Anatomy IT Advocates for MIPS Clients in 2026

September 19, 2025

Anatomy IT (AIT) asks Centers for Medicare and Medicaid Services (CMS) to consider your experience with quality reporting in comments submitted on the 2026 Quality Payment Program (QPP) proposed rule. See our previous blog for a summary of the proposed changes to the QPP in 2026. You can also refer to our previous blog on the Requests for Information (RFIs) included in the 2026 QPP proposed rule.

Quality Payment Program Comments

In AIT’s response to the 2026 QPP proposed rule, we focused on problems that our clients currently face under MIPS and flagged foreseeable challenges that could be caused by the proposed changes.

In the Quality section we:

Continued to advocate for our specialty and subspecialty clients.
- There are a decreasing number of relevant measure options, particularly at the subspecialty level.
- We emphasized the need for a comprehensive set of specialty- and subspecialty-specific measures to accurately reflect the quality of care delivered by these physicians.
Supported CMS’ decision to maintain the 75% data completeness threshold through 2028, but we expressed concerns about CMS’ plans to propose increases in future years.
Requested that CMS add an exception for all outcome measures for patients who pass away prior to the end of the outcome window.

In the Improvement Activities (IA) section we:

Advocated for small practices by encouraging CMS to maintain special scoring in future years.
Opposed CMS’ proposal to remove the eight IAs that were suspended this year. We asked CMS to reinstate these IAs as their suspension violated existing CMS regulation and created instability for MIPS physicians.

In the Promoting Interoperability (PI) section we:

Supported CMS’ proposal to suppress (not score) the eCR measure for 2025 due to the CDC’s pause in onboarding new healthcare organizations.
Supported CMS’ update to the Security Risk Analysis (SRA) measure with an important modification.
- CMS’ proposal would require clinicians to attest to implementing security measures during the performance year, in addition to conducting the SRA.
- Our requested modification: We asked CMS to extend the timeframe for implementation for practices that conduct their SRAs in the final quarter of the performance year.
Responded to CMS’ request for feedback on the Query of PDMP measure: we strongly refuted CMS’ plans for a future proposal to make this measure performance rate-based (numerator and denominator). States’ PDMPs are not yet ready to fully onboard all EHRs.
Responded to CMS’ request for feedback on making measures performance rate-based in the Public Health and Clinical Data Exchange objective. We urged CMS to avoid overburdening clinicians. We recommended that HHS focus on improving the infrastructure of state public health agencies, rather than attempting to use the MIPS PI category to achieve modernized data exchange infrastructure.

In the Cost section we:

Thanked CMS for proposing a two-year informational-only feedback period for new cost measures. This will allow time to evaluate and refine the measures before they impact clinician scores.
Enthusiastically supported CMS’ proposed change to the attribution for the Total Per Capita Cost (TPCC) measure.
- The proposed change would exclude advanced practice nonphysician practitioners (NPs/PAs/CCNSs) from TPCC if all other clinicians in the group are excluded based on the specialty exclusion criteria.
- This is a huge win for specialty practices that have been unfairly attributed the measure under the current approach.
Continued to advocate for increased transparency in measure development, more substantive information in feedback reports, and greater clarity in measure specifications.
Urged CMS to implement specialty attribution exclusions for episode-based chronic condition cost measures.
- This would ensure that only clinicians directly responsible for the care of a condition would be assigned the associated costs, thus avoiding a repeat of the broad and inappropriate attribution that occurred with the 2022 Diabetes Cost Measure.
- This would also mirror the exclusions in the TPCC measure.

In the MIPS Value Pathways (MVPs) section we:

Supported CMS’ proposal for groups to self-attest to their specialty composition during MVP registration, rather than CMS determining specialty based on two-digit specialty codes.
Supported the proposal to exclude small multispecialty practices from having to divide into subgroups beginning in 2026.
Advocated for increased measure choice in MVPs, particularly for subspecialists.
Responded to CMS’ request for feedback on the use of Medicare procedural codes:
- We cautioned CMS against using claims data to determine a clinician’s specialty in the future, as the information provided by claims has significant limitations and may not accurately depict the clinician’s true focus of care.
Advised against a potential future policy that would require clinicians to choose from a subset of mandatory measures in each MVP – termed “Core Elements”.
- This would further limit clinician choice and lead to specialists being forced to choose measures that may not be relevant to their practice.
Strongly advocated for MVPs to remain voluntary in all future years.
- In the proposed rule, CMS reiterated their desire to “sunset” traditional MIPS and make MVPs mandatory as early as 2029.
- We believe a fee-for-service model will always be both valuable and necessary. Moreover, we do not believe that MVPs will be applicable to specialists in the timeline CMS is anticipating.

Next Steps

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Written By: Sarrah Hakim, MHSA