CMS has been building toward MIPS Value Pathways for several years now, and 2026 is the year the framework has enough specialty coverage that most practices have a genuine option to consider. With 27 MVPs available this year, including six newly added, the question for many clinicians isn’t whether MVPs exist for their specialty anymore. It’s whether switching actually makes sense.
Traditional MIPS isn’t going away this year, and while CMS has proposed to finalize by 2030, we won’t know for sure until November when the Final Rule is released. But the agency has been direct about its long-term intent to eventually sunset traditional MIPS entirely, making MVP reporting the standard path for most clinicians. That direction matters even if you’re not ready to switch today, since practices that wait until the option disappears entirely will have far less time to adjust workflows than those who start experimenting now.
This guide walks through what actually changes when you move from traditional MIPS to an MVP, what stays the same, and how to think about the decision before this year’s registration window closes.
What Actually Changes If You Switch
The most immediate difference is measure count. Traditional MIPS requires selecting six quality measures, including one outcome or high-priority measure. MVPs narrow that to four quality measures specific to your chosen pathway, still including one outcome or high-priority measure where available. CMS maintains full detail on how MVPs work through its MIPS Value Pathways page.
Improvement Activities narrows as well. Traditional MIPS generally asks for two activities. Under an MVP, you generally choose one and perform it for the same 90 continuous days required under traditional MIPS.
What doesn’t change is just as important. The same four performance categories apply, Quality, Cost, Improvement Activities, and Promoting Interoperability, using the same category weights as traditional MIPS. Promoting Interoperability still requires a continuous 180-day reporting period, and Cost is still calculated automatically from claims data. An MVP isn’t a different program. It’s a narrower, specialty-focused lens applied to the same underlying MIPS structure.
The Cost category has one meaningful nuance under MVPs worth understanding. Rather than being scored across the full range of cost measures CMS uses in traditional MIPS, MVP participants are scored exclusively on the cost measures included in their specific MVP, and only if they meet the case minimum for attributed patients on those measures. For specialists whose patient population doesn’t generate enough attributed episodes on a given cost measure, that measure simply doesn’t factor into their score at all.
Promoting Interoperability and the population health measures sit in what CMS calls the MVP’s foundational layer, which applies identically across every MVP regardless of specialty. If your practice already qualifies for automatic PI reweighting under traditional MIPS, whether due to small practice status, hospital-based status, or non-patient-facing status, that same exemption carries over under an MVP.
The Built-In Safety Net Most Practices Don’t Realize Exists
Here’s the detail that changes the risk calculation considerably: if you register for and report an MVP, you can still also report traditional MIPS in the same performance year, and CMS will calculate both and award you the higher of the two final scores.
This means trying an MVP this year isn’t an all-or-nothing decision. A practice that registers for an MVP but finds its traditional MIPS performance ends up stronger simply keeps the traditional MIPS score. The downside risk of testing an MVP is largely administrative, not financial, provided your MIPS/MVP Registry Reporting partner can actually track both pathways simultaneously without doubling your reporting workload.
Curious whether reporting both pathways this year would be worth the administrative lift for your practice? Contact us today and our team can walk through what dual reporting would look like for you.
Why CMS Is Pushing Practices Toward MVPs
CMS’s reasoning isn’t just about reducing measure count. MVP scoring compares your performance against other clinicians reporting the same MVP, rather than the broader MIPS population across every specialty. For clinicians whose specialty has historically had a limited or awkward fit within the general MIPS measure inventory, that narrower, more clinically relevant comparison can genuinely improve how fairly your performance gets scored.
CMS has said plainly that this direction is where the Quality Payment Program is heading long term, and that traditional MIPS is expected to be phased out eventually in favor of MVPs becoming the default reporting structure for most clinicians. Practices that adopt MVPs early get the benefit of building familiarity and internal workflows before the switch stops being optional.
The Multispecialty Group Complication
Starting with the 2026 performance year, multispecialty groups that aren’t small practices can no longer report a single MVP at the full group level. They’re required to report as subgroups or as individual clinicians instead. A subgroup is a subset of clinicians within the same TIN sharing a clinical focus, identified by at least one MIPS-eligible clinician alongside the group’s tax identification information.
This is a meaningful operational shift for larger multispecialty practices. Deciding which clinicians belong in which subgroup, and which MVP each subgroup should report, takes real planning, and it’s not a decision you want to make close to the registration deadline. Small multispecialty practices are exempt from this subgroup requirement and can continue registering as a full group if they choose.
A subgroup must include at least one MIPS-eligible clinician and cannot mix clinicians from different tax identification numbers. In practice, this often means grouping clinicians by the specific clinical focus they share rather than by department or location, which can require conversations with clinicians who haven’t previously had to think about how their individual performance data gets reported. A practice that waits until October to sort this out is unlikely to have time to do it thoughtfully.
For specialties where the standard MVP measure menu still doesn’t fit well, a QCDR offering specialty-specific measures can sometimes fill gaps that neither traditional MIPS nor a given MVP fully covers.
The Registration Window You Can’t Miss
Registration for 2026 MVP reporting opened April 1 and closes November 30, 2026 at 8 p.m. ET. Once that window closes, changes to your registration aren’t permitted, and you cannot report an MVP you didn’t register for, even if you decide later in the year that it would have suited your practice better.
Given that this deadline is still several months out from today, practices that haven’t yet decided still have time for a genuine evaluation rather than a rushed choice. That’s a meaningfully different position than practices find themselves in every December, when the decision window has effectively already closed.
At registration, you’ll also need to indicate whether you plan to count any administrative claims measures or the CAHPS for MIPS Survey measure toward your four required quality measures. That’s a detail worth confirming with whoever manages your reporting, since it affects how many measures you’ll actually need to actively collect data on versus how many CMS calculates on your behalf.
Not sure whether your practice still has time to make an informed decision before the deadline? Contact us and our team can help you weigh the options before November.
Who Should Actually Consider Switching
A few honest questions can help clarify whether an MVP is worth pursuing this year:
- Does an MVP exist for your specialty among the 27 currently available, and does its quality measure set genuinely reflect the care you provide
- Is your practice a multispecialty group that would need to plan a subgroup structure, and if so, is there enough time before November 30 to do that properly
- Would your traditional MIPS performance likely hold up as a safety net if you registered for an MVP and reported both
- Does your specialty currently struggle to find a strong fit within the general MIPS quality measure inventory, which is the exact gap MVPs were designed to close
How Patient360 Helps You Decide
As one of the original 16 CMS Qualified Registries, in continuous operation since 2009, Patient360 supports both traditional MIPS and MVP reporting through the same MIPS/MVP Registry Reporting platform, which means testing an MVP this year doesn’t require switching partners or rebuilding your reporting workflow from scratch.
Switching to an MVP isn’t a decision that needs to feel permanent, given that CMS lets you report both pathways and keeps whichever score is higher. What it does require is enough lead time to register correctly, plan any necessary subgroup structure, and confirm the MVP’s measure set genuinely fits your practice before the November deadline arrives.
If your practice is weighing whether this is the year to make the switch, reach out to Patient360, and let us help you compare your traditional MIPS performance against what an MVP would realistically offer before registration closes.
