How Should Practices Prepare for Future CMS Rule Changes Impacting MVPs

The Centers for Medicare & Medicaid Services continues to reshape the Merit-based Incentive Payment System landscape through MIPS Value Pathways. While MVP reporting remains voluntary and running concurrently with MIPS, CMS is building toward a future where this framework becomes the standard for nearly all practices. The shift brings significant changes to how healthcare organizations measure quality, form reporting groups, and demonstrate value-based care.

Key Takeaways

MVPs are expected to replace traditional MIPS as the primary reporting structure, with CMS considering mandatory implementation as early as 2028.
Starting in 2026, multispecialty groups must form subgroups to report MVPs, adding complexity to the reporting process.
The 2026 performance year includes 27 available MVPs with streamlined measure requirements and automatic population health scoring.
Registration for MVP participation opens April 1 and closes November 30 annually, with earlier deadlines for practices planning to report CAHPS.
Practices can test MVP reporting voluntarily now while maintaining the safety net of traditional MIPS scoring if needed. If reporting via both collection types; MIPS & MVP, CMS will allocate the payment adjustment for the better of the 2 scores.

Understanding the MVP Framework

MIPS Value Pathways group together quality measures, improvement activities, and cost measures that relate to specific specialties or conditions. Instead of selecting six quality measures from hundreds of options, practices reporting through an MVP choose just four quality measures from a predetermined list.

For 2026, there are 27 MVPs available covering specialties from emergency medicine to surgical care. For 2026, CMS added six new pathways and consolidated two neurology-focused MVPs into a single pathway.

Starting in 2025, CMS automatically calculates all available population health measures for MVP participants and applies the highest-scoring one. This eliminates the need to select a population health measure during registration.

The Coming Mandatory Changes

CMS introduced MVPs as voluntary during the 2023 performance year and plans to keep them optional through at least 2027. However, the agency is considering making MVPs mandatory in 2028 and sunsetting traditional MIPS. This timeline gives practices a limited window to prepare.

The most immediate mandatory requirement affects multispecialty practices. Beginning in 2026, multispecialty groups will be required to form subgroups to report MVPs. A multispecialty group is defined as any practice with two or more specialty types as determined by Medicare Part B claims data. Single-specialty practices can continue reporting at the group level.

What Subgroup Reporting Means

Subgroup reporting allows larger multispecialty practices to create smaller reporting units based on specialty or care type. For example, a practice with primary care physicians, cardiologists, and orthopedic surgeons could form three separate subgroups. Each subgroup would report the MVP most relevant to their specialty.

While this adds flexibility, it increases administrative complexity. Each subgroup requires its own registration, measure selection, data collection, and submission. A practice that previously submitted one MIPS report might need to manage multiple MVP submissions, each tracking different measures.

CMS uses the initial 12-month segment of the 24-month MIPS determination period to establish eligibility for subgroups. Each eligible clinician can participate in only one subgroup per Tax Identification Number.

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Preparing Your Practice: A Strategic Timeline

2025: Test and Learn

This year offered the last low-risk opportunity to experiment with MVP reporting before mandatory subgroup requirements. Practices should have identified which MVPs align with their specialties and begun tracking relevant measures. Since MVP registration isn’t binding, if you registered by December 1st, and tested the process, you can fall back to traditional MIPS if needed.

Focus on two or three MVPs that will be most relevant to your practice long-term. This gives your team time to understand measure specifications and identify data collection gaps.

2026: Implement Subgroups

For multispecialty practices, 2026 marks a critical transition. You’ll need to form subgroups, assign each eligible clinician to a subgroup, and ensure each subgroup submits its relevant MVP. Start planning early. Consider which clinicians naturally group together based on specialty and which MVPs they’ll report.

Single-specialty practices have more flexibility but should still consider testing subgroup reporting for future readiness.

2027 and Beyond: Optimize Performance

With your subgroups established and tested, shift focus to optimizing performance within each MVP. Analyze which measures score well and which need improvement. Traditional MIPS is expected to sunset after 2027, making this possibly the final year to refine your approach.

Make sure you are caught up with all the current information about the Final Rule!

Key Registration and Reporting Requirements

Registration for MVP participation opens April 1 and closes December 1st of each performance year. However, practices planning to report CAHPS must complete registration by June 30.

During registration, you’ll select the MVP you intend to report, which clinicians will participate (if forming subgroups), and your reporting method.

The performance threshold remains at 75 points through 2028, and data completeness requirements stay at 75% through 2028.

Cost and Quality Measure Updates

CMS continues refining the measures used in MVP reporting. In 2025, the agency added six new episode-based cost measures, including one acute inpatient medical condition measure and five chronic condition measures. For 2026, they didn’t expand the existing inventory of 35 cost measures, but they did modify the Total Per Capita Cost (TPCC) measure.

Cost measures are calculated automatically by CMS using administrative claims data. Most cost measures require a minimum of 20 episodes before CMS includes it in your score.

CMS added five new quality measures for 2026 while removing ten others and making substantive changes to 30 existing measures. Review the updated measure inventory to ensure the measures in your chosen MVP align with your practice patterns.

nurse smiling while looking at a doctor

Working Within the Quality Payment Program

MVPs exist as one reporting option within the broader Quality Payment Program. Practices participating in Advanced Alternative Payment Models follow different rules, though some may still report through MVPs.

For practices involved in ACOs, understanding how MVP requirements intersect with ACO reporting obligations is critical. Some measures may fulfill requirements for both programs. However, this requires careful coordination and often benefits from specialized support in ACO management.

If your practice qualifies for QPP exception applications, review those options carefully. Certain circumstances allow reweighting of performance categories.

Getting Professional Support

The transition to MVPs represents a significant undertaking for most practices. When you’re ready to streamline your MVP reporting process and ensure your practice is positioned for success, explore comprehensive MIPS reporting solutions designed to simplify quality measurement and maximize your performance-based bonuses.

The right support system can transform MVP reporting from a compliance burden into a strategic advantage.

Taking Action Now

The shift to mandatory MVP reporting is coming. You have time to prepare, and voluntary reporting offers a low-risk way to build expertise. Start by identifying which MVPs align with your practice specialties, then test the reporting process while traditional MIPS still provides a safety net.

For multispecialty practices, 2026 marks a hard deadline for subgroup implementation. Begin planning now. Understanding the administrative requirements and data systems needed for subgroup reporting takes time.

The practices that will thrive are those that start preparing today. Use the voluntary years to experiment and refine your approach. By the time MVPs become mandatory, you’ll have the experience and systems in place to succeed.