Changes Proposed to MIPS Value Pathway for Dermatology in 2026

August 8, 2025

The Centers for Medicare and Medicaid Services (CMS) is proposing updates to the Dermatological Care MVP for the 2026 performance year.

Although MVP reporting is currently voluntary, CMS has expressed the intention of sunsetting traditional MIPS and transitioning to MVPs entirely in the future. In the 2025 MIPS proposed rule, CMS requested feedback on the possibility of making MVPs mandatory as early as 2029.

Anatomy IT will continue to advocate for MVPs to be optional and for improvements to the Dermatological Care MVP to make it possible for all dermatologic subspecialties to be successful.

In this blog, we’ll break down what changes are proposed for the measures and activities in the Dermatological Care MVP. For more details on the current Dermatological Care MVP and how to report it, please visit our 2025 Dermatological MVP blog.

What Changes Are Proposed for the 2026 Dermatological Care MVP?

The following modifications are proposed for the 2026 Dermatological Care MVP:

Add 2 quality measures:
- 47: Advance Care Plan (topped out with 7-point cap)
- 238: Use of High-Risk Medications in Older Adults (topped out)
Remove 4 quality measures:
- 130: Documentation of Current Medications in the Medical Record
- 487: Screening for Social Drivers of Health
- AAD17: Continuation of Anticoagulation Therapy in the Office-based Setting for Closure and Reconstruction After Skin Cancer Resection Procedures*
- AAD18: Avoidance of Opioid Prescriptions for Closure and Reconstruction After Skin Cancer Resection*
Remove 1 improvement activity:
- PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B

*AAD17 and AAD18 were not requested for removal by DataDerm.

To see all the measures and activities that would be included in the 2026 Dermatological Care MVP, click on the category names below.

Dermatological Care Measures (Specific to This MVP)

Quality

Proposed 2026 Dermatological Care MVP Quality Measures

Green = Proposed for Addition; Red = Proposed for Removal

Report 4 of the following (at least 1 outcome):

47: Advance Care Plan (high priority)
130: Documentation of Current Medications in the Medical Record (high priority)
176: Tuberculosis Screening Prior to First Course of Biologic and/or Immune Response Modifier Therapy
226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
238: Use of High-Risk Medications in Older Adults (high priority)
397: Melanoma Reporting (high priority)
410: Psoriasis: Clinical Response to Systemic Medications (outcome)
440: Skin Cancer: Biopsy Reporting Time – Pathologist to Clinician (high priority)
485: Psoriasis – Improvement in Patient-Reported Itch Severity (outcome)
486: Dermatitis – Improvement in Patient-Reported Itch Severity (outcome)
487: Screening for Social Drivers of Health (high priority)
503: Gains in Patient Activation Measure (PAM®) Scores at 12 Months (outcome)
509: Melanoma: Tracking and Evaluation of Recurrence (high priority)
AAD6: Skin Cancer: Biopsy Reporting Time – Clinician to Patient (high priority)
AAD8: Chronic Skin Conditions: Patient Reported Quality-of-Life (high priority)
AAD12: Melanoma: - Appropriate Surgical Margins (outcome)
AAD16: Avoidance of Post-operative Systemic Antibiotics for Office-based Closures and Reconstruction After Skin Cancer Procedures (high priority)
AAD17: Continuation of Anticoagulation Therapy in the Office-based Setting for Closure and Reconstruction After Skin Cancer Resection Procedures (high priority)
AAD18: Avoidance of Opioid Prescriptions for Closure and Reconstruction After Skin Cancer Resection (high priority)

Improvement Activities

Proposed 2026 Dermatological Care MVP Improvement Activities

Red = Proposed for Removal

Report 1 of the following:

BE_4: Engagement of patients through implementation of improvements in patient portal
BE_6: Regularly Assess Patient Experience of Care and Follow Up on Findings
BE_15: Engagement of patients, family and caregivers in developing a plan of care
EPA_2: Use of telehealth services that expand practice access
EPA_X: Enhance Engagement of Medicaid and Other Underserved Populations
EPA_X: Provide Education Opportunities for New Clinicians
PM_16: Implementation of medication management practice improvements
PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B
PSPA_8: Use of Patient Safety Tools
MVP: Practice-Wide Quality Improvement in MIPS Value Pathways

Cost

Foundational Layer (Applies to All MVPs)

Population Health

Population Health Measures

You will be automatically scored on both of the following population health measures. CMS will assign you the highest of the two scores.

479: Hospital-Wide, 30-Day, All-Cause Unplanned Readmission (HWR) Rate for the Merit-Based Incentive Payment Systems (MIPS) Groups
484: Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions

Promoting Interoperability

Promoting Interoperability Requirements

The PI requirements for an MVP are the same as those for traditional MIPS.

All of the following attestations and measures are required (no exclusions):

Use of CEHRT
Actions to Limit or Restrict Interoperability of CEHRT
ASTP/ONC Direct Review
High Priority SAFER Guides Assessment
Security Risk Analysis
Provide Patients Electronic Access to Their Health Information

All of the following measures are required (unless claiming an exclusion):

e-Prescribing
Query of Prescription Drug Monitoring Program (PDMP)
Immunization Registry Reporting
Electronic Case Reporting

One of the following options is required:

Option 1: Support Electronic Referral Loops by Sending Health Information + Support Electronic Referral Loops by Receiving and Reconciling Health Information
- Exclusions are available for both measures in this option.
Option 2: Health Information Exchange (HIE) Bi-Directional Exchange
Option 3: Enabling Exchange Under the Trusted Exchange Framework and Common Agreement (TEFCA)

You can optionally report on one (only one) of the following measures for 5 bonus points in the PI category:

Syndromic Surveillance Reporting
Clinical Data Registry Reporting
Public Health Registry Reporting
Public Health Reporting Using TEFCA*

*Proposed new measure for the 2026 performance year.

Other Proposed Changes Impacting MVPs

The following changes would affect all MVPs:

Qualified Registry (QR) and Qualified Clinical Data Registry (QCDR) Support: Because QRs and QCDRs report the 2026 measures and MVPs they will support to CMS by September 2025 and the Final Rule will not be published until October or November, CMS is proposing to allow QRs and QCDRs an additional year to support a new MVP after it’s finalized. This means that QRs and QCDRs would have until 2027 to start supporting MVPs finalized in 2026.
Subgroup Reporting and Specialty Composition: If you report at the group level and are part of a multispecialty group, you will be required to report at the subgroup level starting in 2026 (this was previously finalized). CMS is proposing to have groups self-attest to their specialty composition during the registration process beginning in 2026. CMS is also proposing to exempt small practices from the mandatory subgroup reporting requirement.

What If I Have Feedback on These Proposed Changes?

You can provide feedback to CMS on the proposed changes to this MVP (or voice any other changes you’d like to see) by commenting on the 2026 Medicare Physician Fee Schedule Proposed Rule. The comment period is open from now until September 12, 2025, at 11:59 pm ET.

Next Steps

Share this information with your colleagues.
Subscribe to our blog to get alerts on this and other important issues. You can subscribe using the field in our website footer below.
If you are an Anatomy IT client, contact your MIPS Expert if you have any questions.
If you are not an Anatomy IT client, contact us to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.

If you have any questions on this, let us know!

Written By: Sarrah Hakim, MHSA