Learn about data completeness threshold, minimum reporting period for Promoting Interoperability, key dates and deadlines, and much more, through the Frequently Asked Questions (FAQs) below. Please schedule a consultation if you are looking for a Security Risk Analysis (SRA) for MIPS or Expert Consultants to help you navigate the process.
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What is the data completeness threshold for the Quality category?
CMS has confirmed the data completeness threshold will remain at 75% through at least the 2028 performance year, with a possible increase to 80% under consideration beginning in 2029. For 2026, a clinician’s data must cover at least 75% of the relevant patient population for a given measure in order for that measure to be scored competitively against a performance benchmark. Measures that fail to meet the completeness threshold are still counted toward the submission but receive a minimum score of 1 out of 10 achievable points rather than being benchmarked. For large practices (16 or more clinicians), there is no 3-point scoring floor, measures below the completeness threshold score a 1, not a 3. Small practices retain the 3-point floor.
What is the minimum reporting period for Promoting Interoperability in 2026?
For the 2026 performance year, clinicians must collect and report PI data for a minimum of 180 consecutive days within the calendar year, a requirement in place since the 2024 performance year and unchanged for 2026. This means the latest a clinician can begin the PI reporting period and still satisfy the minimum is July 5, 2026; any later start date cannot reach 180 consecutive days before December 31. Clinicians who miss the July 5 start date cannot satisfy the 180-day minimum within the 2026 calendar year and will receive a zero score in the PI category unless they qualify for automatic reweighting, which applies to small practices, hospital-based clinicians, ASC-based clinicians, and non-patient-facing clinicians, or are approved for a PI Hardship Exception. The 180-day window does not need to begin on January 1 or end on December 31; any continuous 180-day period falling within the calendar year qualifies, provided it is tied to the practice’s certified EHR technology reporting period.
When does MVP registration open for the 2026 performance year?
MVP registration for the 2026 performance year opens April 1, 2026, and closes November 30, 2026, at 8:00 PM ET. Clinicians should monitor qpp.cms.gov for any deadline changes. Groups that plan to administer the CAHPS for MIPS Survey as part of their 2026 reporting must register separately, the CAHPS for MIPS Survey registration window runs April 1 through June 30, 2026. MVP participation is not mandatory in 2026, but registration is required for any clinician who chooses to report through an MVP pathway. Clinicians who report both Traditional MIPS and an MVP will receive the higher of the two resulting scores, making early MVP participation a low-risk way to build familiarity with the pathway before it becomes mandatory.
What is the CAHPS for MIPS Survey, and who must administer it?
The Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey is a standardized patient experience questionnaire administered to Medicare beneficiaries by CMS-approved survey vendors, with results contributing to the Quality category score under MIPS. Groups with 2 or more clinicians under a single TIN may elect to administer the CAHPS for MIPS Survey as part of their quality reporting, participation is voluntary, not mandatory, but it counts as one of the required 6 quality measures and automatically satisfies the patient experience measure requirement. Individual clinicians cannot administer the CAHPS for MIPS Survey; it is available only to groups. Because administering the survey requires coordinating with a CMS-approved vendor over a defined data collection period, advance registration is required. For the 2026 performance year, CAHPS for MIPS Survey registration opens April 1, 2026, and closes June 30, 2026, groups that miss this window cannot administer the survey for 2026. Once registered, the survey vendor manages beneficiary outreach and data submission directly; the group does not submit CAHPS data through the QPP portal.
Can I use a third-party intermediary to submit my MIPS data?
MIPS-eligible clinicians have five pathways for submitting performance data to CMS: direct entry through the QPP portal at qpp.cms.gov, submission through a qualified clinical data registry (QCDR), submission through a qualified registry, EHR-based submission, and claims-based submission for the Quality category only under certain circumstances. Compliance platforms such as databrackets support practices in organizing, preparing, and tracking MIPS data across all four performance categories before submission, regardless of the final submission channel used. For 2026, CMS finalized a new requirement for QCDRs and qualified registries: these intermediaries must support any MVPs applicable to the participants on whose behalf they submit data, no later than one year after the MVP is finalized, giving registries a defined preparation window and reducing the risk of a clinician choosing an MVP their registry cannot yet support. Regardless of submission method, the attesting clinician remains responsible for the accuracy and completeness of all submitted data.
Is there a new optional bonus measure available in the PI category for 2026?
CMS finalized a new optional bonus measure for the Promoting Interoperability category beginning in 2026: Public Health Reporting Using TEFCA (Trusted Exchange Framework and Common Agreement). To satisfy this measure, a clinician must attest to being in active engagement, specifically validated data production (Option 2), with a public health agency to transmit health information using the TEFCA framework. This measure joins three other available optional bonus measures under the Public Health and Clinical Data Exchange objective. The maximum bonus points that can be earned from any combination of optional PI bonus measures remains capped at 5 points total, regardless of how many optional measures are reported.
What are the key dates and deadlines for the 2026 MIPS performance year?
The 2026 MIPS performance year runs January 1 through December 31, 2026, with a data submission deadline of March 31, 2027, and payment adjustments applied to Medicare Part B payments in 2028. The complete calendar of binding deadlines is as follows.
January 1, 2026, Performance year begins. The Quality performance period also begins.
April 1, 2026, MVP registration opens. CAHPS for MIPS Survey registration opens.
June 30, 2026, CAHPS for MIPS Survey registration closes. Groups that want to administer the CAHPS for MIPS Survey must register by this date.
July 5, 2026, Last day to begin the 180-day Promoting Interoperability performance period. Any clinician who begins their PI period on this date will report continuously through December 31. Clinicians who miss this date cannot satisfy the 180-day minimum within the 2026 calendar year.
October 3, 2026, Last day to begin a 90-day Improvement Activities performance period. Any clinician who begins on this date will complete their 90-day window by December 31.
November 30, 2026, at 8:00 PM ET, MVP registration closes.
December 31, 2026, at 8:00 PM ET, End of the 2026 MIPS performance year. Deadline to submit the EUC exception application and the PI Hardship Exception application. Final day to complete the Security Risk Analysis and the High-Priority Practices SAFER Guide self-evaluation for PI attestation purposes.
March 31, 2027, Data submission deadline. All 2026 MIPS performance data must be submitted to CMS by this date. Missing this deadline results in the full,9% payment penalty for 2028.
Summer 2027 (estimated), CMS releases final 2026 MIPS scores and performance feedback. The targeted review window opens at this time under 42 CFR 414.1385(a)(2) and closes 30 days after CMS publishes the 2028 payment adjustment factors.
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