Finalized Policies in the CY 2026 Medicare Physician Fee Schedule Final Rule

The 2026 Medicare Physician Fee Schedule Final Rule is Here

The 2026 Medicare Physician Fee Schedule (MPFS) Final Rule is out and you’re wondering what it means for you. It’s packed with finalized updates on MIPS, six new MVPs, easier ACO reporting, a new program model, and acknowledgment of the extensive feedback received on multiple RFIs.

We’ll walk you through the highlights of what’s now official and show you how a QCDR like Patient360 can help you navigate these changes.

Breaking Down the CY 2026 CMS-1832-F Final Rule

The Centers for Medicare & Medicaid Services (CMS) has dropped its Medicare Physician Fee Schedule Final Rule for 2026, and, as usual, it’s a hefty one. This Final Rule outlines significant changes to the Physician Fee Schedule (PFS), the Quality Payment Program (QPP), and the Medicare Shared Savings Program (MSSP). It’s important to understand how these changes will affect your practice, your reporting, and ultimately, your revenue.

The Medicare PFS Final Rule is over 1,800 pages, so let’s break down some key areas.

Key Takeaways

• The MIPS performance threshold is finalized to remain at 75 points for 2026. (CMS did not finalize the multi-year proposal, reverting to annual rulemaking for 2027 and beyond).
• The transition from Traditional MIPS to MIPS Value Pathways (MVPs) continues, with CMS finalizing six new MVPs and changes to the inventory.
• Other MVP-related policies have been finalized, including changes to the registration process whereby multispecialty groups will split into subgroups through self-attestation, while small multispecialty groups can maintain their small group status.
• The Quality and Improvement Activities categories will see several finalized additions, removals, and changes.
• A new policy for the Cost category was finalized: new cost measures will have a two-year informational-only feedback period before being scored.
• Modest Promoting Interoperability changes were finalized, including modifications to the EHR SAFER Guide measure, suppression of the Electronic Case Registry requirement, and a new optional bonus measure.
• If you’re in an ACO, CMS finalized several minor but important changes, giving you more time to focus on improving quality measure reporting and adjusting to the APP program.
• CMS is launching a new program called the Ambulatory Specialty Model (ASM), which will indeed start with Performance Year 2027.
• CMS acknowledged extensive feedback received through RFIs on topics like FHIR rollout, the PDMP measure, and well-being measures, which will inform future rulemaking.

What’s Finalized in MIPS for the 2026 Performance Year

You should be aware that the MIPS 2026 Performance Year will bring several changes. CMS is aiming for program stability and simplification while advancing priorities like reducing burden, preventative care, and outcomes-focused assessment. The final regulations contain important updates that will affect your reporting and performance.

MIPS Performance Threshold Finalized to Remain at 75 Points for 2026

For providers participating in MIPS, the performance threshold is finalized to remain at 75 points for the 2026 performance year. This means you’ll need to achieve at least this score to avoid a negative payment adjustment.

Maintaining this threshold requires a continued focus on high-quality care. It’s a good idea to monitor your ongoing 2025 results in Patient360 throughout the performance period. Lessons learned indicate that monitoring and validating your data early and often is best practice. In addition, you should also review your 2024 Performance Feedback Scores in QPP, which are now available. Being informed about your past performance is a great way to make informed decisions and set attainable goals. 

CMS applies many scoring updates and changes AFTER submissions such as the cost category, complex patient bonuses, and various reweights, so awareness of your final score is extremely important!

Quality & Improvement Activity Measure Inventory Changes

CMS continues to advance priorities to reduce process measures in favor of outcome measures. Overall, CMS finalized adding 5 new, removing 10, and making substantive changes to 32 MIPS Clinical Quality Measures. Selecting measures that best represent your clinical area and ensuring accurate data collection are going to be key to optimizing your score.

For the Improvement Activities category, CMS finalized adding 3, modifying 7, and removing 8 activities while adding a new subcategory called Advancing Health and Wellness and removing the Achieving Health Equity category.

Changes to the Cost Category

CMS finalized its policy to provide a two-year informational-only feedback period for new cost measures starting with those finalized for the 2026 performance year. This feedback is designed to help you understand your performance and cost efficiency before these measures fully impact your MIPS score.

At Patient360, we saw this as a positive step for providers. In our formal comments on the proposed rule, we strongly advocated for CMS to also apply this new policy retroactively, specifically to the Low Back Pain (LBP) cost measure that was finalized in 2024. We argued this would provide much needed relief and a fair on-ramp for specialties just now being scored on that measure.

How did CMS respond? In the Final Rule, CMS did acknowledge our specific request. However, they did not adopt the recommendation. CMS stated that they did not propose to apply the policy retroactively. The measure was already finalized for the 2025 performance period. Clinicians have already made participation decisions based on the existing rules, and changing them now would disrupt those expectations.They explained that providers already receive adequate advanced notice and retroactively applying the policy would present operational challenges and confusion.

While the LBP cost measure will be scored as planned, this new two-year informational period for all future measures is a direct result of advocacy from many stakeholders.

As proposed, CMS did not add or remove any cost measures for 2026. They did finalize the proposed changes to the Total Per Capita Cost (TPCC) measure. The changes to this measure were not about what costs are in the measure, but about making the attribution of who is responsible for them much fairer and more accurate. CMS has posted the fully updated “2026 Total Per Capita Cost (TPCC) measure specifications” on its website, which reflect these finalized changes.

Promoting Interoperability Changes: TEFCA Bonus & Measure Suppression Policy

CMS finalized Promoting Interoperability changes, including modifying the Security Risk Analysis measure and the High Priority Practices Safety Assurance Factors for Electronic Health Record (EHR) Resilience (SAFER) Guide measure. Additionally, they finalized the addition of the Public Health Reporting Using Trusted Exchange Framework and Common Agreement (TEFCA) as an optional bonus measure. 

Clinicians will need to attest that they’re in active engagement with a public health agency to transfer health information using TEFCA to receive the bonus.

Another layer of flexibility CMS finalized for the Promoting Interoperability category is the ability to suppress measures. CMS also confirmed the suppression of the Electronic Case Reporting measure for the 2025 performance year.

Six New MVPs and Flexibility for Multispecialty Small Practices

The CY 2026 Final Rule finalized six new MVPs, expanding specialty options. These new pathways are designed to offer clinicians more relevant and manageable participation options for the following specialties: Diagnostic Radiology, Interventional Radiology, Neuropsychology, Pathology, Podiatry, and Vascular Surgery.

The rule reaffirmed that as of the 2026 performance year, multispecialty groups will no longer be a registration option for MVPs. To support this, CMS finalized its proposal to allow multispecialty groups to self-attest to the relevant area(s) of specialty focus when they subdivide and register as subgroups. Furthermore, multispecialty groups that are small practices (15 or fewer clinicians) will retain the option to register as a group.

Key Changes Finalized for 2026 MSSP ACO Reporting

For 2026, several important changes were finalized to continue streamlining MSSP APP reporting. Here is a deeper dive into the main changes, including how stakeholders reacted and why CMS finalized them.

• • Finalized: A revision to the definition of “eligible beneficiaries for Medicare CQMs.”
    • Commenter Feedback: This was overwhelmingly supported by commenters, including Patient360. The previous definition was complex and administratively burdensome, leading to confusion.
    • CMS Response: CMS finalized the policy as proposed, agreeing with commenters that this simplification was necessary. The new, streamlined definition, which focuses on beneficiaries who receive a primary care service from an ACO, reduces reporting burden and makes it much easier for ACOs to accurately identify their quality reporting population. This is already being operationalized for 2025 and you will notice it on your MCQM rosters if you report the MCQM collection type. Q2 & Q3 rosters have a PCS flag in them and the Q4 roster will automatically drop the non-PCS providers.  If you need to know more about this functionality in Patient360, let us know and we can walk you through it.
  • Finalized: Removal of the Health Equity Adjustment from the ACO quality score (effective PY 2026).
    • Commenter Feedback: This was very mixed with several pages of comments. Some commenters, like Patient360, supported the removal because the adjustment was seen as duplicative. Others, however, expressed concern about removing an incentive for health equity and proposed that CMS either retain it or rename it along with other requests that CMS said were out of scope.
    • CMS Response: CMS ultimately finalized the removal. They addressed commenter concerns by pointing out that other, more effective incentives already exist, making the adjustment duplicative and unnecessary. Specifically, they cited the Complex Organization Adjustment (which rewards ACOs for reporting eCQMs on behalf of complex populations.) 
  • Finalized: Removal of Quality ID 487 (screening for Social Drivers of Health).
    • Commenter Feedback: Most stakeholders supported this removal, but not because they oppose SDoH. The feedback, which Patient360 also shared, was that this measure is a simple check-the-box process measure. It only tracks if a screening was done, not if it led to a positive outcome for the patient.
    • CMS Response: CMS agreed. They finalized the removal, stating it aligns with their broader strategic shift away from low-bar process measures and toward meaningful outcome measures that track improvements in patient health.
  • Finalized: CAHPS survey changes for 2027 (expanding administration protocol to web-mail-phone).
    • Commenter Feedback: This proposal received support. Stakeholders, including Patient360, pointed to CMS’s own field test data, which showed that a “web-first” protocol dramatically increased patient response rates from 28% to 43%.
    • CMS Response: Given the strong positive feedback and the successful pilot, CMS finalized the policy. This change modernizes the survey, makes it more convenient for beneficiaries, and will result in more complete and statistically reliable data.

• Finalized: Expansion of EUC policies for ACOs to include those impacted by cyberattacks.

• • Commenter Feedback: This was met with universal support. Stakeholders, including Patient360, NAACOS, and other major provider groups, strongly endorsed this proposal. Commenters argued that a major cyber event, such as a ransomware attack, is the modern equivalent of a natural disaster like a hurricane or wildfire.
  • CMS Response: CMS finalized the policy as proposed. They acknowledged the  support and agreed that this change provides critical and necessary protection for ACOs who face significant operational and financial disruption from a cyber event.

• Patient360 Advocacy & CMS Denial: In addition to supporting this change, we at Patient360 strongly advocated for CMS to further expand the EUC framework. In our formal comments, we argued that the EUC policy fails to address a critical issue: structurally ineligible specialty TINs like Dermatology, Orthopedics, or Radiology within an ACO who cannot report the APP’s primary care focused measures due to measure inapplicability or EHR CEHRT limitations. We proposed that this be recognized as a valid circumstance for EUC relief.
  • In the Final Rule, CMS acknowledged these comments but did not adopt our recommendation. CMS stated they were not expanding the EUC qualification framework beyond the 20% beneficiary/location threshold or the newly added cyberattack provision. They stated the request to expand the EUC was out of scope. In other related discussions, the position is that ACOs are voluntarily formed entities and are responsible for their own composition. They did acknowledge the EHR CEHRT limitations by directing ACOs facing unresolvable EHR issues to the formal complaint process here: https://www.healthit.gov/topic/certified-health-it-complaint-process

• Finalized Quality Measures: Now that the rule is final, MSSP ACOs will NOT need to report Quality Measure 487. They WILL still need to report Quality Measure 113 (Colorectal Cancer Screening), which was finalized last year. Quality measures 112 & 113 for the APP Plus Quality Measures Set will continue to maintain flat benchmarking for 2026, while the other measures (001, 134, & 236) will likely have historical benchmarks applied as they will all be in the program longer than 2 years by 2026. 

NEW Program Model: Ambulatory Specialty Model (ASM)

CMS finalized its proposal for a new test model launching in 2027: the Ambulatory Specialty Model (ASM).

This model is intended to promote prevention, upstream management, and timely, targeted care of low back pain and heart failure. While many aspects of the model mirror MIPS/MVPs, including data completeness, benchmarking, and the same 4 categories; there are some key differences:

• Mandatory Participation: CMS finalized that the following clinician specialty types will be required to report at the individual level and, if eligible, will NOT report MIPS/MVPs. 
  • Heart Failure Cohort: Clinicians with a cardiology specialty code.
  • Low Back Pain Cohort: Clinicians with an anesthesiology, interventional pain management, neurosurgery, orthopedic surgery, pain management, or physical medicine and rehabilitation specialty.
    • Note: They did modify and finalize the proposed policy to allow for small practices to report the quality measure set at the TIN level (as a group.)
    • PI & IA categories will also be reported at the group level.
• Eligibility: Heart failure and low-back pain episode-based cost measures will be part of determining eligibility.
• Payment Adjustments: CMS finalized its plan to retain a percentage (15%) of the payment adjustment rather than distributing all funds.  
  • This model is different from MIPS in that it doesn’t rely on a budget-neutral penalty pot that can shrink to zero if everyone has a perfect score. Instead it creates a guaranteed ‘Incentive Pool’ where participants will be scored and then ranked against their peers.  
• Required Measures: ALL measures within the model’s Quality sets will be required.
  • For Low Back Pain this includes:
    • MIPS Q238: Use of High-Risk Medications in Older Adults (eCQM/MIPS CQM)
    • MIPS Q134: Preventive Care and Screening: Screening for Depression and Follow-Up Plan (eCQM/MIPS CQM)
    • MIPS Q128: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan (eCQM/MIPS CQM)
    • MIPS Q220: Functional Status Change for Patients with Low Back Impairments (eCQM/MIPS CQM). Note: CMS finalized Q220 despite significant commenter feedback, including from Patient360, regarding the measure’s high operational burden and lack of EHR interoperability.
    • Excess Utilization: Claims Measure: TBD
    • Cost Measure: Low Back Pain Episode-Based Cost Measure
  • For Heart Failure Cohort this includes:
    • MIPS Q492: Risk-Standardized Acute Unplanned Cardiovascular-Related Admission Rates for Patients with Heart Failure (Claims)
    • MIPS Q008: Heart Failure (HF): Beta-Blocker Therapy for Left Ventricular Systolic Dysfunction (LVSD) (eCQM/MIPS CQM)
    • MIPS Q005: Heart Failure (HF): Angiotensin-Converting Enzyme (ACE) Inhibitor or Angiotensin Receptor Blocker (ARB) or Angiotensin Receptor-Neprilysin Inhibitor (ARNI) Therapy for LVSD (eCQM/MIPS CQM)
    • MIPS Q236: Controlling High Blood Pressure (eCQM/MIPS CQM)
    • MIPS Q377: Functional Status Assessments For Heart Failure (eCQM)
    • Cost Measure: Heart Failure Episode-Based Cost Measure

CMS received significant feedback on this model, with many commenters like Patient360 and the AMA raising concerns about the mandatory nature and timeline. While CMS acknowledged these concerns, the model was finalized as proposed:

1. Problem Urgency

The primary reason CMS denied the delay is that they view the problems the ASM addresses, (high costs and poor outcomes in heart failure and low back pain), as too urgent to postpone.

CMS frames the ASM as the solution to reduce avoidable hospitalizations and unnecessary procedures for these significant areas of Medicare spending. From their perspective, any delay would simply slow progress in correcting these known problems, resulting in continued low-value care and unnecessary costs to the Medicare program.

2. The Timeline Provides Sufficient Preparation Time

CMS formally disagreed with commenters who felt the timeline was too aggressive. They argued that the finalized schedule already provides more than enough time for specialists to prepare:

• Notification Period: CMS will notify the preliminary list of mandatory participants by early 2026 through direct notifications (mail and/or email) and publicly via the CMS Innovation Center website. 

In CMS’s view, giving specialists a full year to prepare for a program is a sufficient and reasonable implementation timeline. In summary, their position is that the problem is too urgent to delay and the finalized timeline is already generous.

CMS Acknowledges Feedback: RFIs That Will Shape the Future

CMS actively sought input on several key areas in the Proposed Rule. The comment period is now closed, and the Final Rule confirms CMS received extensive, detailed RFI feedback that will directly shape future regulations.

Here’s a brief review of some of the Patient360 RFI feedback:

• FHIR Interoperability (dQMs)
  • What CMS Asked: CMS asked about the timeline, tools, and challenges for transitioning to FHIR-based digital quality measures (dQMs).
  • Patient360 feedback: Patient360 stated that the proposed 24-month optional reporting timeline was insufficient and unrealistic, recommending additional time. We also detailed the major technical and operational barriers that remain, such as the poor performance of Bulk FHIR APIs, the lack of standardized data mapping from EHRs, and the critical need for CMS to provide developer sandboxes and testing tools before any transition can be successful. This feedback provided CMS with the real-world hurdles.
• MVP Core Elements
  • What CMS Asked: CMS solicited feedback on which measures should be included in a foundational Core Elements set that would be part of all MIPS Value Pathways (MVPs).
  • Patient360 Feedback: Patient360 advised CMS to prioritize cross-cutting, condition-general measures (PRO-PMs like PROMIS) that allow for broad patient comparability while minimizing burden through the use of custom short forms.  Additionally, we advocated for leveraging psychometric cross-walking techniques, which would allow clinicians to continue using legacy tools (like the Oswestry) while mapping the data to a common, modern metric for reporting.
• Well-Being & Nutrition Measures
  • What CMS Asked: CMS sought input on new tools and measures that can be used to improve overall health proactively, focusing on well-being and a Food is Medicine approach to nutrition.
  • Patient360 Feedback: Patient360 recommended that CMS adopt specific PROMIS measures, including General Life Satisfaction, Meaning and Purpose and Ability to Participate in Social Roles and Activities as the standard for assessing patient well-being. We explained PROMIS tools are superior because they rely on modern measurement science (Item Response Theory). This allows them to be customizable and interoperable while maintaining a single, comparable scoring metric across the entire healthcare system, all with significantly lower burden on the patient.

This rule contained more RFIs than many previous rules. While Patient360 didn’t receive specific responses because RFI comments are legally distinct from Proposed Rule comments, our feedback is now part of the official administrative record. Just like the MVP framework took a couple of years to go from ‘RFI idea’ to ‘Formal Proposal,’ Patient360 and all other commenters have planted the seeds now for policies that will likely appear in future rulemaking, especially the feedback regarding FHIR.

How Patient360 Simplifies Navigating the 2026 CMS Final Rule

Patient360 is a QCDR partner that simplifies reporting and compliance with CMS requirements. We help healthcare providers understand these new and updated finalized policies, implement necessary changes, and ensure success in the 2026 performance year.

Patient360 offers expert guidance, simplified reporting, and real-time data analytics to help healthcare providers stay ahead of the curve. We provide updates on key CMS regulatory changes like this Final Rule, simplify data submission, and identify opportunities to improve MIPS scores and reimbursement. 

Patient360 is committed to providing proven tools and dedicated support to help practices thrive in the evolving healthcare landscape, reducing administrative burdens and allowing them to focus on patient care.