MIPS 2026: What Changed, Who Can Still Report as a Group, and Why 30 November Is Your Real Deadline

The 2026 performance year keeps the MIPS performance threshold at 75 points — and CMS has now locked it there through the 2028 performance period, so a score that merely clears the bar buys less room every year the target stays fixed while competitors improve. The more consequential change is procedural: beginning with 2026, a multispecialty group can no longer register as a group to report a MIPS Value Pathway. It must register at the subgroup, individual, or APM Entity level, unless it qualifies as a small practice of 15 or fewer clinicians. Six new MVPs bring the inventory to 27. All of it — registration, attestation, and a subgroup roster if you need one — has to be settled before MVP registration closes on 30 November 2026 at 8:00 p.m. ET.

This is not a full rule recap — CMS's own fact sheet on the CY2026 Quality Payment Program final rule runs to dozens of policy areas most practices will never touch. What follows is the part that changes what a multispecialty practice has to do differently this fall, what the payment math looks like two years out, and the exact dates standing between you and an MVP registered correctly versus a scramble in late November. If you want the full mechanics of how MIPS scoring works category by category, start with our complete guide — this piece assumes you already know what Quality, Cost, Improvement Activities, and Promoting Interoperability are, and focuses only on what changed for the 2026 performance year.

CMS calculates the MIPS performance threshold using the mean final score from a reference performance period. For the 2026 through 2028 performance periods, that reference point stays fixed at the mean final score from the 2017 performance period, and on that basis CMS has set the performance threshold at 75 points through the CY2028 performance period/2030 MIPS payment year. In plain terms: the bar is not just staying at 75 for one more year — CMS has committed to it for three more reporting cycles.

That stability cuts both ways. A practice that has been comfortably scoring 78–82 points can stop treating each performance year as a fresh negotiation with a moving target. But a practice that has been scoring in the high 70s with no real strategy behind it should read this as a warning, not relief — because the threshold not moving does not mean the competition for the positive-adjustment pool is standing still. MIPS payment adjustments above the threshold are scaled to stay budget-neutral, so as more practices cluster near or above 75, the upside per point compresses. "Just avoid the penalty" was already a mediocre strategy; a fixed, well-known bar makes it a shrinking one.

This is the mechanic more practices misunderstand than any other part of MIPS. Data you collect between 1 January and 31 December 2026 determines your final score for the 2026 performance period — and that score sets your Medicare Part B payment adjustment for the 2028 MIPS payment year. Nothing you do in 2026 affects a 2026 or 2027 payment. The consequences of this year's reporting decisions land two calendar years later.

The -9% ceiling is set in statute by MACRA and does not change based on the final rule. What does move year to year is how much upside a strong score actually produces, because positive adjustments above 75 are scaled to keep the whole program budget-neutral — CMS cannot pay out more in bonuses than it collects in penalties. A practice planning its 2026 reporting strategy around MIPS reporting support should be modeling the 2028 payment year now, not treating the deadline pressure as an abstraction two years away.

What changed

Through the 2025 performance period, a multispecialty group — a group made up of clinicians across two or more specialty types, or clinicians involved in multiple foci of care — could register and report an MVP the same way a single-specialty group could: as one unit, under one TIN. Beginning with the 2026 performance period, that option is gone for most multispecialty groups. CMS's finalized policy is direct: multispecialty groups interested in reporting an MVP can no longer register as a group. They must register at the subgroup, individual, or APM Entity level.

The small-practice exception

CMS finalized one exception, and it matters enormously if your group qualifies. Multispecialty groups that meet the small-practice special status — 15 or fewer clinicians — may continue to register and report an MVP as a group, and they are not required to form subgroups if they would rather not report as individuals. CMS also formally updated the definition of an "MVP Participant" to explicitly include multispecialty groups that meet the small-practice threshold, alongside individual clinicians, single-specialty groups, subgroups, and APM Entities. If your multispecialty practice has 15 or fewer clinicians, this entire section does not force any operational change on you for 2026 — you can register exactly as you did before.

What forming a subgroup actually takes

For everyone above the 15-clinician threshold, "just register as a subgroup" undersells the work involved. A subgroup is not a checkbox on a registration form — it is a defined subset of the group's clinicians, identified by their specific TIN-NPI combinations, that reports the MVP together and is scored as its own unit, separate from the rest of the group.

None of this is optional busywork. A subgroup that is misdefined, or that cannot independently satisfy case-minimum and data-completeness thresholds, risks losing MVP credit entirely for that unit of clinicians — which, given the two-year payment lag, would not surface as a problem until the 2028 payment year. Practices already working with a MIPS reporting partner should be having this TIN/NPI mapping conversation now, in August, not in the weeks before the deadline.

Previously, CMS determined whether a group was single-specialty or multispecialty by analyzing Medicare Part B claims. That determination now shifts to the group itself. During MVP registration, groups attest to their own specialty composition — whether they are a single-specialty group, or a multispecialty group that meets the small-practice definition. CMS has been explicit that it will not make this determination for practices. The stated rationale is to help groups assess, ahead of time, whether they actually need to participate as subgroups — but the practical effect is that the burden of getting this classification right now sits with your practice, and an incorrect attestation is a self-inflicted problem rather than a CMS clerical error you can appeal.

CMS finalized six new MVPs for the 2026 performance period: Diagnostic Radiology, Interventional Radiology, Neuropsychology, Pathology, Podiatry, and Vascular Surgery. That brings the total MVP inventory to 27 available for reporting in 2026. Just as important for anyone already reporting an MVP: CMS is also modifying all 21 previously existing MVPs in the same rule, aligned with broader changes to the quality measure and improvement activity inventories — the quality measure inventory itself dropped from 195 measures in 2025 to 190 for 2026, with 5 additions, 10 removals, and substantive changes to 30 existing measures.

If your specialty falls under one of the six new MVPs, confirm with your registry or QCDR vendor whether they can fully support it for the 2026 performance period — CMS's rule gives QCDRs and Qualified Registries up to one year after a new MVP is finalized before they are required to fully support it, which in practice means some vendors will not have a newly finalized MVP production-ready until the 2027 performance period. Ask before you register into a pathway your submission vendor cannot yet execute.

Cost is the category practices ignore because there is nothing to submit — CMS calculates it entirely from Medicare claims data already on file. For 2026, the inventory holds at 35 cost measures, unchanged from 2025, but CMS modified how one of the most commonly attributed measures, Total Per Capita Cost (TPCC), assigns responsibility. The updated rules exclude candidate events initiated by an advanced-practice-clinician TIN-NPI when every other non-advanced-practice TIN-NPI in the same group has already been excluded on specialty grounds, and they tighten what counts as a valid second candidate-event service — it now has to be an E/M or related primary care service delivered within 90 days by a TIN-NPI in the same TIN that has not itself been excluded.

The practical effect for a multispecialty group: which of your TINs gets attributed cost responsibility for a given patient can shift under the new rules even though nothing about how you deliver care changed. CMS also finalized a two-year informational-only feedback window for any future new cost measure — clinicians and groups will see their score on a new cost measure for two performance periods before it counts toward their final score. No new cost measures are being implemented for 2026, so this glide path does not apply yet, but it is worth knowing before CMS adds one.

Four dates matter this cycle, and they are not evenly spaced — two of them have already passed for anyone planning ahead of this post.