Traditional MIPS is the original way Medicare Part B clinicians report quality and performance data to CMS. For 2026, you need a final score of at least 75 points to avoid a penalty. Your score comes from four categories: Quality, Cost, Improvement Activities, and Promoting Interoperability. What you do in 2026 affects your Medicare payments in 2028.

What changed for 2026? Not much. CMS kept the 75-point threshold and the category weights the same. The updates are small: a new Security Risk Analysis attestation, a new TEFCA bonus option, and a few changes to measure and activity lists.

What Is Traditional MIPS, and How Is It Different From MVPs and the APP?

The Merit-based Incentive Payment System (MIPS) is part of the Quality Payment Program. It checks how well eligible clinicians perform and adjusts their Medicare Part B payments up, down, or not at all. Traditional MIPS reporting is the original pathway. You pick your own quality measures and improvement activities from CMS lists.

There are two other ways to take part. MIPS Value Pathways, often called MVPs, group measures by specialty or condition. The APM Performance Pathway, or APP, is for clinicians in Accountable Care Organizations and similar models.

CMS has not said when traditional MIPS will end. When it does, MVPs are expected to become the standard. For 2026, traditional MIPS is still fully available.

Who Has to Report MIPS in 2026?

You must report if you bill Medicare Part B and meet all three of these tests during the eligibility period: more than $90,000 in allowed charges, more than 200 Part B patients, and more than 200 covered professional services. These limits did not change for 2026.

If you meet only one or two of the tests, you can opt in. Opting in lets you earn a payment adjustment, so it can be worth it if you expect a high score.

Eligible clinician types include physicians, nurse practitioners, physician assistants, and several therapy and specialty roles. New Medicare enrollees are exempt in their first year. CMS posts final eligibility in December, and you can check your status any time with the QPP Participation Status Tool.

Eligibility is set per clinician and per practice. A group can have some clinicians who must report and others who do not, so check every NPI.

How Is the MIPS Final Score Calculated in 2026?

Your final score runs from 0 to 100. Each category adds points based on its weight.

Category	Weight
Quality	30%
Cost	30%
Improvement Activities	15%
Promoting Interoperability	25%

The performance threshold is 75 points. A score of exactly 75 receives a neutral adjustment of 0%. Scores above 75 may earn a positive adjustment, while scores below 75 can result in a penalty. Scores from 0 to 18.75 get the maximum penalty of 9%.

Here is a simple example. If your final score is 60, you are 15 points short. That means a negative adjustment on your 2028 Medicare payments. Positive adjustments vary each year because CMS has to keep the program budget neutral.

The performance period runs from January 1 to December 31, 2026. Some categories need data for the whole year, so early planning matters.

How Does the Quality Category Work?

Quality is worth up to 30 points. You report six quality measures for the full year. At least one must be an outcome measure or a high-priority measure.

Each measure must meet a data completeness rule. You need to report on at least 75% of the patients or cases that qualify for the measure. This applies to all payers, not just Medicare. A measure that falls short of 75% earns zero points, so this is where many practices lose their score.

You can submit through several collection types. These include electronic clinical quality measures (eCQMs), MIPS clinical quality measures (CQMs), qualified clinical data registry (QCDR) measures, and Medicare Part B claims measures. Claims reporting is open only to small practices.

CMS compares your results to national benchmarks and gives each measure up to 10 points. Some older measures are “topped out,” which means most clinicians already perform well on them. These measures have capped scoring, so picking them is a weak choice. Small practices get at least 3 points on a measure if they report at least one eligible case.

Choose measures that fit your specialty and your patient mix. Then watch them monthly, not once a year.

Do I Have to Submit Anything for the Cost Category?

No. Cost is worth up to 30 points, and you do not send any data. CMS calculates it from your Medicare claims for the full year. New cost measures have a two-year period where they are shown for information only. They do not count toward your score during that time. You cannot fix cost results late in the year. Accurate coding, care coordination, and avoiding repeat tests all help from January onward. Check your feedback reports during the year to see where you stand.

What Are Improvement Activities, and What Is the Easiest Way to Score Them?

Improvement Activities (IA) are worth up to 15 points. You attest that you completed activities for at least 90 days in a row. Most clinicians need to complete two activities. Small practices, rural practices, and practices in health professional shortage areas need only one. For 2026, CMS added three activities, changed seven, and removed eight. Check the current list before you pick.

Choose activities you already do. Examples include patient safety work, care coordination, expanded access, and population health efforts. Keep proof on file, such as policies, logs, or meeting notes. CMS can ask for it during an audit.

What Do Promoting Interoperability Reporting Requirements Look Like for 2026?

Promoting Interoperability (PI) is worth up to 25 points. You need certified EHR technology (CEHRT) and a minimum of 180 continuous days of data in 2026. If you did not begin by early July, a full 180 days no longer fit in this year.

PI has four objectives: e-Prescribing, Health Information Exchange, Provider to Patient Exchange, and Public Health and Clinical Data Exchange. You must report every required measure unless you qualify for an exclusion. If you miss a required measure without an exclusion, you can lose the whole category.

The HIPAA Security Risk Analysis is required every year. For 2026, you must also attest yes or no that you carried out risk management steps under the HIPAA Security Rule. The analysis should be done in the performance year and covers how you protect electronic patient data. Save the report and the dates.

You can earn bonus points for syndromic surveillance, clinical data registry reporting, and the new TEFCA option under Public Health and Clinical Data Exchange.

Some clinician types, such as nurse practitioners and physician assistants, are reweighted out of PI automatically.

How and When Do I Submit MIPS Data?

You have four main choices:

• Your EHR vendor
• A registry or QCDR
• Direct submission through the QPP website
• Medicare Part B claims, for small practices only

The window usually opens in January and closes on March 31 of the next year. For 2026 data, plan to submit in early 2027, and confirm the exact date on the QPP site.

You can report as an individual or as a group. Group reporting can save time, but one weak area affects everyone. Before you submit, check measure counts, completeness rates, the PI dates, and your IA proof.

Can I Get an Exception or Reweighting?

Yes, in some cases. CMS reweights categories for clinicians with special status, such as certain clinician types and small practices that apply for a hardship exception. You can also apply if extreme events, such as a natural disaster or EHR failure, kept you from reporting.

When a category is reweighted, its points move to other categories. For example, if PI is reweighted, IA rises to 30%. Apply early, keep records of what happened, and check the QPP site for the current deadline.

What Are the Most Common MIPS Mistakes?

Most lost MIPS points come from a few common mistakes that practices can avoid with early planning and regular monitoring:

• Missing the 75% completeness rule: Some practices report only Medicare patients, even though the rule applies across all eligible patients and payers.
• Starting PI too late: The 180-day reporting period can become difficult to manage if practices wait until later in the year.
• Skipping the security risk analysis: Rushing or missing this requirement can put the entire Promoting Interoperability category at risk.
• Choosing the wrong measures: Selecting easy measures that do not align with your specialty can result in weaker performance and lower scores.
• Ignoring feedback reports: Waiting until the end of the year leaves little time to identify problems and make improvements.
• Missing the targeted review window: Practices should be aware of the 30-day period before and after final scores are released to address potential issues.

Finally, do not assume a neutral score is a safe goal. The program is budget neutral, so only higher scores earn real gains. Good strategies to succeed under MIPS in 2026 start with early measure selection and monthly data checks.

Should I Stay in Traditional MIPS or Move to an MVP?

It depends on your specialty and your systems. MIPS Value Pathways can fit well if there is an MVP for your specialty and your vendor supports it. They use fewer, more focused measures. Traditional MIPS gives you more freedom to pick measures, which helps if your specialty has limited MVP options.

Traditional MIPS in 2026 still works fine. Because its end date is not set, many practices test an MVP while keeping a traditional plan in place.

Frequently Asked Questions

Q1: What is the 2026 MIPS performance threshold? 

The threshold is 75 points. A final score of exactly 75 earns a neutral 0% adjustment, a higher score earns a positive adjustment, and a lower score leads to a penalty. CMS plans to keep the threshold at 75 points through the 2028 performance year.

Q2: What is the maximum MIPS penalty? 

The maximum penalty is 9%. It applies to final scores from 0 to 18.75 points. Scores between 18.75 and 75 receive a smaller penalty, and the adjustment is applied to your Medicare Part B payments two years after the performance year.

Q3: Is MIPS mandatory? 

Yes, if you bill Medicare Part B and meet all three eligibility tests: more than $90,000 in allowed charges, more than 200 Part B patients, and more than 200 covered services. If you meet only one or two tests, you can opt in. Clinicians in their first year of Medicare enrollment are exempt.

Q4: When does 2026 performance affect payments? 

Your 2026 results affect your Medicare Part B payments in 2028. The performance period runs from January 1 to December 31, 2026, you submit data in early 2027, and CMS applies the payment adjustment in 2028.

Q5: Do small practices have lighter rules? 

Yes. A small practice has 15 or fewer clinicians. These practices need only one improvement activity instead of two, can report quality measures through Medicare Part B claims, and earn at least 3 points on a quality measure if they report one eligible case. Small practices can also apply for reweighting of the Promoting Interoperability category.

Q6: Do I submit cost data? 

No. CMS calculates the Cost category from your Medicare claims for the full calendar year, so there is nothing to send. You can review your results in your feedback reports during the year. New cost measures are shown for information only during their first two years.

Q7: Can I report only Medicare patients? 

It depends on the collection type. For eCQMs, MIPS CQMs, and QCDR measures, data completeness covers all payers, so you must report on at least 75% of eligible patients no matter who their insurer is. Medicare Part B claims measures, which are open to small practices, cover Medicare Part B patients only. If a measure falls below 75%, it earns zero points.

Q8: What is the usual submission deadline? 

The submission window usually opens in January and closes on March 31 of the year after the performance year. For 2026 data, that means early 2027. Confirm the exact date on the QPP website, and try to submit early so you have time to fix errors.

Q9: Is traditional MIPS going away? 

CMS has not set an end date for traditional MIPS. MIPS Value Pathways are expected to become the standard at some point, but traditional MIPS is still fully available for 2026. It makes sense to learn how MVPs work now so a future change does not catch you off guard.

Your MIPS 2026 Action Plan

Confirm your eligibility. Pick six quality measures that fit your patients. Choose your improvement activities. Finish your security risk analysis. Check your PI dates. Review feedback reports each month. Then submit early in 2027.

How Can PHCS Help With Traditional MIPS Reporting?

Proactive Healthcare Services (PHCS) helps practices handle traditional MIPS reporting from start to finish. Our team checks your eligibility, selects measures that fit your specialty, tracks data completeness through the year, supports your HIPAA Security Risk Analysis, and prepares clean submissions before the deadline. We also help you compare your options and plan strategies to succeed under MIPS in 2026 and beyond. Contact PHCSS today to protect your Medicare payments and keep your reporting on track.