Navigate the Latest MIPS and QPP Proposed Rule: A Comprehensive Overview for CY 2027
The Centers for Medicare and Medicaid Services (CMS) has officially released the 2027 Quality Payment Program (QPP) proposed rule. The 1,592-page proposed rule contains many changes that may take place in the 2027 MIPS performance year and beyond.
This blog breaks down the proposed changes to the QPP and MIPS for 2027.
Performance Threshold
CMS previously finalized maintaining the current threshold to avoid a penalty at 75 points through 2028. There are no proposals to change this.
Category Weights
CMS is not proposing changes to performance category weights in 2027.
Quality Category
Reporting Requirements
CMS is proposing that beginning in 2027, clinicians would no longer be required to submit an outcome or high priority measure. There would no longer be a high priority designation for measures; instead, clinicians would be required to submit at least one measure from a set of designated “MIPS Core Measures.” If none of the Core Measures apply to the clinician, they would have the option to attest to this and select a different measure. Small practices would be exempt from the Core Measures requirement.
Measure Scoring
Similar to the current scoring rule regarding the outcome/high priority measure requirement, CMS is proposing that clinicians who do not submit at least one Core Measure (and are not exempt or have not attested to there being no Core Measures relevant to them) would receive a 0/10 score on 1 of the 6 required Quality measures.
Additionally, Core Measures would not be subject to the topped out measure scoring method. Instead, they would receive defined benchmarks calculated using the same method applied to measures belonging to specialty sets with limited measure choice and a high proportion of topped out measures (see table below).
Click on the dropdown to see the Quality measures that will be scored using the defined topped out measure benchmarks.
The following measure scoring rules will remain in effect:
- Large practices (>15 clinicians) will continue to be scored on a 1–10-point scale for measures meeting data completeness and case minimum.
- Small practices will continue to receive a 3-point floor (i.e., they will be scored on a 3–10-point scale).
Bonuses
- No change to the small practice bonus or the improvement score bonus.
Measures
CMS is proposing the following changes to the 2027 Quality measure inventory:
- 10 new proposed measures
- 20 measures proposed for removal
- 43 existing measures with proposed substantive changes
Data Completeness Threshold
This will remain at 75% for performance years 2027–2028.
Cost Category
Cost Measure Inventory
CMS is not proposing any new cost measures or removals for the 2027 performance year.
Improvement Activities
Improvement Activities List
There are several proposed changes to the list of improvement activities (IAs), including:
- 6 proposed new IAs:
- Use of Data to Improve Practice Workflows
- Understand and Improve Diagnostic Performance
- Systematic Screening and Intervention for Nutrition and Other Health-Impacting, Non-Clinical Issues
- Advance Care Planning Conversations to Support Patient Wellness and Care Preferences
- Clinician Use of Artificial Intelligence (AI) to Improve Patient Care
- Lifestyle Approaches to Diabetes Remediation
- 5 changes proposed to existing IAs
- 11 proposed removals:
- BMH_5: MDD Prevention and Treatment Interventions
- CC_10: Care Transition Documentation Practice Improvements
- CC_11: Care Transition Standard Operational Improvements
- CC_12: Care Coordination Agreements That Promote Improvements in Patient Tracking Across Settings
- PSPA_2: Participation in MOC Part IV
- CC_16: Primary Care Physician and Behavioral Health Bilateral Electronic Exchange of Information for Shared Patients
- BE_15: Engagement of Patients, Family, and Caregivers in Developing a Plan of Care
- PM_19: Glycemic Screening Services
- PM_20: Glycemic Referring Services
- EPA_4: Additional Improvements in Access as a Result of QIN/QIO TA
- PM_2: Anticoagulant Management Improvements
Promoting Interoperability (PI)
There are many changes proposed for the PI category. Unless otherwise specified, changes would take effect in 2027.
ONC/ASTP Direct Review Attestation
CMS is proposing to remove the required ONC/ASTP Direct Review Attestation from the PI category beginning with the 2026 performance period.
Security Risk Analysis
CMS is proposing to remove the Security Risk Analysis (SRA) requirement from the MIPS PI category. Note that the SRA is required under HIPAA and thus would still need to be completed, even if finalized for removal from MIPS.
New Electronic Prior Authorization Measure
Under this measure, for at least one medical item or service (excluding drugs), clinicians would be required to attest “yes” to having requested a prior authorization electronically through a Prior Authorization API using CEHRT.
CMS is proposing to make this measure an optional bonus measure for 2027 and mandatory for 2028. CMS is also proposing that clinicians would receive an additional 5 points for this measure alone—that is, if you reported this measure and another bonus measure, you would have the potential to earn 10 bonus points.
New Electronic Prior Authorization for Prescription Drugs Measure
Under this measure, for at least one prescription drug, clinicians would be required to attest “yes” to having used CEHRT to complete a prior authorization request.
This measure would be mandatory beginning in 2028.
Request for Comment on Making Prior Authorization Measures Performance Rate-Based
For both Electronic Prior Authorization measures, CMS is seeking feedback on measuring performance (i.e., reporting a numerator and denominator) instead of requiring a “yes” attestation.
MIPS Value Pathways (MVPs)
CMS has officially proposed sunsetting traditional MIPS and making MVP reporting mandatory beginning with the 2029 performance year. Anatomy IT will continue to advocate for MVP participation to remain optional.
For the 2027 performance year, CMS has proposed 3 new MVPs: Diabetic Disease, Hospitalist, and Hypertension.
CMS is also proposing to apply the “MIPS Core Measures” requirement to MVP reporting. Each MVP would have a set of designated Core Measures. At least 1 of the 4 required quality measures submitted for MVP reporting would have to be a Core Measure. If none of the Core Measures apply to the clinician, they would have the option to attest to this and select a different measure. Small practices would be exempt from the Core Measures requirement.
Next Steps
- Share this information with your colleagues.
- 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
About the Author: Sarrah is the Director of Health Policy at Anatomy IT.
