Blog
If You Bill Under More Than One TIN, This APM Proposal Is for You
CMS proposes moving Qualifying APM Participant (QP) determinations from the NPI to the TIN/NPI level—closing a loophole that currently extends MIPS exemptions and higher conversion factors to TINs with zero APM participation. For clinicians billing under multiple TINs, this redraws exemption status and reporting obligations. Paired with a $2.38 billion windfall correction, the message is clear: incentives must track actual participation. The CY 2027 Physician Fee Schedule also adjusts conversion factors ($33.17 QP vs. $32.84 non-QP) and thresholds. Comments are due September 14, 2026.
CMS Just Proposed Sunsetting Traditional MIPS: Here's Everything ACOs and MIPS Clinicians Need to Know About the CY2027 Rule
CMS proposes sunsetting traditional MIPS after 2028, making MVPs mandatory by 2029. New double-rate ACO modifiers (32% vs. 16%) reward ACO participation directly. MSSP benchmarking shifts to favor BASIC tracks, prior authorization eases in 2027 but doubles in 2028, and improvement activities gain a wellness focus. This is the biggest value-based care shakeup since MACRA began.
When PI Reweighting Helps, Hurts, or Simply Moves the Risk
MIPS Promoting Interoperability reweighting can reduce burden, but it's not a safety net. It often just shifts risk to other categories like Quality or Cost. Worse, submitting PI data can accidentally cancel your reweighting protection. Don't mistake relief for compliance. Know your status, document your decision, and model where the weight goes. Chirpy Bird helps practices review reweighting assumptions, avoid submission traps, and build a defensible MIPS strategy before reporting season ends.
The Big HIPAA Security Update Got Delayed to 2027, But Your 2026 Risk Assessment Just Got Harder
The federal government delayed major HIPAA Security Rule updates to 2027, but that doesn't ease your 2026 obligations. If you report MIPS Promoting Interoperability, your annual security risk assessment just got tougher. You must confirm it was done and prove you're fixing identified issues, or your entire PI score drops to zero. Don't mistake the delay for a pass. Use the extra year to get ahead. Chirpy Bird helps practices and ACOs meet current requirements and prepare for what's next.
OCR Is Watching: The Risk Analysis Initiative & What It Means for Your Practice
OCR’s Risk Analysis Initiative has made one thing clear: if you can’t prove you did a real Security Risk Assessment and acted on it, you’re exposed - on both HIPAA enforcement and your 2026 MIPS PI attestation.
Your Last 180-Day PI Window Has Started. Is Your Evidence Ready?
July 5 has passed, and the last 180‑day PI performance period for 2026 MIPS is now underway. From this point, Promoting Interoperability isn’t about “getting ready” anymore; it’s about proving your CEHRT, workflows, security, SAFER Guide, and public health reporting are actually in place and documented during the reporting window.
The Operational Blind Spots Hurting Performance
Healthcare organizations often mistake data dashboards for operational visibility. This false confidence is why many are blindsided by compliance failures. Compliance rarely fails during a regulation violation; it fails long before, when organizations lose sight of the workflows that create their performance. From drifting documentation habits to fragmented reporting, small operational changes accumulate into major audit risks.
The strongest organizations know they cannot just measure performance; they must understand why that performance exists. They use governance to challenge assumptions and test workflow integrity. In an era of expanded audits, operational visibility is not just a management tool—it is the strongest predictor of compliance resilience and a critical competitive advantage.
What to Fix Now Versus What to Leave Alone
Mid-year MIPS performance reviews often trigger a frantic scramble to fix every underperforming metric, but this activity can be a trap. The most successful organizations understand that strategic leverage, not busywork, is the key to improving scores. By mid-year, some performance issues are mathematically difficult to move, while others, like documentation and care gap management, remain highly actionable. The smartest strategy is to identify which problems still matter and focus resources there, rather than chasing marginal gains that create an expensive distraction.
The Operational Checks Smart ACOs Are Running Now
Strong performance dashboards can hide fragile workflows. As Q4 approaches, leading ACOs aren't just tracking metrics, but they are stress-testing the assumptions behind them. This article explores why operational maturity depends on validating attribution accuracy, documentation defensibility, and governance structures before reporting problems become visible. Discover why the most sophisticated organizations focus on understanding the systems that produce performance, rather than just celebrating the results.
The HIPAA Security Rule Just Changed: What Every Covered Entity Needs to Understand
The HIPAA Security Rule is changing in 2026, and the updates are more than just technical tweaks. Encryption, multi-factor authentication, and annual risk assessments are moving from optional or flexible expectations to required safeguards for every covered entity.
Operational Discipline Will Matter More Under LEAD
The transition from ACO REACH to LEAD is about more than reporting or compliance; it is a test of operational maturity, governance, and the ability to validate performance continuously rather than once a year.
CAHPS Registration Deadline: What Practices and ACOs Need to Do Before June 30
Practices using CAHPS as one of their four quality measures must complete registration by June 30. Missing this deadline can create avoidable reporting issues later in the performance year, so it is important to confirm eligibility, registration status, and submission responsibilities early.
Healthcare Leaders Are Carrying More Operational Anxiety Than They Discuss Publicly
By mid-year, six months of documentation, coding decisions, and workflow assumptions have quietly accumulated into real audit risk, yet most leaders aren't talking about it. The anxiety isn’t about failing an audit; it’s about not knowing if documentation would survive scrutiny. Strong organizations don’t wait for a payer inquiry. They treat the mid-year mark as a diagnostic checkpoint, asking not just “Are we passing?” but “Can we prove it?” Documentation isn’t a compliance checkbox - it’s a business asset that drives revenue integrity, quality reporting, and defensibility. The second half of the year starts with visibility, not hope.
What Changed in 2026: The Dual Attestation Requirement You Can't Afford to Miss
In 2026, the MIPS Security Risk Analysis measure is no longer just about checking a box. Practices must now attest to both completing the assessment and taking real risk management action to address identified vulnerabilities.
The Mid-Year APP Plus Validation Framework
Many MSSP ACOs still have hidden denominator leakage, and with APP Plus’ all‑patient, all‑payer requirements, a rigorous mid‑year denominator review is now essential to protect both shared savings and compliance.
Your MIPS Score Has a Single Point of Failure and It's Due by December 31
One missed attestation can zero out 25% of your MIPS score. Learn how the HIPAA Security Risk Assessment controls your entire PI category and why December 31 is the deadline that matters.
Your ASM Score Is Being Built Right Now And You Can’t See It Yet
Most cardiology practices assume performance problems begin when dashboards turn yellow. They don't. By then, the operational damage is already months old. A missed follow-up, an incomplete medication reconciliation, or a silent denominator shift quietly erodes future MIPS and APP Plus scores long before submission season arrives. Green dashboards create false confidence while workflow instability accumulates underneath. The organizations winning under modern CMS models aren't just documenting care—they're defending continuity monthly. Because your future reimbursement isn't built during reporting season. It's being shaped right now, inside your daily workflows.
Assigned, But Not Accounted For: Why Cardiac Attribution Errors Surface Too Late
Attribution errors rarely create immediate disruption. They build slowly, often unnoticed, embedded in workflows and data assumptions that appear stable on the surface. By the time these errors are visible, they are no longer easy to correct. They have already influenced performance scores, reporting accuracy, and financial outcomes. The absence of early signals is what makes them dangerous. If you are not actively managing attribution, you are reacting to it.
Follow This Closely: Why Follow-Up Is the Weakest Link in Cardiac Care Measures
From a CMS perspective, incomplete follow-up is indistinguishable from incomplete care. Follow-up failures create gaps in the narrative of care. If a measure indicates successful management of a cardiac condition, there must be documented follow-up to support that claim. The practices that succeed in MIPS are not necessarily doing more, they are doing what they already do with greater precision, structure, and accountability. Because in cardiac measures, the weakest link is not diagnosis or treatment. It is whether you can prove that the care continued.
Where Virtual Cardiac Care Loses Reportable Value
If your virtual cardiac care program is not mapped to reporting logic, then you are not just missing points, you are leaving defensible revenue on the table. From a CMS perspective, if the data is not captured in the right place, at the right time, and in the right format, it does not exist. The difference between high-performing programs and underperforming ones is no longer the care itself. It is whether that care can be measured, reported, and defended.