Finalized Changes to 2026 MIPS Value Pathway for Physical and Occupational Therapy

March 13, 2026

The Centers for Medicare and Medicaid Services (CMS) finalized updates to the Rehabilitative Support for Musculoskeletal 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 Rehabilitative Support for Musculoskeletal Care MVP to make it possible for all specialists in physical and occupational therapy to be successful.

In this blog, we’ll break down what MVPs are, how to report them, and what changes were finalized in the 2026 MVP for physical and occupational therapy.

What is a MIPS Value Pathway (MVP)?

CMS introduced MVPs as an alternative reporting option to traditional MIPS in 2023. According to CMS, MVPs aim to simplify MIPS, reduce reporting burden, and help patients make more informed decisions when choosing their clinicians.

Each MVP has its own specific set of quality measures, improvement activities (IAs), and cost measures, and you are limited to those measures and activities when reporting the MVP. The Promoting Interoperability (PI) category is included as part of a “foundational layer,” meaning that PI requirements are the same for every MVP. Also included in the foundational layer is a population health measure, which contributes to your overall Quality score.

Can I Report an MVP Through a Registry?

Since 2023, Qualified Registries (QRs) and Qualified Clinical Data Registries (QCDRs), such as the Advancing Musculoskeletal (MSK) Care and Rehabilitation QCDR, have been required to support all measures in the Quality, IA, and PI categories of the MVPs relevant to their clinicians. They are not required to support the Cost category, Population Health measures, QCDR measures, or the CAHPS for MIPS Survey.

How Are MVPs Different from Traditional MIPS?

The table below highlights the differences by category between reporting traditional MIPS versus reporting an MVP.

If you choose to report both traditional MIPS and an MVP, CMS will assign you the higher of the two scores.

How Do I Report an MVP?

To report an MVP for the 2026 performance year, you must register between April 1, 2026, and November 30, 2026, at 8 pm ET. Registration is available through your QPP account.

At the time of registration, you must include the following information:

The MVP you are choosing to report,
Any administrative claims measures you would like to be included as 1 of your 4 required Quality measures,
Whether you are planning to count the CAHPS for MIPS Survey measure towards 1 of the 4 required Quality measures, and
Your participation level (group, subgroup, individual, APM).
- If you are reporting at the group level, you will have the chance to attest to being a single-specialty group or a small multi-specialty group (15 or fewer clinicians).
- If you report at the group level and are part of a large multi-specialty group (more than 15 clinicians), you are required to report at the subgroup level in 2026.

If you are an Anatomy IT client, we will discuss whether to report an MVP during your kickoff call.

What Are the 2026 Changes to the MVP for Physical and Occupational Therapy?

CMS finalized the following changes to the 2026 Rehabilitative Support for Musculoskeletal Care MVP:

Added 2 quality measures:
- 134: Preventive Care and Screening: Screening for Depression and Follow-Up Plan (eCQM, MIPS CQM, Medicare Part B Claims)
  - Topped out with 7-point cap (MIPS CQM and Medicare Part B Claims only)
- 182: Functional Outcome Assessment (MIPS CQM)
  - Topped out with 7-point cap
Removed 1 quality measure:

- 487: Screening for Social Drivers of Health *

Added 3 improvement activities:
- AHW_1: Chronic Care and Preventative Care Management for Empaneled Patients
- BE_15: Engagement of Patients, Family and Caregivers in Developing a Plan of Care
- BE_16: Promote Self-Management in Usual Care
Removed 4 improvement activities:

- AHE_9: Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols *
- AHE_12: Practice Improvements that Engage Community Resources to Address Drivers of Health *
- CC_1: Implementation of Use of Specialist Reports Back to Referring Clinician or Group to Close Referral Loop *
- PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B *

*These measures were also removed from traditional MIPS.

To see all the measures and activities included in the 2026 Rehabilitative Support for Musculoskeletal Care MVP, click on the category names below.

Rehabilitative Support for Musculoskeletal Care Measures (Specific to This MVP)

Quality

Rehabilitative Support for Musculoskeletal Care MVP Quality Measures

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

50: Urinary Incontinence: Plan of Care for Urinary Incontinence in Women Aged 65 Years and Older (high priority)
128: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan
134: Preventive Care and Screening: Screening for Depression and Follow-Up Plan
155: Falls: Plan of Care (high priority)
182: Functional Outcome Assessment (high priority)
217: Functional Status Change for Patients with Knee Impairments (outcome)
218: Functional Status Change for Patients with Hip Impairments (outcome)
219: Functional Status Change with Lower Leg, Foot or Ankle Impairments (outcome)
220: Functional Status Change for Patients with Low Back Impairments (outcome)
221: Functional Status Change for Patients with Shoulder Impairments (outcome)
222: Functional Status Change for Patients with Elbow, Wrist or Hand Impairments (outcome)
478: Functional Status Change for Patients with Neck Impairments (outcome)
MSK6: Patients Suffering From a Neck Injury who Improve Pain (outcome)
MSK7: Patients Suffering From an Upper Extremity Injury who Improve Pain (outcome)
MSK8: Patients Suffering From a Back Injury who Improve Pain (outcome)
MSK9: Patients Suffering From a Lower Extremity Injury who Improve Pain (outcome)

Improvement Activities

Rehabilitative Support for Musculoskeletal Care MVP Improvement Activities

Report 1 of the following:

AHW_1: Chronic Care and Preventative Care Management for Empaneled Patients
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
BE_16: Promote Self-Management in Usual Care
BE_26: Promote Use of Patient-Reported Outcome Tools
BMH_12: Promoting Clinician Well-Being
BMH_15: Behavioral/Mental Health and Substance Use Screening and Referral for Older Adults
CC_8: Implementation of Documentation Improvements for Practice/Process Improvements
CC_12: Care Coordination Agreements that Promote Improvements in Patient Tracking Across Settings
EPA_2: Use of Telehealth Services that Expand Practice Access
EPA_3: Collection and Use of Patient Experience and Satisfaction Data on Access
EPA_8: Provide Education Opportunities for New Clinicians
PSPA_16: Use Decision Support—Ideally Platform-Agnostic, Interoperable Clinical Decision Support (CDS) Tools —and Standardized Treatment Protocols to Manage Workflow on the Care Team to Meet Patient Needs
PSPA_21: Implementation of Fall Screening and Assessment Programs
PCMH: Electronic Submission of Patient Centered Medical Home Accreditation
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, if applicable. 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 of the following measures for up to 5 bonus points in the PI category:

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

Is Reporting the MVP for Physical and Occupational Therapy in 2026 Worth It?

Yes. CMS is considering making MVP reporting mandatory starting in 2029. That means there are only a few MIPS performance years left to find flaws, gather data, and recommend improvements before MVPs become the only way in which you can participate in MIPS and avoid a penalty. By reporting the 2026 Rehabilitative Support for Musculoskeletal Care MVP, you will:

Gain invaluable experience to prepare you for mandatory MVP reporting,
Not negatively impact your MIPS payment adjustment as long as you also report traditional MIPS (even if you score poorly in the MVP), and
Be able to provide real-world feedback to CMS to help them improve the MVP available to you before MVP reporting becomes mandatory. You can communicate with us to describe your experience with the MVP or you can tell CMS directly by commenting on the 2027 Medicare Physician Fee Schedule Proposed Rule this summer or by following the steps outlined here by CMS.

Next Steps

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Written By: Sarrah Hakim, MHSA