2027 MIPS Proposed Rule: What practices need to know about MVPs, core measures and reporting changes

Key takeaways:

• Traditional MIPS is proposed to sunset after the 2028 performance year
• MVP reporting is expected to become the standard reporting pathway beginning in 2029
• Three new MVPs are proposed for diabetes, hypertension and hospital medicine
• CMS is proposing to replace high-priority measure requirements with new Core Measure requirements
• Significant changes are proposed to the Quality measure inventory, including measure additions, removals and benchmark updates
• The Promoting Interoperability category remains largely unchanged, though CMS has proposed removing the Security Risk Analysis measure
• Practices should begin evaluating MVP reporting workflows now to prepare for future reporting requirements

Below is a summary of the webinar presentation.

MVPs: New additions and updates 

CMS has proposed the addition of some new MVPs so that every provider has an option to choose from. Three new MVPs are proposed to begin in 2027, bringing the total number of available MVPs to 30. The three proposed MVPs focus on diabetes, hypertension and hospital medicine, helping expand reporting options for clinicians whose specialties previously had limited MVP alignment.

Additionally, CMS is proposing updates to the 27 current MVPs, including the following:

• Adding Core Measures indications/requirements
• Adding/removing measures for Quality Measures, Promoting Interoperability (PI) and Improvement Activities (IA)
• Modifying the name of Rehabilitative Support for Musculoskeletal Care to Rehabilitative Support

For many practices, 2027 may be an ideal opportunity to begin building MVP reporting workflows. Reporting an MVP alongside traditional MIPS allows organizations to gain experience with the framework before it becomes the primary reporting pathway while still benefiting from CMS’s higher-score methodology.

Quality category: Changes to measure inventory

CMS is proposing substantial updates to the Quality category, including both measure additions and removals. These changes continue CMS’s efforts to streamline reporting and prioritize measures that better reflect clinical outcomes and value-based care.

• Removing 20 quality measures from inventory
• Adding 11 new measures
• Adding to the list of measures scored under the Topped-Out Measure benchmarks
• Making substantive changes to 43 existing measures
• Adding the “Core Measure” designation to 78 measures

A full list of measures proposed for removal, measures subject to topped-out benchmarks, and new measures can be found in the webinar slide deck.

Core Measures: A big change with minimal impact

Under the current program, clinicians are required to report an outcome measure whenever available. If an outcome measure is not applicable, they must instead report a high-priority measure, such as patient safety, care coordination, patient experience or efficiency measure.

For 2027, CMS is proposing the removal of the high-priority designation and replacing it with a new designation of Core Measure. They are also proposing the removal of the requirement to report an Outcome measure and instead requiring reporting at least one Core Measure. If a clinician or group does not have an applicable Core Measure, CMS is proposing a self-attestation process to attest to the lack of measure and report another measure in its place. If the attestation is not completed and a Core Measure is not reported, then the clinician or group would receive a score of zero for the required measure. Even if the clinician or group reports extra measures beyond the required number, failure to report a Core Measure or submit an attestation would result in a zero for this requirement.

While this represents a significant policy change, the practical impact on many practices may be limited because many commonly reported measures are expected to receive the core measure designation. Practices should review current measure inventory to determine whether at least one of their regulatory measures will qualify as a Core Measure under the proposed framework.

Promoting Interoperability: Continued focus on key areas

This category will not see too many changes as it will continue to focus on electronic prescribing, health information exchange, provider to patient exchange, public health and clinical data exchange and protecting patient health information.

Similar to prior reporting years, clinicians and groups must still collect data for all required measures – unless an exclusion can be claimed – for the same minimum continuous 180-day period. The final eligible 180-day performance period begins July 5, 2027, consistent with the 2026 reporting period requirements.

There were a few modifications under the Electronic Prior Authorization measure. This was originally proposed to be part of Promoting Interoperability for 2027 – but instead will be optional. It will be worth bonus points for 2027 and required for 2028. Additionally, practices must complete at least one prior authorization request for prescription drugs and medications under Electronic Prior Authorization for Prescription Drugs, beginning with the 2028 performance period.

The biggest change is that CMS has proposed removing the Security Risk Analysis (SRA) measure from the PI category starting with the 2027 performance period. Additionally, CMS has proposed removing ONC Direct Review and ONC-ACB Surveillance attestations, while transitioning electronic prior authorization measures into the category.

Practices should continue conducting annual Security Risk Analyses even if the requirement is removed from MIPS reporting, as HIPAA compliance obligations remain unchanged.

Improvement Activities: Remaining steady

CMS is proposing only limited changes to the Improvement Activities category for the 2027 performance year, including:

• Addition of six new activities divided into two sub-categories: Care Coordination and Advanced Health and Wellness
• Modification of five existing activities
• Removal of 11 activities  

Additional updates: Qualified participants, EUC policy updates and changes to the reweighting policy

CMS is proposing a change to how Qualified Participant (QP) status is applied. Under the current rule, QP status is directly tied to a clinician’s individual National Provider Identifier (NPI). This means if you earn QP status by meeting the patient/payment thresholds at one practice/tax ID, you’re automatically considered a QP at any additional practice/tax ID. CMS is proposing that QP status now be tied to the specific combination of a provider’s tax ID and NPI so the QP benefits will only be applied at the specific clinic that was participating in the Advanced APM.

Further, if a natural disaster hits an area, CMS can automatically apply an Extreme and Uncontrollable Circumstances (EUC) policy to protect clinicians from MIPS penalties. Currently, CMS only looks at the address listed in the PECOS (Provider Enrollment, Chain, and Ownership System) database for disaster zone location information. CMS is proposing removing the restriction to only use PECOS and will instead pull clinician location information from whatever data source is most current at the time of the disaster.

Finally, beginning with the 2027 payment year, CMS is proposing to extend the deadline for clinicians to notify them if a third-party intermediary didn’t submit their data due to circumstances outside of the clinician’s control. The deadline will be extended from November 1 to December 31.

New for 2027: Ambulatory specialty model

The new Ambulatory Specialty Model (ASM) is designed to hold participating specialists accountable for the upstream management of chronic conditions in Medicare beneficiaries. Initially, the model will focus on low back pain and congestive heart failure.

ASM will begin on January 1, 2027, and run for five performance years through December 31, 2031, with payment years running from January 1, 2029, through December 31, 2033. A preliminary list of affected physicians was released in February 2026. A final list is expected soon.

Clinicians are selected based on geographic location, episode volume, and participation within designated Core-Based Statistical Areas (CBSAs). Eligibility is based on 2025 data. Participation in this program is mandatory.

The 2027 Proposed Rule provides a clear indication of CMS’s long-term direction for MIPS reporting. Organizations that begin preparing now, particularly by evaluating MVP participation opportunities and reviewing their measure selection strategies, will be better positioned for future reporting requirements. 

Sources

• Centers for Medicare & Medicaid Services (CMS). CY 2027 Medicare Physician Fee Schedule Proposed Rule Fact Sheet. https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2027-medicare-physician-fee-schedule-proposed-rule
• Quality Payment Program (QPP). CY 2027 PFS Proposed Rule: QPP Fact Sheet and Policy Comparison Table. https://d2g5m5leph8kam.cloudfront.net/s3fs/s3fs-public/2026-07/2027-qpp-proposed-rule-factsheet.pdf?VersionId=ScdLrBiuoevDoAc6C8V5gCiMxCWFS5Au
• CMS Innovation Center. Ambulatory Specialty Model. https://www.cms.gov/priorities/innovation/innovation-models/asm
   
  

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