The Centers for Medicare & Medicaid Services (CMS) has proposed a significant change to the Merit-based Incentive Payment System (MIPS): traditional MIPS would end after the 2028 performance year, and MIPS Value Pathways (MVPs) would become the only MIPS reporting option beginning with the 2029 performance year for clinicians who are not participating in a MIPS Alternative Payment Model (APM).
This timeline is proposed and has not yet been finalized. MVP reporting remains optional for now. However, CMS is encouraging practices to begin preparing before a transition becomes mandatory.
For small practices, the additional lead time creates an opportunity to evaluate available MVPs, identify changes that may be needed and test a new reporting approach while traditional MIPS is still available.
What Is an MVP?
An MVP is a set of measures and activities organized around a specialty, medical condition or scope of care. Unlike traditional MIPS, which allows clinicians to select from the broader MIPS measure inventory, each MVP offers a smaller group of clinically related measures and activities.
CMS designed MVPs to make reporting more relevant to the care clinicians provide and to support more meaningful comparisons among clinicians reporting the same MVP.
Under current requirements, MVP reporting generally includes:
- Four quality measures selected from the registered MVP, or all applicable Medicare Part B claims measures included in the MVP if fewer than four apply
- One improvement activity from the MVP
- The Promoting Interoperability requirements, unless the participant qualifies for reweighting
- Cost measures calculated by CMS using administrative claims data, when attribution and case minimum requirements are met
For small practices, the Promoting Interoperability performance category is automatically reweighted to 0% unless they choose to submit data. CMS defines a small practice as a group with 15 or fewer clinicians identified by National Provider Identifier (NPI) who bill under the group’s Taxpayer Identification Number (TIN).
Why Start Planning Before MVP Reporting Is Required?
Waiting until a final transition year could leave limited time to address measure gaps, workflow changes, or data collection issues. Reviewing MVP options now allows a practice to determine how closely its current traditional MIPS measures align with an available MVP.
An early review may reveal that several measures already being reported are included in an MVP. It may also identify a new measure or improvement activity that requires changes to clinical documentation, data capture or internal workflows.
Practices can use the remaining transition period to:
- Compare current measures with the measures included in available MVPs
- Identify the MVP that best reflects the practice’s specialty or scope of care
- Determine which existing measures can continue to be used
- Test any new measures before MVP reporting becomes mandatory
- Review potential cost measures, even though CMS calculates them
- Confirm that the practice’s EHR, registry or other reporting partner can support the selected MVP
CMS’s new small-practice toolkit includes a Measure Mapping Tool that allows practices to enter the quality measures they currently report and see which finalized or proposed MVPs include those measures. Practices can also explore MVPs on our website here or use the Explore MVPs tools on the Quality Payment Program website. Because the mapping tool also displays proposed MVPs, practices should confirm that an MVP has been finalized before planning to report it.
A Gradual Transition May Reduce Risk
Practices do not have to move to MVP reporting all at once. CMS suggests identifying an MVP that overlaps with current reporting and testing one new measure or improvement activity while continuing to report traditional MIPS.
Another option is to report both an MVP and traditional MIPS while both pathways remain available. Under current CMS policy, clinicians receive the highest final score that can be attributed to them across the reporting and participation options they use. Practices considering this approach should coordinate carefully with their reporting partner to ensure the submissions are structured correctly.
Registering for an MVP also does not require a practice to submit it. A practice that registers but ultimately decides not to report the MVP may still report traditional MIPS, or the APM Performance Pathway if applicable, while those options remain available. However, registering alone does not satisfy MIPS reporting requirements.
Do Not Miss the MVP Registration Period
MVP participants must register before they can report an MVP. The registration period generally runs from April 1 through November 30 of the applicable performance year. Registration is completed through the QPP website by a user with the QPP Security Official role.
Practices planning to administer the CAHPS for MIPS Survey as one of their MVP quality measures face an earlier deadline. Both the MVP registration and the separate CAHPS for MIPS registration must be completed by June 30 of the performance year.
CMS allows changes to an MVP registration before the registration period closes, but a practice cannot report an MVP for which it did not register.
The MVP Identifier Is Essential
One of the most important operational differences is the use of an MVP identifier. The correct MVP ID must accompany measure and activity data submitted for an MVP. Without it, CMS may attribute the data to traditional MIPS instead of the selected MVP.
The requirement applies differently depending on the submission method:
- Uploaded files containing MVP measures or activities must include the appropriate MVP ID.
- Data submitted through a third-party intermediary using the QPP application programming interface must include the MVP ID.
- Practices reporting Medicare Part B claims measures must append the MVP ID to at least one Medicare Part B claim containing an applicable quality data code for a measure in the selected MVP.
- Practices manually attesting to an improvement activity must select the MVP reporting option during submission.
Practices should confirm well before submission that their reporting process can include the required identifier.
Recommended Next Steps for Small Practices
Small practices do not need to make an immediate reporting change, but they should begin assessing their options. A practical starting point is to:
- Confirm the practice’s MIPS eligibility and small-practice status using the QPP Participation Status Lookup Tool.
- List the quality measures and improvement activities currently being reported.
- Use the CMS Measure Mapping Tool or QPP exploration tools to identify MVPs with the greatest overlap.
- Review the complete requirements for the most relevant MVP, including quality, improvement activities, and cost measures.
- Identify any new data elements or workflow changes that would be required.
- Consider testing one new measure or activity before fully transitioning.
- Confirm that the selected reporting partner supports the MVP and can submit the required MVP identifier.
The proposed 2029 transition may seem distant, but measure selection and workflow preparation can take time. Practices that begin evaluating MVPs now will be better positioned to make a deliberate transition if CMS finalizes the proposal.
MDinteractive can help practices compare traditional MIPS measures with available MVPs, evaluate reporting options, and prepare for MVP reporting. Contact us at support@mdinteractive.com with questions about how the proposed transition may affect your practice.
This article summarizes CMS guidance and proposed policy available as of September 2026. Proposed policies may change before they are finalized. Practices should review the applicable final rule and current CMS guidance before making reporting decisions.