07/21/2025
QPP
New 2023 Quality Payment Program Participation and Performance Data Available
Today, the Centers for Medicare & Medicaid Services (CMS) released more participation and performance data for the 2023 performance year of the Quality Payment Program (QPP), including both Merit-based Incentive Payment System (MIPS) and Alternative Payment Model (APM) participation. The following resources are now available:
- Building on the previously released 2023 QPP Participation and Performance Results At-A-Glance (file download), the 2023 QPP Experience Report (file download) provides a more in-depth review of aggregated data on QPP program experience and review of program trends over time. It includes an expansive set of aggregated program metrics on participation, performance category scoring, final scores, and payment adjustments factors.
- The 2023 MIPS Value Pathway (MVP) Reporting Supplement (file download) expands on the MVP data in the Experience Report, highlighting scores and performance from all MVP data that was reported, even if the clinician or group ultimately earned their final score from traditional MIPS reporting.
- The 2023 QPP Public Use File provides clinician-level data at the Taxpayer Identification Number (TIN)/National Provider Identifier (NPI) level regarding MIPS eligibility, measure level scoring, performance category scoring, MIPS final scores, and MIPS payment adjustments factors.
CMS Proposes Policy Changes for Quality Payment Program
The Centers for Medicare & Medicaid Services (CMS) has issued its Calendar Year (CY) 2026 Medicare Physician Fee Schedule (PFS) Proposed Rule, which includes proposed policies for the Quality Payment Program (QPP).
The Notice of Proposed Rulemaking (NPRM) includes proposals for the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs), as well as several Requests for Information (RFIs).
Specifically, we’re proposing policies that:
- Continue the transformation of MIPS through MIPS Value Pathways (MVPs).
- Are responsive to feedback and concerns raised by interested parties.
- Maintain stability within the MIPS program through the established performance threshold.
2026 Policy Proposal Highlights
Key QPP policies that we are proposing in the CY 2026 PFS Proposed Rule include:
- Introducing 6 new MVPs for the 2026 performance year that are related to diagnostic radiology, interventional radiology, neuropsychology, pathology, podiatry, and vascular surgery.
- Introducing a 2-year informational-only feedback period for new cost measures, allowing clinicians to receive feedback on their score(s) and find opportunities to improve performance before a new cost measure affects their MIPS final score.
- Maintaining the current performance threshold policies, leaving the performance threshold set at 75 points through the 2028 performance year.
- Introducing Qualifying APM Participant (QP) determinations at the individual level, in addition to existing determinations at the APM entity level.
Overview of RFIs
We are also seeking feedback on RFIs about the following topics:
- Establishing Core Elements for MVPs, to require reporting on key quality measures within each MVP.
- Establishing a process to assign clinicians to an MVP, to facilitate the most relevant reporting for their scope of care.
- Transitioning to FHIR-based electronic clinical quality measure (eCQM) reporting in quality reporting programs.
- Understanding the current environment, including challenges, with collecting and exchanging high-quality healthcare data.
- Changing requirements for the Query of Prescription Drug Monitoring Program (PDMP) Measure and Performance-Based Measures in the Public Health and Clinical Data Exchange Objective.
How Do I Comment on the CY 2026 Proposed Rule?
To submit a comment, click here. Comments must be received by September 12, 2025.