The performance period for Medicare’s Merit-based Incentive Payment System 2026 reporting year runs from January 1 through December 31, 2026.

Performance during this period will directly impact Medicare Part B payments under the Physician Fee Schedule in the 2028 payment year.

A clinician or group’s final MIPS score determines whether they receive a negative, neutral, or positive payment adjustment. These adjustments apply to professional services billed under the Physician Fee Schedule and do not affect facility payments (e.g., services provided in hospital outpatient departments or ambulatory surgical centers).

This blog posts summarizes key updates to MIPS for 2026 and outlines practical considerations for clinicians and programs participating in the Quality Payment Program. For an update on Quality in wound care see topic "Quality in Wound Care".

What is MIPS ?

The Quality Payment Program is a CMS program established by law to shift Medicare reimbursement toward value and outcomes. Clinicians participate through one of two tracks:

• Merit-based Incentive Payment System
• Advanced Alternative Payment Models (Advanced APMs). For more information on APMs visit the QPP website.

Under MIPS, eligible clinicians report performance data across multiple categories:

• Quality
• Promoting Interoperability (if applicable)
• Improvement Activities

CMS calculates performance for the Cost category based on claims data.

Each clinician or group receives a final score from 0 to 100, which is compared to a performance threshold.

• Scores above the threshold may receive a positive payment adjustment
• Scores below the threshold may receive a negative adjustment (penalty) of up to 9%

Some MIPS categories require data to be collected throughout the entire year of 2026.

However, if you have not started collecting data for 2026 yet, it is not too late to start now. Submitting some data is better than submitting no data.

How has MIPS evolved over the past years? 

Box 1 below summarizes key updates since 2017. 

Box 1. Key updates in MIPS since 2017

What's new with MIPS in 2026? 

CMS has taken a measured approach for 2026, emphasizing stability while continuing the gradual evolution of the Merit-based Incentive Payment System toward more clinically aligned reporting through MIPS Value Pathways. Box 2 summarizes main 2026 Policy Changes for the Quality Payment Program.

Box 2. Summary of 2026 Policy Changes for the Quality Payment Program

How does MIPS affect payments to eligible clinicians? 

If you are required to participate in MIPS, you will earn a performance-based payment adjustment - up, down, or not at all - based on the 2026 data that you submit (or do not submit) by March 2027. Your Medicare Part B-covered professional services beginning on January 1, 2028. will be affected.

Your MIPS final score will determine whether you receive a negative, neutral, or positive MIPS payment adjustment. The 2026 MIPS payment adjustments vary between -9% and +9%. 

Table 1 below outlines how final scores relate to the size of your MIPS payment adjustment with a performance threshold of 75 points. The final score ranges will change if and when the performance threshold is updated through rulemaking.

Table 1. Final scores and MIPS payment adjustment with a performance threshold of 75 points

See CMS 2026 Quality Benchmarks User Guide with Scoring Examples.

In the 2026 MIPS, to avoid a payment penalty, eligible clinicians have to score a total of at least 75 overall MIPS points

How do I know if I am required to participate in MIPS? 

Clinicians listed in table 2 who bill Medicare through the Medicare Physician Fee Schedule and meet certain criteria are required to participate:

For eligible clinician types above, the quickest way to find out if a clinician meets participation criteria is by looking him/her up on the QPP Participation Status Tool. 

• You will need your National Provider Identifier (NPI) and Associated Taxpayer Identification Numbers (TINs). When you reassign your Medicare billing rights to a TIN (e.g., TIN that belongs to a hospital or practice), your NPI becomes associated with that TIN. This association is referred to as a TIN/NPI combination. 
• If the provider is required to participate, determine if provider is considered “Facility-based”. Medicare's goal for measuring performance at the facility level is to reduce reporting burden for MIPS eligible clinicians who are facility-based.
• For more information about eligibility: Review the CMS QPP website.

How can I report for MIPS 2026? 

There are three MIPS reporting frameworks available to MIPS eligible clinicians:

• Traditional MIPS, established in the first year of the Quality Payment Program, is the original framework for reporting to MIPS. You select the quality measures and improvement activities, in addition to the complete Promoting Interoperability measure set, that you will collect and report. Medicare collects and calculates data for the Cost performance category for you.
• The Alternative Payment Model (APM) Performance Pathway, or APP, is a streamlined reporting framework for clinicians who participate in a MIPS APM. The APP is designed to reduce reporting burden, create new scoring opportunities for participants in MIPS APMs, and encourage participation in APMs. The available quality measures might not offer relevant overlap with wound care practices.
• If you are in a Medicare Shared Savings Program (Shared Savings Program) Accountable Care Organization (ACO), your ACO will report quality data on your behalf. Shared Savings Program ACOs are required to report to APP Plus quality measure set.
• MIPS Value Pathways, or MVPs, are the newest way to fulfill MIPS reporting requirements. MVPs include a subset of measures and activities that are related to a given specialty or medical condition. MVPs offer reduced reporting requirements, allowing MVP participants to report on a smaller, more cohesive subset of measures and activities (within the measures and activities available for traditional MIPS).
• For the 2026 performance year, 27 MVPs are available. For wound care programs, the set "Value in Primary Care", “Podiatry”, and “Vascular Surgery” offer some measures that might overlap with their practice, however the available quality measures might not be relevant enough to meet the requirement to report 4 quality measures from the list provided in this MVP set. Examples of quality measures available in this set are:  
• Quality ID #47 (CBE 0326): Advance Care Plan
• Quality ID #487: Screening for Social Drivers of Health
• Quality ID #483 (CBE 3568): Person-Centered Primary Care Measure Patient Reported Outcome
• Check each MVP and identify QMs that may be pertinent to your wound care practice

CMS will sunset traditional MIPS through future rulemaking, at which point the MVP reporting option will become mandatory unless the clinician is eligible to report the APP.

How can I participate in MIPS 2026? 

"Participation options" refers to the levels at which data can be collected and submitted, or "reported", to CMS for MIPS.

There are 5 participation option for MIPS eligible clinicians: 1. as an individual, 2. group, 3. virtual group, 4. as an alternative payment model (APM) Entity or 5. Subgroup.

• 1. Individual: To participate as an individual, clinician needs to:
• Be identified as a MIPS eligible clinician type on Medicare Part B claims, (see Table 1),
• Have enrolled as a Medicare provider before 2026, 
• Not be a Qualifying Alternative Payment Model Participant (QP), AND
• Exceed the low volume threshold as an individual
• What is the low volume threshold? Medicare looks at your Medicare claims from two 12-month segments, referred to as the MIPS determination period, to assess the volume of care you provide to Medicare beneficiaries. Data from the first segment is released as preliminary eligibility. Data from the second segment is reconciled with the first segment and released as the final eligibility determination.
• The two 12-month segments for MIPS 2026 are: October 1, 2024 to September 30, 2025 and October 1, 2025 to September 30, 2026. Medicare will release final (reconciled) data from the 2 segments in December 2026.  Medicare will notify you when your new eligibility information is posted on the QPP Participation Status Lookup Tool
• Clinicians are required to participate in MIPS if, in both 12-month segments, you:
• Bill more than $90,000 for Part B covered professional services/ segment AND
• See more than 200 Part B patients/ segment AND
• Provide 200 or more covered professional services to Part B patients.
• If you start billing Medicare Part B claims under a practice’s TIN during segment 2, your eligibility at that practice will be based solely on the results from segment 2.
• If you’re not required to participate as an individual, you may still be required to participate (and receive a payment adjustment) if:
• Your practice chooses to participate as a group
• You are part of an approved virtual group
• You participate in a type of APM called a MIPS APM
• 2. Group: Collect and submit data for all clinicians in the group.
  
• 3. Virtual Group: Collect and submit data for the clinicians in several groups, through a CMS-approved virtual group (traditional MIPS only). A formal election is required.
• 4. Alternative Payment Model (APM) Entity: Collect and submit data for the clinicians identified as participating in the MIPS APM.
• 5. Subgroup: Collect and submit data for a subset of clinicians in the group. This participation option is only available to clinicians reporting an MVP. Advance registration is required.
  

How do I get started?

Follow this MIPS 2026 Key Steps and Timeline:

1. Determine eligibility for QPP (Now): Check if you are required to participate by using the QPP Participation Status Tool.
2. If participation is required, determine if you’re participating in MIPS as an individual, group, virtual group, and/or APM Entity (Now)
3. Choose your reporting pathway: Determine whether you will report through Traditional MIPS, an MIPS Value Pathways, or participate through an APM (if applicable).
4. Understand Thresholds: The performance threshold remains at 75 points.
5. Collect performance data (2026):
1. Quality is typically reported over the full calendar year (Jan 1–Dec 31) for optimal scoring
2. Promoting Interoperability and Improvement Activities generally require a minimum of 90 consecutive days
3. Cost data is calculated by CMS based on claims
6. Performance categories:
1. Traditional MIPS & MVP: Quality, Cost, Improvement Activities, Promoting Interoperability
2. MIPS APM participants are scored under MIPS, often receiving full credit for Improvement Activities
7. Monitor eligibility: Review your participation status periodically throughout the year
8. Submit data: Submit performance data (directly or via a Qualified Clinical Data Registry (QCDR) or Qualified Registry between January and March 2027
9. Review feedback: Performance feedback becomes available in mid-2027
10. Preview public reporting: Late 2027 to early 2028
11. Payment adjustments applied: Throughout 2028

Table 3. Summary of traditional MIPS 2026 - categories, submission requirements and collection period  

NOTE: to visualize columns on the right, scroll down to the bottom of the table and slide it to the right

* This percentage can change due to Exception Applications or Alternative Payment Model (APM) Entity participation. 

There is a “non-pressure ulcer” cost measure under development by CMS, which will be directly relevant to wound care eligible clinicians.

How can WoundReference help eligible clinicians and groups perform well in MIPS? 

• Quality category: WoundReference provides clinical algorithms/pathways that naturally highlight quality measures that clinicians can more easily meet in wound clinics. By following the algorithms and protocols, not only clinicians can perform well in the MIPS Quality category, but will also practice evidence-based wound care.
• Cost category: WoundReference’s content and tools are designed with cost-effectiveness in mind. Tools such as the Formulary Module enable clinics to smoothly set up a local wound dressings formulary and save in inventory/supply costs. Another example is the TeleVisit Tool 2.0, which allows efficient use of time for clinicians and patients. 
• Improvement Activities category: And last but not least, by using WoundReference’s decision support protocols and tools eligible clinicians and groups can easily meet the number of measures required in the Improvement Activities category. See topic "MIPS in Wound Care and Hyperbaric Medicine - Improvement Activities".

More topics on MIPS will be published soon. To find out more about how WoundReference can help clinicians perform well in MIPS, contact us.