As CMS moves to end traditional MIPS, practices face a Nov. 30 MVP deadline

Practices that want to report a MIPS Value Pathway for the 2026 performance year have until Nov. 30 at 8 p.m. ET to register, and the deadline arrives as CMS proposes making MVPs the only MIPS reporting option three years from now.

The American Medical Association flagged both in its Sept. 18 National Advocacy Update, urging physicians to answer a new CMS survey on MVP adoption, especially if they object to the plan to retire traditional MIPS. Anders Gilberg, senior vice president of government affairs at the Medical Group Management Association, doesn't see the replacement as an upgrade.

"We are not the biggest fans of the value pathway approach, even though it is an alternative to MIPS," Gilberg told Physicians Practice in a July interview.

What CMS proposed

Under the calendar year 2027 Medicare Physician Fee Schedule proposed rule, CMS would sunset traditional MIPS reporting after the 2028 performance period. Starting with the 2029 performance period, which sets 2031 payment adjustments, MVPs would be the only MIPS reporting option for clinicians outside a MIPS alternative payment model, according to CMS' Quality Payment Program fact sheet. Clinicians in a MIPS APM could still report through the APM Performance Pathway.

None of it is final. The comment period closed Sept. 14, and the AMA expects a final rule by Nov. 1, according to its rundown of the proposal. CMS says it has signaled since 2019 that traditional MIPS would eventually go away, but this is the first rule to put a date on it.

The agency frames the timeline as ample runway for clinicians to pick the MVP most relevant to them, build workflows around its measures and set up subgroup data collection where needed. The rule would also add Diabetic Disease, Hypertension and Hospitalist MVPs for 2027, bringing the total to 30, and would let virtual groups report MVPs starting in 2029.

Why physician groups are pushing back

The AMA told CMS in its comment letter that it strongly opposes sunsetting traditional MIPS, arguing MVPs are not built around the conditions physicians actually treat and that critical gaps remain. The group has also said the move is not a true reform that reduces MIPS' administrative burden.

Gilberg's objection starts with history. Congress created MIPS when it repealed the sustainable growth rate formula more than a decade ago, and the program was supposed to move practices toward alternative payment models. "It was only meant to be a temporary bridge," he said. Instead, he said, "MIPS has just been sort of a reporting exercise, a compliance exercise," one that rewards practices that are good at reporting quality measures more than it tracks the care they deliver.

MVPs could make that worse for multispecialty groups, he said. In a 30-physician practice with several specialties, each specialty could end up reporting its own MIPS-like measure set, pushing one group's reporting load to dozens of measures. It is the same concern behind his "MIPS on steroids" description of MVPs in July.

MGMA and the AMA are backing legislative alternatives. The Medicare Physician Data-Driven Performance Payment System Act (H.R. 8622), from Reps. Mariannette Miller-Meeks, M.D., R-Iowa, and Herb Conaway Jr., M.D., D-N.J., would reform MIPS directly rather than push practices into MVPs, which Gilberg described as "doubling down on a problematic part of the fee schedule." The broader Patients First Act (H.R. 9693), the focus of a Sept. 15 House Energy and Commerce health subcommittee hearing, would replace MIPS with a streamlined, clinician-driven quality program, according to the AMA.

What to do before Nov. 30

For 2026, MVPs are still optional, and unlike other MIPS reporting options they require advance registration during a set window, according to the QPP registration page. Individuals, groups, subgroups and APM entities that want to report an MVP for 2026 must register by Nov. 30 at 8 p.m. ET.

CMS' MVP adoption survey asks whether a practice reported an MVP for 2025, is preparing to report one for 2026 or hasn't started. Participation is voluntary and confidential, responses reach CMS only in aggregate, and eligible clinicians may earn improvement activity credit for completing it, according to the AMA.

If the sunset is finalized, the 2026 through 2028 performance years become the window for testing an MVP while traditional MIPS remains a fallback. The performance threshold to avoid a penalty stays at 75 points through the 2028 performance year either way, the AMA noted.

CMS is expected to release the final rule by Nov. 1, giving practices about four weeks to see whether the sunset survives before MVP registration closes.