CMS Just Put a Date on the End of Traditional MIPS
After years of “eventually,” the CY 2027 proposed rule names a performance year: CY 2028 is the last one
Since 2019, CMS has said, in one form or another, that MIPS Value Pathways (MVPs) are the future and traditional MIPS reporting will not last forever. What has been missing is a date.
The CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P) supplies one: CMS proposes to sunset the traditional MIPS reporting option after the CY 2028 performance period. Starting with the CY 2029 performance period, MVPs would be the only MIPS reporting option for clinicians who are not in a MIPS APM. Those clinicians keep the APM Performance Pathway.
That gives MIPS-eligible clinicians through the end of 2028, roughly two more full reporting cycles, to have an MVP strategy in place. If your specialty does not have a natural MVP fit today, then that clock is the one to watch.
The MVP inventory is about to get a lot more crowded
CMS proposes 3 new MVPs for CY 2027: Diabetic Disease, Hypertension, and Hospitalist, bringing the total from 27 to 30. CMS says that covers a relevant reporting option for roughly 98% of specialties.
All 27 existing MVPs are getting modified too, and the Rehabilitative Support for Musculoskeletal Care MVP is being renamed to simply Rehabilitative Support MVP.
Virtual groups, which currently cannot report an MVP at all, would gain that ability starting with the CY 2029 performance period, timed to land exactly when MVPs become mandatory for everyone else.
A new kind of required measure: the “MIPS Core Measure”
This is one of the more consequential mechanical changes in the rule. CMS proposes a MIPS Core Measure designation, applied to 78 measures across the inventory, that would replace the current requirement to report an outcome or high-priority measure.
Traditional MIPS reporters would need a core measure as 1 of their 6 required quality measures.
MVP reporters would need one as 1 of their 4 required quality measures.
Small practices are exempt.
If there is genuinely no applicable core measure, clinicians can self-attest and substitute. But skip that step without the attestation, and you are looking at 0 of 10 points on that measure.
In the same breath, CMS proposes eliminating the “high priority measure” designation altogether, including it as a factor in deciding which measures get to stick around in the inventory.
The measure inventory is shrinking, a little
CMS proposes 180 quality measures for CY 2027, down from 190. This includes a mix of additions, replacements, removals, and substantive changes.
The proposed updates include:
2 new prevention and chronic-disease measures
5 new functional outcome measures for orthopedic patients, replacing 7 older ones
20 outright removals
Substantive changes to 43 existing measures
Seventeen measures would get “defined topped-out” benchmarks, and topped-out core measures would no longer be capped at 7 points. They would be eligible for the full 10.
Promoting Interoperability gets lighter, mostly
CMS proposes dropping the required ONC Direct Review attestation and the Security Risk Analysis measure, while making Electronic Prior Authorization optional for one more year. Electronic Prior Authorization would be required again in CY 2028, alongside a brand-new Electronic Prior Authorization for Prescription Drugs measure set to arrive in 2028.
Net effect: less required paperwork in 2027, with more specific, FHIR-enabled requirements phasing in for 2028.
Three things CMS is asking about, not proposing yet
The rule also includes Requests for Information on:
A 2028–2030 timeline for FHIR-based digital quality reporting
A possible MVP scoring methodology that would compare clinicians only to peers reporting the same MVP
A refresh of the star-rating methodology used for public reporting on Care Compare
None of this is final, but all of it previews where CY 2028 and CY 2029 rulemaking is likely headed.
What to do now
The performance threshold holds at 75 points through CY 2028, so nothing changes in the scoring bar itself this year.
What changes is the runway.
With a named sunset date, the right question for every practice is no longer “Should we look at MVPs?”
The right question is: “Which MVP, and by when?”
Comments on the proposed rule are due September 14, 2026.
Chirpy Bird Inc helps practices choose and transition to the right MVP before the mandate hits. Not sure which MVP fits your specialty? Let's map it out.
