have to do to clear it is not.
What we'd do between now and September 14
Map your current six measures against the 78-measure core list and the 20-measure removal list. Do this before the final rule, not after. If both your core-eligible measure and your highest-scoring measure are on the removal list, you are rebuilding a measure set, and that takes a full cycle.
Pick an MVP and shadow-report it in 2027. Two performance years is enough time to do this deliberately and not enough time to do it twice.
Replace IA_PSPA_2 now if MOC Part IV is carrying your improvement activity attestation.
Decouple your HIPAA Security Risk Analysis from MIPS in your compliance calendar, so its removal from the program doesn't quietly remove it from your operations.
Put FHIR export capability in every vendor contract you sign this year, on a CY 2028 readiness horizon.6. Comment. File code CMS-1848-P at regulations.gov, docket CMS-2026-2377. The core measure list, the MVP normalization RFI, and the FHIR transition timeline are all places where operational detail written now saves rework later.
Why ReportingMD is watching this one closely
We have been doing population health and quality reporting work with CMS since 2007, and we have a seat at the table for most of the program architecture ambulatory practices live inside today.
We were part of the group that helped wire-frame MIPS. We built one of the first bidirectional interfaces for MIPS submission, because we did not think a one-way file drop was a real answer for practices that needed to act on their data during the year rather than read about it afterward. And we began working with CMS on eCQMs while they were still in development, starting in 2011.
That history is why the core measure proposal reads to us as the most consequential item in this rule, and the MVP sunset as the most urgent. Measure selection has always been where MIPS performance is actually won or lost. CMS is about to change the selection rules and shrink the inventory in the same year it starts the countdown on traditional MIPS. Practices that treat measure selection as an annual administrative task rather than a modeled decision are going to feel both changes at once.
We are an eCQM-certified vendor serving ambulatory practices. If you are working out what these proposals mean for your PY 2027 measure set or your MVP transition plan, we would welcome the conversation.
Not sure which MVP fits your specialty mix?
Talk to our team about shadow-reporting an MVP in 2027, before it's your only option.
This post summarizes proposals in CMS-1848-P, published at 91 FR 43842 on July 16, 2026. Proposals are not final policy and may change in the final rule, typically issued in early November. Nothing here is legal or compliance advice.
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