10/21/2026

Quality Payment Program (QPP)

Calendar Year (CY) 2027 CMS Physician Fee Schedule (PFS) Proposed Rule

The Centers for Medicare & Medicaid Services (CMS) has released the CY 2027 Medicare PFS Proposed Rule, which includes proposed policies for QPP. The proposed rule includes proposals for MIPS and Advanced Alternative Payment Models (APMs), and includes several Requests for Information (RFIs).  

Key QPP proposals that are applicable to small practices include:  

• Sunsetting the traditional MIPS reporting option after the 2028 performance year. 
• Introducing 3 new MIPS Value Pathways (MVPs) for the 2027 performance year related to diabetic disease, hypertension, and hospitalists, and modifying all 27 previously  finalized MVPs.  

Learn more about the QPP proposals by reviewing the following resources: 

• Overview of the 2027 Proposed Rule for the QPP (LINK)– This webinar provides an overview of proposed policies for the 2027 performance year of the QPP. CMS subject matter experts discuss proposed policy changes for traditional MIPS, MVPs, the Medicare Shared Savings Program, and APMs.  
• 2027 QPP Proposed Rule Fact Sheet and Policy Comparison Table (PDF, 815KB)– This resource provides an overview of QPP proposals and RFIs included in the CY 2027 Medicare PFS Proposed Rule, and a comparison table that contrasts existing policies with proposals. 
• Proposed Timeline: Transitioning from Traditional MIPS to MVPs (PDF, 1MB)– This graphic displays the timeline for sunsetting traditional MIPS as proposed in the CY 2027 Medicare PFS Proposed Rule.  
• MVP Transition Toolkit for Small Practices (ZIP, 1MB)– This new resource provides guidance for small practices participating in MIPS as they transition from traditional MIPS to MVP reporting. It includes a tool to help identify applicable MVPs based on the measures you currently report. 
• 2027 Proposed and Modified MVP Guide (PDF, 1MB)– This resource provides details on the newly proposed MVPs and proposed changes to existing MVPs.  
• Explore MVPson the QPP website – This webpage provides information on the proposals for new and updated MVPs.

2026 MIPS Value Pathway (MVP) Registration is Open until November 30

The MVP registration window is open for the 2026 performance year. Individuals, groups, subgroups, and APM Entities that wish to report an MVP can register or update an existing registration until November 30, 2026, at 8 p.m. ET. 

Did you know?  

Clinicians and groups registered for an MVP may report traditional MIPS instead of, or in addition to, the MVP you registered for. 

• If you report traditional MIPS instead of the MVP you registered for, your traditional MIPS submission will determine your final score. 
• If you report traditional MIPS in addition to the MVP you registered for, we’ll score both data sets and use whichever results in a higher score for your final score, either your traditional MIPS reporting or your MVP reporting.   

To register, you’ll sign in to the QPP website with your HCQIS Access and Roles Profile (HARP) account. 

You must have a HARP account and a QPP Security Official role to complete the MVP Registration. 

• For more information on HARP accounts, please refer to the Register for a HARP Account document in the QPP Access User Guide (ZIP, 5MB). 

For more information on obtaining the QPP Security Official role, review the Connect to an Organization document in the QPP Access User Guide (ZIP, 5MB). 

Prepare for MVP Registration

Before you register, you’ll need to have the following items ready: 

• The MVP you plan to report. 
• Whether you want to be evaluated on an outcomes-based administrative claims quality measure, if it’s a quality measure option in your selected MVP. 
• The participation option you plan to use. Participation options include individual, group, subgroup, or APM Entity. 

Additional Information for Group Registration  

Starting in 2026, to register for MVP reporting as a group, your practice will need to attest to their specialty composition (whether you’re a single specialty group or multispecialty small practice) during the MVP registration process. We won't make this determination for you. All other groups will need to participate as subgroups or as individuals (if eligible) to report an MVP.  

A single specialty group means a group that consists of clinicians in one specialty type, or clinicians in more than one specialty type with a single clinical focus of care. For example, a group consisting of internists, cardiologists, nurse practitioners, and physician assistants that are focused on providing cardiovascular care could attest to being a single specialty group and register to report an MVP as a group. 

Learn more in the MVPs Group and Subgroup Participation Examples (PDF).

How to Register

Individuals, groups, subgroups and APM Entities will register through the QPP website. You'll need to have the Security Official role to register your organization. Please refer to the QPP Access User Guide (ZIP, 5MB) for information about obtaining a Security Official role for your organization. To register: 

• Sign in to QPP
• Click Register or edit an MVP registration from the landing page 
• Click your MVP reporting option 

Note: If the CAHPS for MIPS Survey is an available measure in your chosen MVP and you wish to administer it as one of your four required measures, you should have completed your MVP registration and a separate CAHPS for MIPS Survey registration by June 30, 2026, at 8 p.m. ET. Visit the QPP website to learn more about CAHPS for MIPS registration. 

Additional Resources

• 2026 MVP Registration Guide (PDF, 2MB)
• 2026 MVPs Implementation Guide (PDF, 3MB)
• 2026 Explore MVPs

Reminder: 2026 Quality Payment Program Exception Applications are Available

The 2026 Quality Payment Program (QPP) exception applications are available now through December 31, 2026, at 8 p.m. ET. There are 2 types of exception applications allowing participants to indicate why they can’t report data for one or more Merit-based Incentive Payment System (MIPS) performance categories, MIPS Promoting Interoperability Performance Category Hardship Exception Application and MIPS Extreme and Uncontrollable Circumstances Exception Application. 

MIPS Promoting Interoperability Performance Category Hardship Exception Application 

Individual clinicians, groups, and virtual groups (or their third-party representative) can submit a MIPS Promoting Interoperability Performance Category Hardship Exception application for the following reasons: 

• You have decertified Electronic Health Record (EHR) technology (must be decertified under the Office of the National Coordinator for Health Information Technology (ONC) Health IT Certification Program). 
• You have insufficient internet connectivity. 
• You face extreme and uncontrollable circumstances such as a disaster, practice closure, severe financial distress, or vendor issues. 
• You lack control over the availability of certified EHR technology (CEHRT). 

This application is specific to the MIPS Promoting Interoperability performance category. If your application is approved, you won’t be required to report data for this performance category.  

REMINDER: Small practices, hospital-based clinicians, non-patient-facing clinicians, and ambulatory surgical center (ASC) based clinicians are automatically excepted from having to report data for the MIPS Promoting Interoperability performance category. 

MIPS Extreme and Uncontrollable Circumstances Exception Application 

Individual clinicians, groups, and virtual groups  

Individual clinicians, groups, and virtual groups (or their third-party representative) can submit a MIPS Extreme and Uncontrollable Circumstances (EUC) Exception application for one or more MIPS performance categories (quality, cost, improvement activities, and Promoting Interoperability) due to extreme and uncontrollable circumstances, defined as rare events entirely outside of your control and the control of the facility in which you practice, such as hurricanes, wildfires, floods, and other major disasters or public health emergencies. 

These circumstances would: 

• Cause you to be unable to collect information necessary to submit for a MIPS performance category. 
• Cause you to be unable to submit information that would be used to score a MIPS performance category for an extended period of time (for example, if you were unable to collect data for the quality performance category for 3 months). 
• Impact your normal processes, affecting your performance on cost measures and other administrative claims measures. 

If your application is approved, you won’t be required to report data for the performance category or categories approved in your application. However, please note that a qualifying data submission will override approved reweighting on a category-by-category basis. Qualifying data submissions will be scored, and those performance categories will contribute to your final score. 

Alternative Payment Model Entities  

Alternative Payment Model (APM) Entities, including Medicare Shared Savings Program Accountable Care Organizations (ACOs), can also submit a MIPS Extreme and Uncontrollable Circumstances application. APM Entities must request reweighting for all MIPS performance categories. If your application is approved, you won’t be required to report MIPS data, and any data submitted won’t be scored for purposes of MIPS. 

How to Apply 

To submit either exception application: 

• Sign in to the QPP website with your Health Care Quality Information System (HCQIS) Access Roles and Profile (HARP) account. 
• Choose “Exceptions Application.” 
• Click “Add New QPP Exception.” 
• Choose your exception type. 

Additional Resources 

• Quality Payment Program Access User Guide – Refer to “Step 1: Register for a HARP Account” 
• Exception Applications (webpage on the QPP website)
• 2026 MIPS Promoting Interoperability Hardship Exception Application Guide
• 2026 MIPS Extreme and Uncontrollable Circumstances Exception Application Guide
• 2026 MIPS Automatic Extreme and Uncontrollable Circumstances Policy Fact Sheet