Learn about 3 ways to participate in MIPS, APP, MVPs, reporting, MIPS as a group, multispecialty groups reporting MVPs, 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.
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What are the three ways to participate in MIPS for 2026?
Three reporting pathways are available to MIPS-eligible clinicians for the 2026 performance year: Traditional MIPS, the APM Performance Pathway (APP), and MIPS Value Pathways (MVPs). Traditional MIPS is the original, most flexible option, allowing clinicians to select their own measures from the full quality catalog and report across all four performance categories against national benchmarks, it remains available for 2026, though CMS has stated its long-term intent to sunset it in favor of MVPs. The APM Performance Pathway (APP) is available exclusively to clinicians participating in MIPS APMs and uses a standardized, pre-specified set of quality measures. MIPS Value Pathways (MVPs) are the newest and increasingly central option, organizing measures and activities around specific clinical specialties or conditions. Clinicians who report both Traditional MIPS and an MVP will be assigned the higher of the two resulting scores, making dual reporting a low-risk strategy during the transition period.
What is the APM Performance Pathway (APP)?
The APM Performance Pathway (APP) is a standardized MIPS reporting pathway available exclusively to clinicians participating in MIPS Alternative Payment Models, APMs that require participants to use certified EHR technology and tie payment to quality performance, but that do not meet the financial risk and threshold requirements to qualify as Advanced APMs. Rather than selecting from the full MIPS quality measure catalog, APP participants report a fixed, pre-specified set of quality measures drawn from the Core Quality Measures Collaborative, reducing administrative complexity for practices already operating within an APM structure. The Cost and Promoting Interoperability categories function the same way as under Traditional MIPS, Cost is calculated by CMS from Medicare Part B claims data, and PI requires the standard 180-day CEHRT reporting period. The APP is not available to individual clinicians reporting outside an APM Entity; participation requires enrollment in a qualifying MIPS APM.
What are MIPS Value Pathways (MVPs)?
MIPS Value Pathways (MVPs) are a structured reporting option in which all measures and activities across the four performance categories are organized around a specific clinical specialty, condition, or patient population, rather than selected from the full MIPS measure catalog. The intent is to reduce administrative burden by offering clinicians a curated, relevant subset of measures. As of the 2026 performance year, 27 MVPs are available, 6 newly added for 2026, covering diagnostic radiology, interventional radiology, neuropsychology, pathology, podiatry, and vascular surgery, and 21 previously finalized MVPs updated for 2026. MVP participation is voluntary for 2026. Clinicians who choose to report through an MVP must register with CMS; registration for the 2026 performance year opens April 1, 2026, and closes November 30, 2026, at 8:00 PM ET.
Should I consider switching to MVP reporting in 2026?
CMS has signaled a long-term intent to phase out Traditional MIPS and make MVP reporting the default framework, though no mandatory transition date has been confirmed, the year 2029 has appeared in prior comment solicitations as a potential target, but any formal change requires notice-and-comment rulemaking. Clinicians who report an MVP in 2026 and also submit data under Traditional MIPS will receive the higher of the two scores, making early MVP participation a low-risk way to build familiarity before the pathway becomes mandatory. Practices whose patient population aligns closely with an available MVP, particularly those in specialties newly covered in 2026, including diagnostic radiology, interventional radiology, neuropsychology, pathology, podiatry, and vascular surgery, are well-positioned to benefit from the curated measure set and reduced reporting burden MVPs provide.
Can I report MIPS as a group rather than as an individual?
MIPS-eligible clinicians may participate as an individual (identified by a TIN/NPI combination), as part of a group (a single TIN with two or more clinicians, at least one of whom is MIPS-eligible), or as part of a Virtual Group. Reporting as a group means that all MIPS-eligible clinicians under the TIN share a single composite score and receive the same payment adjustment at the individual TIN/NPI level. Clinicians who are individually below the low-volume threshold but practice under a TIN that collectively exceeds it are included in the group’s score. One binding rule applies: the decision to report as an individual or as a group is irrevocable for the entire performance year and applies across all four performance categories, a clinician cannot report as an individual in some categories while reporting as a group in others.
What is a Virtual Group, and how does it work?
A Virtual Group is a reporting arrangement that allows solo practitioners and groups of ten or fewer eligible clinicians from different Tax Identification Numbers (TINs) to pool their data and report collectively as if they were a single entity, giving smaller and independent practices access to the same performance averaging available to larger group practices. Virtual Group elections must be submitted to CMS before the performance year begins and cannot be changed once the year starts. For the 2026 performance year, which began January 1, 2026, the Virtual Group election window has already closed. Clinicians interested in Virtual Group participation for the 2027 performance year should monitor qpp.cms.gov for the election window, which typically opens in the fall of the prior calendar year.
Are there new rules for multispecialty groups reporting MVPs in 2026?
Beginning with the 2026 performance year, multispecialty groups are prohibited from registering to report an MVP as a single group, they must instead register and report at the subgroup level, as individuals, or as an APM Entity. There is an important carve-out for practice size: multispecialty groups that qualify for small practice special status (15 or fewer clinicians under the TIN) may still register to report an MVP as a group and are not required to form subgroups. Additionally, CMS changed how multispecialty status is determined, rather than CMS assigning it based on two-digit specialty codes, groups now self-attest their specialty composition (single-specialty or multispecialty) during the MVP registration process itself.
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