Learn about the basics of MIPS, rules for 2026, eligibility, low-volume threshold, who qualifies for an exemption, determination period, and 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.
Table of Contents
What is MIPS?
MIPS, the Merit-based Incentive Payment System, is the primary participation track within Medicare’s Quality Payment Program (QPP), which ties Medicare Part B compensation to measured performance across four categories: Quality, Cost, Promoting Interoperability, and Improvement Activities. Each year, CMS evaluates a clinician’s performance during the prior calendar year, produces a composite score from 0 to 100, and applies a corresponding positive, neutral, or negative adjustment to that clinician’s Medicare Part B payments two years after the performance year.
What law created MIPS, and when did it take effect?
MIPS was established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), signed into law on April 16, 2015. MACRA permanently repealed the Sustainable Growth Rate (SGR) formula, a flawed mechanism that had threatened physicians with large annual payment cuts, and replaced it with a value-based payment structure through the Quality Payment Program (QPP). The QPP, and MIPS within it, went live on January 1, 2017, with the first payment adjustments applied in 2019. MIPS consolidated three older CMS quality programs, the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier (VBM), and Meaningful Use (MU), into a single unified scoring framework.
What are the MIPS rules for 2026?
The 2026 MIPS performance year is governed by the CY 2026 Medicare Physician Fee Schedule Final Rule, published November 5, 2025, which CMS characterized as a stability year with few sweeping structural changes while continuing the gradual transition toward MIPS Value Pathways (MVPs) as the long-term replacement for Traditional MIPS.
Payment timeline and adjustment range. The performance year runs January 1 through December 31, 2026. Data must be submitted by March 31, 2027. Payment adjustments are applied to Medicare Part B payments in 2028. The maximum negative adjustment is 9% for clinicians scoring 0 through 18.75 points. The maximum positive adjustment is budget-neutral and calculated after the year closes. CMS projects a median final score of 89.47 points, with 84.04% of clinicians receiving a positive adjustment, 4.03% neutral, and 11.92% negative.
Category weights. Unchanged from 2025: Quality 30%, Cost 30%, Promoting Interoperability 25%, Improvement Activities 15%. Small practices (15 or fewer clinicians) receive automatic PI reweighting to 0%, with weight shifted to Quality (40%) and Improvement Activities (30%), plus a 6-point composite score bonus. Hospital-based, non-patient-facing, and ASC-based clinicians also receive automatic PI reweighting to 0%, with the full 25% flowing to Quality only (55%).
Eligibility and the low-volume threshold. A clinician must exceed all three thresholds to be required to participate: more than $90,000 in Medicare Part B allowed charges, more than 200 Part B-enrolled patients, and more than 200 covered professional services, each assessed across both segments of the MIPS Determination Period.
Quality category. The 2026 inventory contains 190 measures (5 added, 10 removed, 30 substantially updated). Clinicians report 6 measures, including at least one outcome or high-priority measure. The data completeness threshold holds at 75% through 2028. Large practices (16 or more clinicians) no longer receive the 3-point scoring floor; small practices retain it. “Health equity” has been removed from the definition of a high-priority measure. Claims-based measure scoring now uses a median-based methodology.
Cost category. The inventory holds at 35 measures with no additions or removals. TPCC attribution rules were updated to exclude advanced practice practitioners from specialty group attribution when all other clinicians in the group are excluded based on specialty. A new two-year informational-only feedback policy applies to any future new cost measures.
Improvement Activities. The 2026 inventory contains 104 activities (3 added, 7 modified, 8 removed). The medium/high weighting system has been eliminated. Large practices must attest to 2 activities; small practices, rural practices, HPSA practices, non-patient-facing clinicians, and MVP reporters need only attest to 1. Each activity requires a minimum continuous 90-day window. The “Achieving Health Equity” subcategory was retired and replaced with “Advancing Health and Wellness.”
Promoting Interoperability. The minimum continuous reporting period is 180 days. Key 2026 changes: the Security Risk Analysis now requires a second attestation component confirming that risk management activities were completed under the HIPAA Security Rule (45 CFR 164.308(a)(1)); the SAFER Guides requirement was updated to the 2025 edition; and the eCR measure is suppressed with full credit awarded automatically. A new optional TEFCA bonus measure was added, capped at 5 total optional bonus points.
Reporting options. Three pathways remain available: Traditional MIPS, the APM Performance Pathway (APP), and MVPs. For 2026, 27 MVPs are available (6 new, 21 updated). Multispecialty groups, other than small practices, can no longer report MVPs as a single group and must form subgroups or report individually. MVP registration opens April 1, 2026, and closes November 30, 2026, at 8:00 PM ET.
APM changes. Advanced APM participants can now qualify for Qualifying APM Participant (QP) status at the individual clinician level, in addition to the existing APM Entity-level determination.
Who is required to participate in MIPS?
Clinicians are required to participate in MIPS if they meet four conditions: they are an eligible clinician type, they enrolled in Medicare before January 1 of the current performance year, they are not a Qualifying Participant (QP) in an Advanced Alternative Payment Model (Advanced APM), and they exceed all three criteria of the low-volume threshold. Eligible clinician types include physicians (MD/DO), physician assistants, nurse practitioners, clinical nurse specialists, certified registered nurse anesthetists, physical therapists, occupational therapists, clinical psychologists, marriage and family therapists, and mental health counselors, the latter two added as Medicare-eligible providers under the Consolidated Appropriations Act of 2023, effective January 1, 2024, and included in the MIPS-eligible clinician list beginning with the 2025 performance year. Clinicians newly enrolled in Medicare for the first time on or after January 1 of the current performance year are exempt from mandatory participation for that year. Certain limited-license practitioners and clinician types not enumerated under MACRA’s eligible clinician framework remain outside the scope of MIPS eligibility.
What is the low-volume threshold, and who qualifies for an exemption?
The low-volume threshold defines the minimum activity level a clinician or practice must exceed before MIPS participation becomes mandatory. For 2026, a clinician is required to participate only if they exceed all three of the following criteria during both segments of the MIPS Determination Period: billing more than $90,000 in Medicare Part B allowed charges for covered professional services; providing care for more than 200 Part B-enrolled Medicare beneficiaries; and billing more than 200 covered professional services to Part B beneficiaries. Clinicians who meet only one or two of these three criteria are not required to participate but may elect to opt in, an irrevocable decision for that performance year, made through the QPP Portal at qpp.cms.gov. Clinicians who fall below all three thresholds may still report voluntarily without being subject to any payment adjustment.
What is the MIPS Determination Period, and what are its two segments?
The MIPS Determination Period is the time frame CMS uses to assess whether a clinician meets the low-volume threshold and is therefore required to participate in a given MIPS performance year. It consists of two segments. Segment 1 covers a 12-month assessment window ending approximately six months before the performance year begins, typically October 1 through September 30 of the year prior to the performance year. Segment 2 covers the first six months of the performance year itself, January 1 through June 30. CMS uses both segments to account for clinicians whose Medicare practice volume changes meaningfully between periods. A clinician who falls below all three low-volume threshold criteria during either segment, not both, is exempt from mandatory participation for the full performance year. Clinicians can verify their current determination and segment-level eligibility status through the QPP Participation Status Lookup Tool at qpp.cms.gov.
How do I check whether I am required to participate in MIPS?
CMS provides a QPP Participation Status Lookup Tool at qpp.cms.gov where any clinician can enter their National Provider Identifier (NPI) to see their current MIPS eligibility status, including whether they are required to participate, eligible to opt in, or exempt. Eligibility is assessed at the TIN/NPI combination level, meaning a single clinician who bills Medicare under multiple Tax Identification Numbers (TINs) will receive a separate eligibility determination for each unique TIN/NPI pairing.
Explore Blogs, Webinars and other Resources
Trusted by Reputed Companies
Accreditations and Associations
* Disclaimer: This list of accreditations is held by our team of employees and consultants.
What Our Clients Say
We used databrackets (formerly EHR 2.0) in our small medical practice for our risk analysis assessment to be in compliance with meaningful use. Their response was fast, the final report is detailed but simple and easy to follow. They were always available to answer our questions.
E. Compres
Pulmonary and Sleep Center of the Valley
I never miss the opportunity to learn something new …that’s why I am always registering to all free seminars offered on the web. databrackets (formerly EHR 2.0) happened to be the friendliest, comprehensive and up-to- date source of HIPAA Privacy and Security updates.
Alexandra V.
Community Healthcare Network
Today’s presentation was great! Thank you for sending the slides. My only feedback is that it would be fabulous to have the slides ahead of time so I could print them and take notes on the slides.Thanks for your time and knowledge today!
T.B., PM
Community Health Network
Particularly interesting was the flow chart on Administrative Simplification. I utilize all of the Security subcategories you list under the Security tile and appreciate knowing that I am hitting all of the relevant topics during my employee training.
Jessica B.
JD, CHC
I have re-worked our original risk assessment….We are using databrackets' (formerly EHR 2.0) Meaningful Use Security Risk Analysis Toolkit and it meets our needs. It was easy to use and I believe that it very beneficial to our meeting meaningful use.
Bill Curtis
Neurosurgical Associates Of Texarkana, TX
Information (webinars) presented by databrackets (formerly EHR 2.0) highlights some of today’s most demanding healthcare topics. The webinars help to direct those operating in today’s rapidly changing environment in the right direction.
Candace M.
Privacy and Security Officer, Springhill Medical Center
Our Growing List of Credentials
0
+
Assessments
0
+
Clients
0
+
Assessment Libraries
0
+
Years of Experience
0
+
No. of Staff Trained
0
+
HIPAA
0
+
SOC 2 Readiness
0
+
Pen Testing
0
+
ISO 27001 Certifications
0
+
Dollars Saved in Compliance Penalties