New MIPS Value Pathway Finalized for Podiatry in 2026

March 18, 2026

The Centers for Medicare and Medicaid Services (CMS) has finalized the Podiatry MVP, which is available for reporting in 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 Podiatry MVP to make it possible for all podiatric subspecialties to be successful.

In this blog, we’ll break down what MVPs are, how to report them, and what measures and activities are included in the new Podiatry MVP.

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 Registry Clearinghouse, 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.

While registries must support MVPs relevant to their clients, MEX5 and all REGCLR measures are only available through Registry Clearinghouse. Similarly, all USWR measures are only available through the U.S. Wound Registry.

*Because QRs and QCDRs report the measures and MVPs they will support to CMS by September of the year prior to the performance year and the Final Rule is not published until October or November of the year prior to the performance year, CMS finalized a new policy that, beginning in 2026, QRs and QCDRs have an additional year to support a new MVP after it has been finalized. This means that, for MVPs finalized in 2026 (i.e., the Podiatry MVP), QRs and QCDRs are not required to offer support until 2027.

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 Measures Are Included in the Podiatry MVP?

Click on the category names below to see the measures and activities that were finalized for this MVP.

Podiatry MVP Measures (Specific to This MVP)

Quality

Rehabilitative Support for Musculoskeletal Care MVP Quality Measures

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

126: Diabetes Mellitus: Diabetic Foot and Ankle Care, Peripheral Neuropathy – Neurological Evaluation
127: Diabetes Mellitus: Diabetic Foot and Ankle Care, Ulcer Prevention – Evaluation of Footwear
155: Falls: Plan of Care (high priority)
226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
317: Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented
358: Patient-Centered Surgical Risk Assessment and Communication (high priority)
374: Closing the Referral Loop: Receipt of Specialist Report (high priority)
MEX5: Hammer Toe Outcome (outcome, high priority)
REGCLR1: Heel Pain Treatment Outcomes for Adults (outcome, high priority)
REGCLR3: Bunion Outcome – Adult and Adolescent (outcome, high priority)
REGCLR5: Offloading with Remote Monitoring (outcome, high priority)
REGCLR8: Monitor and Improve Treatment Outcomes in Chronic Wound Healing (outcome, high priority)
USWR32: Adequate Compression at Each Visit for Patients with Venous Leg Ulcers (VLUs) Appropriate to Arterial Supply (outcome, high priority)
USWR33: Diabetic Foot Ulcer (DFU) Healing or Closure (outcome, high priority)
USWR34: Venous Leg Ulcer (VLU) Healing or Closure (outcome, high priority)
USWR35: Adequate Off-Loading of Diabetic Foot Ulcers Performed at Each Visit, Appropriate to Location of Ulcer

Improvement Activities

Rehabilitative Support for Musculoskeletal Care MVP Improvement Activities

Report 1 of the following:

BE_6: Regularly Assess Patient Experience of Care and Follow Up on Findings
BMH_12: Promoting Clinician Well-Being
CC_19: Tracking of Clinician's Relationship to and Responsibility for a Patient by Reporting MACRA Patient Relationship Codes
EPA_7: Enhance Engagement of Medicaid and Other Underserved Populations
PM_14: Implementation of Methodologies for Improvements in Longitudinal Care Management for High-Risk Patients
PSPA_7: Use of QCDR Data for Ongoing Practice Assessment and Improvements
PSPA_18: Measurement and Improvement at the Practice and Panel Level
PSPA_22: CDC Training on CDC’s Guideline for Prescribing Opioids for Chronic Pain
PSPA_23: Completion of CDC Training on Antibiotic Stewardship
MVP: Practice-Wide Quality Improvement in MIPS Value Pathways
PCMH: Electronic Submission of Patient-Centered Medical Home Accreditation

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 higher 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 Podiatry MVP 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 Podiatry 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