For healthcare organizations participating in Medicare, MIPS reporting is not a checkbox exercise. It is a direct line to financial performance. Missing the mark means payment penalties that compound over time. Getting it right means actively building a stronger revenue position, not just avoiding losses.
This blog covers what MIPS reporting involves, who needs to do it, what the stakes are, and why some organizations consistently outperform others.
What Is MIPS Reporting?
MIPS, the Merit-Based Incentive Payment System, was created under the Medicare Access and CHIP Reauthorization Act (MACRA) in 2015. It replaced older Medicare incentive programs, including the Physician Quality Reporting System (PQRS), the Value-Based Modifier, and Meaningful Use with a single, unified performance framework under the Quality Payment Program (QPP).
MIPS is straightforward in concept. CMS evaluates eligible clinicians across four performance categories each year, assigns a composite score, and adjusts Medicare Part B payments accordingly. In practice, it’s considerably more involved.
The four categories are:
• Quality — Measures clinical outcomes and adherence to evidence-based care standards
• Cost — Evaluates Medicare spending relative to peers and risk-adjusted benchmarks
• Improvement Activities — Credits organizations for care delivery changes that improve outcomes, access, and safety
• Promoting Interoperability — Measures the use of certified EHR technology and health information exchange (HIE)
Each category carries a weighted percentage toward the final composite score, and CMS adjusts these weights periodically through the annual rulemaking process.
Who Is Required to Submit MIPS Data?
MIPS applies broadly, but not universally. Eligibility is determined by CMS volume thresholds based on Medicare Part B allowed charges, number of Medicare patients served, and total covered professional services.
Clinician types subject to MIPS include:
• Physicians (MD and DO)
• Nurse Practitioners
• Physician Assistants
• Clinical Nurse Specialists
• Certified Registered Nurse Anesthetists
Beyond individual clinicians, MIPS also applies to group practices and virtual groups. Organizations participating in the Medicare Shared Savings Program (MSSP) may report under MIPS APM scoring rules, which operate under a different set of benchmarks.
How MIPS Reporting Affects Medicare Reimbursement
MIPS uses a performance threshold model. For 2026, CMS has maintained the performance threshold at 75 points through the 2028 performance year. Organizations that score above the threshold receive a positive payment adjustment. Those that fall below receive a negative adjustment. Exceptional performers get access to a bonus payment pool on top of the standard adjustment.
As the AMA notes, payment adjustments can reach up to plus or minus 9% of Medicare Part B payments. For a large group practice or ACO, that kind of swing can translate into millions of dollars across a single performance year. Even a 1 to 2 difference in adjustment has material revenue implications.
The adjustment applied in a given payment year is based on performance data from two years prior, meaning performance in 2026 determines payments in 2028. That lag makes proactive reporting management critical.
MIPS Reporting Requirements: What Organizations Need to Submit
Reporting requirements vary depending on how an organization participates, as an individual, a group, or through an alternative payment model. That said, there are consistent elements most organizations need to address.
Quality measures require selecting from CMS-approved measures and reporting data that demonstrate clinical performance. According to CMS quality reporting requirements, organizations must report on at least six quality measures, including at least one outcome measure.
A growing share of those measures are submitted as electronic clinical quality measures (eCQMs). It is format CMS has formalized and is actively expanding across its quality programs. As defined by CMS, eCQMs use data electronically extracted from EHRs and health IT systems to assess care quality, replacing the slower, error-prone process of manual chart abstraction. They use standardized clinical logic, which means measure calculations are consistent, auditable, and capable of running against large patient populations in real time. CMS updates eCQM specifications annually to keep them aligned with current clinical guidelines.
CMS has been explicit that eCQM reporting is the future of the quality program. For ACOs, it is already mandatory, and the broader MIPS program is moving the same way. Organizations still relying on manual abstraction for quality reporting are working against a reporting infrastructure that is moving firmly toward electronic, EHR-integrated data. For those without the right systems in place, eCQM reporting introduces data completeness and patient matching challenges that directly affect scoring. Measure selection strategy and the ability to execute accurately across the full denominator population are what separate high-performing reporters from the rest.
Cost measures are calculated by CMS using Medicare claims data, organizations don’t submit cost data directly. For 2026, CMS finalized 35 cost measures with no new additions or removals. Incomplete HCC coding and risk adjustment gaps can hurt the cost score even when clinical care is strong.
Improvement activities require attestation that qualifying activities have been implemented, such as care coordination programs, beneficiary engagement strategies, or expanded access initiatives. For 2026, CMS added 3 new activities, modified 7, and removed 8, leaving 104 total available activities.
Promoting Interoperability has specific requirements around the use of certified EHR technology, e-prescribing, health information exchange, and patient access to electronic records. This category has a required minimum threshold, and failing to meet it results in a score of zero for the category.
MIPS Value Pathways: Where the Program Is Heading
MIPS is still the default for most organizations in 2026, but it is not the long-term destination. CMS has been steadily building out MIPS Value Pathways (MVPs) as the future framework for the program and the 2026 performance year marks a significant expansion of that effort.
MVPs are a structured reporting option that replaces the open-ended measure selection of traditional MIPS with a focused, specialty-aligned subset of quality measures, cost measures, and improvement activities. Instead of choosing from a library of 190 quality measures, organizations reporting under an MVP work within a defined pathway tied to their clinical area making the reporting more clinically relevant and, in theory, more meaningful as a performance signal.
MVPs are a structured reporting option that replaces the open-ended measure selection of traditional MIPS with a focused, specialty-aligned subset of quality measures, cost measures, and improvement activities. Instead of choosing from a library of 190 quality measures, organizations reporting under an MVP work within a defined pathway tied to their clinical area — making the reporting more clinically relevant and, in theory, more meaningful as a performance signal.
For 2026, CMS finalized 27 total MVPs, 6 newly added pathways covering diagnostic radiology, interventional radiology, neuropsychology, pathology, podiatry, and vascular surgery, alongside updates to all 21 existing MVPs. MVP reporting remains optional this year, but CMS has been transparent about its intent to eventually sunset traditional MIPS and make MVP participation mandatory, potentially as early as 2029.
For ACOs and larger value-based care organizations, staying ahead of the MVP timeline is part of sound MIPS strategy. The measure sets are becoming more clinically integrated, the reporting pathways more specialty-specific, and the program’s overall direction is toward fewer, more meaningful data points over broad compliance checklists.
MIPS Reporting for ACOs and Value-Based Care Organizations
For ACOs and larger value-based care organizations, MIPS reporting doesn’t exist in a vacuum. It intersects with MSSP reporting requirements, population health analytics, risk stratification work, and broader contract performance.
High-performing organizations don’t treat MIPS as a standalone compliance obligation. They treat it as part of their enterprise quality strategy. That means:
• Aligning eCQM measure selection with the population segments where the highest concentration of care gaps exists
• Using cost and utilization data to understand where performance is leaking before CMS calculates it
• Running continuous quality analytics rather than pulling data quarterly when submission deadlines approach
• Ensuring HCC capture and risk adjustment processes are robust enough to accurately reflect patient complexity
Organizations that operate this way consistently score better than those running MIPS reporting as a year-end activity. CMS estimates that approximately 84% of eligible clinicians will receive a positive payment adjustment for the 2026 performance year, with a projected median final MIPS score of 89.47 — which means there is meaningful room to either gain or lose ground depending on how well reporting is managed.
Common MIPS Reporting Challenges
Most organizations know MIPS is important. Fewer have the infrastructure to execute it well. Here’s where things typically break down.
- Fragmented data sources
When patient data lives across multiple EHR systems, quality measure calculations become incomplete. Missing data means missing denominator populations, which directly hurts scores. - Manual processes
Spreadsheet-based quality tracking is time-consuming and error-prone. It also makes mid-year course corrections nearly impossible because the data is always lagging. - No real-time visibility
Without dashboards that reflect current performance, organizations often don’t know where they stand until it’s too late to act. - Weak risk adjustment
Incomplete HCC coding doesn’t just affect value-based contracts, it affects MIPS cost category scoring. Providers treating complex patients need accurate risk documentation to avoid being penalized for appropriate utilization. - Keeping up with CMS rule changes
Measure specifications change every year. The 2026 QPP Final Rule alone spans thousands of pages, covering updates across all four performance categories. Staying current requires dedicated attention that many organizations can’t sustain with existing staff.
MIPS Reporting Deadlines for the 2026 Performance Year
CMS publishes specific submission windows each year and missing them triggers automatic negative payment adjustments. There are no extensions for most reporting pathways.
A few principles that apply regardless of the specific calendar:
• Performance tracking should be continuous throughout the year, not concentrated in Q4
• Measure specifications should be reviewed and validated at least quarterly
• Pre-submission audits are worth conducting, particularly for quality and Promoting Interoperability data
• Submission windows typically open in early Q1 of the year following the performance year and close within a few months
How Persivia Supports Accurate, Efficient MIPS Reporting
One of the harder parts of MIPS reporting isn’t understanding what to submit, it’s having the right data infrastructure to execute it consistently across a large and complex patient population.
Persivia’s Clinical Quality Management solution is built to handle this end-to-end. The platform aggregates data from multiple EHR systems and external sources, normalizes it using semantic processing and natural language processing, and applies clinical quality measure calculations across the full range of CMS-required measure sets. That includes eCQMs for both Eligible Providers and Eligible Hospitals, Chart Abstracted Measures, Promoting Interoperability, HEDIS and custom eCQMs for commercial payers, and The Joint Commission measures, covering the full spectrum of what healthcare organizations are expected to report across programs.
What makes a practical difference for MIPS reporting specifically is the combination of real-time performance monitoring and accurate measure attribution. Quality teams can see where care gaps exist and act on them during the performance year, not after the fact.
The results reflect that approach. Persivia’s customers achieve an average MIPS score of 91%, compared to a national average of 82%. And 72% of providers on the platform achieve a perfect score of 100. Those numbers come from infrastructure that treats quality reporting as a continuous process, not an annual event.
See how Mount Nittany Physician Group improved their MIPS score with Persivia.
Frequently Asked Questions
What is MIPS reporting in simple terms?
MIPS reporting is the annual process of submitting clinical performance data to CMS. The score across quality, cost, interoperability, and improvement activities determines whether Medicare Part B reimbursements increase, decrease, or stay flat in future years.
Is MIPS reporting mandatory?
Yes, for eligible clinicians and organizations that meet CMS volume thresholds. Organizations that don’t report receive an automatic negative payment adjustment.
What happens if an organization doesn’t submit MIPS data?
CMS applies a negative payment adjustment to Medicare reimbursements in the payment year tied to that performance year. The maximum negative adjustment is 9%.
What is the difference between MIPS and ACO reporting?
MIPS evaluates individual clinicians and group practices on a per-clinician or group basis. ACO reporting under MSSP looks at organizational-level performance and is tied to shared savings arrangements. The two can overlap, ACO participants may report under MIPS APM scoring, which operates under modified rules.
How do organizations improve their MIPS score?
The most consistent performance improvements come from better data capture, strategic measure selection, continuous quality monitoring, and strong HCC documentation. The AMA recommends that organizations track internal performance data throughout the year and validate data transmission regularly rather than treating reporting as a year-end event.
Conclusion
MIPS reporting has real financial consequences, and the organizations that handle it well treat it as a strategic function, not an administrative one. That means investing in the right processes, the right data infrastructure, and consistent visibility into performance throughout the year.
Whether it’s an independent group practice or a large ACO, a MIPS score reflects how well the underlying systems support the care clinicians are already delivering. Getting the reporting right means that work shows up in the reimbursements.
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