A working checklist for practice administrators, quality specialists, and analysts: who has to report, how to decide between traditional MIPS and an MVP, what each of the four categories asks of you, when the windows open and close, and what has to be true on the day you file.
By Jonan Portal Alvarez, Chief Executive Officer, Alara Healthcare (management services) · Updated September 10, 2026 · About 10 minutes
None of these is reporting. All of them decide what reporting will be worth.
Eligibility is decided per clinician, from Medicare Part B volume over a lookback period, and it changes. Look up every clinician's status on the Quality Payment Program site rather than assuming last year's list. A clinician below the low-volume threshold can opt in or stay out, and the practice decides which, in writing.
As individuals, as a group under the tax identification number, as a subgroup, or through an APM entity. The choice decides whose data counts, whose score it is, and who signs. A group is scored once, and every clinician in it carries that score.
Traditional MIPS means six quality measures from the full inventory and two improvement activities, with no registration. An MVP is a specialty-shaped pathway with four measures, population health measures CMS computes for you, and a registration window that opens in April and closes at the end of November for 2026. Registering removes nothing: a registered group can still report traditional MIPS, and CMS keeps the higher score. Letting the window close is the only irreversible move.
Small practice, meaning fifteen or fewer clinicians, rural, health professional shortage area, non-patient-facing, and hospital-based statuses change what you must report and how it is scored: fewer improvement activities, bonus quality points, reweighting options. CMS assigns them from claims. Check them rather than claim them.
Data reaches CMS through a qualified registry, a qualified clinical data registry, your certified EHR, or, for small practices only, Medicare Part B claims. Attestations go through the Quality Payment Program portal. Someone in the practice needs a working sign-in with the right role before January of the filing year, not during it.
Promoting Interoperability requires certified EHR technology that meets the current certification criteria for the whole performance period. If the vendor's certification lapsed or the version changed, find out now. It is the difference between a scored category and a zero.
A MIPS final score is out of 100. Four categories feed it, each with a weight, and the weights have held for several years. The performance threshold for 2026 is 75 points: above it a positive adjustment, below it a negative one, both applied to Medicare Part B payments two years later, in 2028, and both capped at nine percent. Three categories you report. The fourth is computed for you.
| Category | Weight | What you report | Performance period | What decides the score |
|---|---|---|---|---|
| Quality | 30% | Six measures, at least one of them an outcome measure or, failing that, a high-priority measure. Small practices earn bonus points for reporting at all. | The full calendar year | Each measure is scored against a national benchmark for its collection type, not against 100 percent. A measure needs data completeness of at least 75 percent of eligible patients and a case minimum of 20 to score. Topped-out measures are capped. |
| Cost | 30% | Nothing. CMS computes it from claims after the year closes. | The full calendar year | Total per capita cost, Medicare spending per beneficiary, and episode-based measures, each with its own case minimum. Below the minimums the category is dropped and its weight moves to the others. |
| Improvement Activities | 15% | Attestation to activities the practice performed: two for most practices, one for small, rural, shortage-area, and non-patient-facing practices. | A continuous 90 days, at minimum | The attestation itself, and the evidence you can produce for it later. Nothing is measured, which is exactly why the record matters. |
| Promoting Interoperability | 25% | Measures from certified EHR technology: e-prescribing, prescription drug monitoring program query, health information exchange, patient access, and public health reporting, plus the required attestations. | A continuous 180 days, at minimum | A pass-or-fail gate first: the security risk analysis, the safety assurance guides, the information blocking and ONC direct review attestations, and the required measures. Miss any one and the category scores zero. Then points by measure. |
The measure set is chosen and the data inventory built: for each measure, which source feeds it and whether that source can reach 75 percent completeness. Last year's submission is in its final weeks. The Promoting Interoperability window can start now, and starting early leaves room to restart it if something breaks.
The prior performance year's submission closes. Sign-off, snapshot, and evidence filed. Then this year's baseline is set on last year's numbers.
MVP registration opens. Compare the traditional and MVP paths on live numbers before deciding, and register if a pathway fits, because registration removes nothing.
The last day a 180-day Promoting Interoperability period can start and still finish inside the calendar year. The security risk analysis should be scheduled by now, not merely planned.
Mid-year check on every quality measure: rate against benchmark, completeness against 75 percent, case count against 20. Measures that cannot reach the minimums are swapped now, while there is time to build the replacement's data. The improvement activities' 90 days begin no later than early October.
Gap closure for the quality measures, patient by patient. Hardship and extreme-circumstances applications are prepared for anyone who needs them. MVP registration closes at the end of November.
The last visits that count. Exception applications are due by the end of the year unless CMS extends them. The pre-submission readiness list starts running: what is complete, what is missing, what would score zero if filed as-is.
The submission window opens the first week of January and closes March 31. Snapshot, sign, file, lock, and retain. The locked snapshot is what a later query is answered with.
Performance feedback and the final score are released. A targeted review can be requested for a limited window if the score does not match what was filed. The payment adjustment applies to Part B claims from the following January.
Quality is the category the practice controls most directly, and the one most often filed wrong. Three rules decide it.
A measure scores against a benchmark for its collection type. A 90 percent rate where the national median is 95 scores badly. A 60 percent rate where the median is 40 scores well. The six measures worth submitting are the six that produce the highest total, which is not always the six with the best rates.
A measure below 75 percent data completeness or below 20 eligible cases does not score, whatever its rate. The mid-year check is about these two numbers before it is about performance.
A measure whose benchmark is topped out is capped at seven points. Improving it further scores nothing. That effort belongs on a measure with room above it.
The open measure gaps figure is the working list: for each selected measure, the eligible patients who have not met it. A high count can mean the care did not happen or that it happened and nobody can see it, and those need different responses. The first is a visit. The second is a data problem, and it is the one that quietly destroys completeness.
The pre-submission list, in the order the items tend to fail.
Alara Healthcare's quality service prepares the submission packet from the same screens the practice sees, works the open measure gaps from January rather than the fourth quarter, and coordinates the filing with your registry or EHR. The practice signs. Quality & HEDIS services
No. The score you can see is Quality, Promoting Interoperability, and Improvement Activities, weighted. Cost is computed by CMS from claims after submission, and nobody can know it beforehand. Q-Track shows a projection that stands in last year's Cost, and a range for what different Cost outcomes would produce. Read the locked score as the part you control.
Only clinicians and groups above the low-volume threshold are required to: more than 90,000 dollars in Part B allowed charges, more than 200 Part B patients, and more than 200 covered services, all three, over the determination period. Below that you may opt in if you meet at least one. Qualifying participants in Advanced APMs are excluded. Check each clinician's status on the Quality Payment Program site every year.
The structure is an asymmetry, not a dilemma. Registering for an MVP removes nothing, because a registered group can still report traditional MIPS and CMS keeps the higher score. Not registering removes the option for the year. So register if a pathway fits your clinicians' work, compare both paths on live numbers all year, and file whichever stands higher when the window opens.
The category scores zero unless it is reweighted for a hardship or a clinician type, and a zero there is a quarter of the final score. The window must start by early July to finish inside the year, and the security risk analysis must be completed inside the year too. Start the period in January and there is room to restart it if something breaks.
The share of all eligible patients, across every payer, that you actually reported for a measure. A measure below 75 percent does not score, except that small practices keep a small floor, and a measure whose source cannot see the care will never reach it. That is why the inventory, which names the source behind each measure, is checked before the rates are.
Six years. CMS can audit a submission for that long and will ask for the documentation behind quality data, improvement activity attestations, and Promoting Interoperability measures. The locked snapshot and its supporting data answer the numbers; the attestation evidence lives outside the platform and has to be kept as carefully.
Two years after the performance year. The 2026 score sets an adjustment applied to Medicare Part B payments through 2028, positive or negative, capped at nine percent, with positive adjustments scaled for budget neutrality. Performance feedback arrives in the summer between, with a short window to request a targeted review.
Bring a measure list and a sample extract to the demo and we will show which six produce the highest total, and what completeness looks like on your data.
