CMS issued the CY 2027 Physician Fee Schedule final rule (CMS-1848-F) on November 4, 2026. For MIPS, the scoring rules hold steady, but the program's structure is shifting fast: a new core measure requirement, a leaner Promoting Interoperability category, and a firm end date for traditional MIPS.
Here is what changed, what it means for your 2027 performance year, and what to do now.
The headlines
The performance threshold stays at 75 points for CY 2027.
Traditional MIPS is available through CY 2030. MVP or APP reporting is required starting CY 2031, two years later than CMS proposed.
Every traditional MIPS and MVP reporter outside a small practice must report at least one MIPS core measure, or attest that none applies.
The Security Risk Analysis measure is removed from Promoting Interoperability. Electronic Prior Authorization is worth 10 bonus points in 2027 and becomes required in 2028.
Three new MVPs (Diabetic Disease, Hypertension, Hospitalist) bring the inventory to 30.
Shared Savings Program ACOs get a higher BASIC Level E sharing rate (60%) and can apply to reduce or eliminate Part B cost sharing, with a target start date of April 1, 2027.
The 2027 Traditional MIPS rules, category by category
| Category | Weight | What changed for CY 2027 |
|---|---|---|
| Quality | 30% | 180 measures (20 removed, 10 added, 43 revised). New MIPS core measure requirement replaces the outcome/high-priority rule. |
| Cost | 30% | No new or removed measures; annual code maintenance only. |
| Promoting Interoperability | 25% | Security Risk Analysis measure removed. Electronic Prior Authorization optional for 10 bonus points. |
| Improvement Activities | 15% | 6 new, 5 modified, 11 removed. New Advancing Health and Wellness subcategory. |
Eligibility. The low-volume threshold is unchanged: more than $90,000 in Part B allowed charges, more than 200 Part B beneficiaries, and more than 200 covered professional services. CMS estimates 586,925 MIPS eligible clinicians covering about $51.7 billion in allowed charges. QP and Partial QP status will now be determined at the TIN/NPI level.
Quality. Traditional MIPS reporters must include one MIPS core measure among their six measures; MVP reporters, one among their four. If no core measure applies, you attest to that during submission and report another measure. Skip both and you get 0 achievement points on one required measure. Small practices (15 or fewer clinicians) are exempt. Core measures that have been topped out for two or more years are now scored on a defined benchmark worth up to 10 points, instead of a 7-point cap, but full credit requires near-100% performance.
Cost. Nothing to submit; CMS calculates it from claims. Because it still carries 30% of the score, review your attributed measures and post-acute and referral spending.
Promoting Interoperability. The 100 base points come from e-Prescribing (10), PDMP query (10), Health Information Exchange (30), patient electronic access (25), and public health reporting (25). Bonus points: Electronic Prior Authorization (10) and an extra public health registry (5). The SAFER Guide and CEHRT attestations are still required. In CY 2028, Electronic Prior Authorization becomes required and a new prior authorization measure for prescription drugs is added.
Improvement Activities. New activities include Use of Data to Improve Practice Workflows, Understand and Improve Diagnostic Performance, nutrition and non-clinical screening, Advance Care Planning conversations, Clinician Use of AI to Improve Patient Care, and Lifestyle Approaches to Diabetes Remediation. If you used a removed activity in 2026 (for example IA_PSPA_2, Participation in MOC Part IV, or IA_BE_15), choose a replacement now.
What scoring above 75 is worth, and the road to MVPs
CMS's own model in the rule estimates a maximum positive adjustment of 1.34% and a median positive adjustment of 0.83% for the 2029 payment year. About 87.7% of eligible clinicians are projected to earn a positive adjustment, and roughly $330 million moves from low scorers to high scorers. On the downside, the median negative adjustment is -2.62%, and clinicians who don't report at all face the full -9%.
For a practice with $1,000,000 in Part B allowed charges, that is about $13,400 at the top of the range and $8,300 at the median, versus a $90,000 penalty for not participating. The upside is real but modest because MIPS is budget-neutral and the exceptional performance bonus has expired. The bigger financial story is protecting against the penalty, especially with the 2027 conversion factor falling 2.31% to $32.63 for non-QPs.
Our estimate of a realistic path past 75 (not a CMS projection): quality near 85%, full PI points (100; the 10-point prior authorization bonus only helps if you would otherwise fall short of 100), full IA credit, and cost performance around 60%. That combination lands around 83 to 84 points.
MVP timeline.
CY 2027: MVPs, traditional MIPS and the APP are all available. The core measure requirement starts.
CY 2029: virtual groups can report MVPs.
CY 2030: last year of traditional MIPS (2032 payment year).
CY 2031: MVP or APP reporting is required (2033 payment year).
With 30 MVPs available, now is the time to pick the pathway that fits your specialty and test it before it becomes mandatory.
ACO updates, next steps and resources
Shared Savings Program. The BASIC Level E sharing rate rises from 50% to 60%, and the prior savings adjustment scaling factor rises from 50% to 75%. A new growth adjustment rewards ACOs that bring in clinicians and beneficiaries new to value-based care. Approved ACOs may reduce or eliminate Part B cost sharing, with a target start date of April 1, 2027. The prepaid shared savings option ends after 2027, and in 2028 advance investment payments move to $45 per beneficiary per quarter for LIS, dual-eligible, or rural beneficiaries and a flat $25 for all others. The APP Plus quality set holds at eight measures, after CMS dropped two measures that had been scheduled to be added in 2027. A new Medicare eCQM collection type arrives, and the once-per-agreement-period beneficiary notice now has a May 30 deadline, with the follow-up communication requirement removed.
What to do now
Confirm 2027 MIPS eligibility for each TIN/NPI.
Choose traditional MIPS or an MVP and lock in your core measure.
Replace any removed improvement activities.
Ask your EHR vendor about FHIR-based electronic prior authorization for the 10 bonus points.
Keep your HIPAA security risk analysis current even though MIPS no longer scores it.
Map your MVP for CY 2031.
Chirpy Bird can help you with your MIPS strategy and performance and even model your 2027 score and the dollars behind it. Reach out at hello@chirpybirdinc.com.
Still not sure what to do to be compliant in 2026? Contact us today 888-647-7247
