CMS Requests Feedback in the 2026 QPP Proposed Rule

August 26, 2025

The 2026 Quality Payment Program (QPP) proposed rule includes several Requests for Information (RFIs), in which the Centers for Medicare and Medicaid Services (CMS) gathers feedback from the public to inform future rulemaking.

In this blog, we go over the RFIs in the proposed rule and how to share your feedback with CMS. For an overview of the major proposals, refer to our previous blog.

Promoting Interoperability RFIs

RFIs on the Query of Prescription Drug Monitoring Program (PDMP)

The Query of PDMP measure is a required measure under the MIPS Promoting Interoperability (PI) category. Currently, this measure is attestation-based. It requires the clinician to attest “Yes” to having checked the PDMP for the patient’s prescription drug history before electronically prescribing at least one Schedule II opioid or Schedule III or IV drug.

Making the Query of PDMP Measure Performance Rate-Based

CMS is considering making this measure performance rate-based in the future, which means clinicians would have to report a numerator and denominator. CMS states that because PDMPs are now widely available across all fifty states and PDMP integration with EHRs has increased since this measure was finalized, changing the measure to be performance rate-based would better support appropriate prescribing for controlled substances.

Specifically, CMS wants to gather feedback on the following topics:

How to define the numerator and denominator
Potential barriers for clinicians
How to account for varying levels of readiness and capacity, especially for small and rural practices
Potential exclusions
Timeframe for implementation
Other measure concepts related to overdose prevention
Whether to explore measures related to monitoring data from PDMPs (e.g., multiple opioid prescriptions, prescriptions from multiple providers)

Expanding the Types of Drugs in the Query of PDMP Measure

CMS is also seeking feedback on expanding the Query of PDMP measure to include all Schedule II drugs, instead of just Schedule II opioids. CMS feels this would improve quality of care by supporting appropriate prescribing of controlled substances.

Specifically, CMS would like to hear about the following:

Challenges around expanding the measure to include all Schedule II drugs
Potential benefits vs. risks
Whether expanding the measure would create barriers for patients who are appropriately prescribed Schedule II non-opioids (e.g., ADHD medications)
How to account for varying levels of readiness and capacity, especially for small and rural practices
Potential exclusions

RFI on Alternatives to Attestation-Based Measures in Public Health and Clinical Data Exchange

Public Health and Clinical Data Exchange is one of the objectives under the MIPS PI category. This objective currently consists of two required measures (Immunization Registry Reporting and Electronic Case Reporting) and three optional bonus measures (Public Health Registry Reporting, Clinical Data Registry Reporting, and Syndromic Surveillance Reporting).* These measures all require the clinician to attest “Yes” to being in active engagement with a Public Health Agency (PHA) to submit data. CMS is requesting feedback on making these measures performance rate-based and on potential additional measures in the future.

*There is an additional bonus measure proposed for 2026: Public Health Reporting Using TEFCA.

Additional Information on this RFI

CMS feels that attestation-based reporting for these measures does not capture aspects such as data quality and timeliness of health information shared with PHAs. As a result, CMS is considering other ways to collect data and score the Public Health and Clinical Data Exchange objective.

Specifically, CMS is requesting feedback on the following topics:

Aspects of data quality and usability that would be appropriate and valuable to measure
How to define data completeness
Other metrics to consider (e.g., overdose prevention)
How to focus on data quality in a way that would result in high value and low burden
Potentially revising scoring to make measures performance rate-based
How to better leverage certified health IT to support public health reporting
- How this would impact measurement of clinicians’ performance
- Whether this could reduce the number of measures in the PI category

RFI on Data Quality

CMS also included a more general RFI on data quality. CMS would like feedback on how to support clinicians’ use of modern technology and standards to ensure that data is usable, complete, accurate, timely, and consistent.

Additional Information on this RFI

Specifically, CMS would like to hear about the following:

Data quality challenges that your practice experiences and how you are working to address them
Barriers to collecting high-quality data and resources that could help
Solutions that you have found to address data quality issues
Steps that CMS should take to drive further improvement in data quality and usability
Potential partnerships with clinicians, industry, and federal agencies

MIPS Value Pathways (MVP) RFIs

CMS included three RFIs related to MVPs in the 2026 proposed rule. For an overview of MVPs and how they differ from traditional MIPS, you can refer to any of our previous MVP blogs, which are all linked here.

RFI on Core Elements

To further standardize MVP reporting, CMS is considering proposing a policy in the 2027 proposed rule that would require MVP participants to select one quality measure from a subset of quality measures in the MVP they are reporting, referred to as “Core Elements.” Clinicians would still choose the other three MVP quality measures to meet the reporting requirement of four total quality measures. Each MVP would have its own set of Core Elements.

Additional Information on this RFI

CMS feels that this policy would lead to more directly comparable clinician data for patients.

Specifically, CMS would like to hear feedback on the following:

Other ways to ensure MVP reporting provides comparative performance data for patients
Whether to make some Core Elements the same across all MVPs
The ideal number or percentage of Core Elements for each MVP
How to address limited clinician choice when it comes to measures that can only be reported via certain collection types
How to avoid disadvantaging clinicians if there is no applicable Core Element available for them to report
Feedback on specific measures that should or should not be used as Core Elements
Whether to consider proposing the Core Elements policy in 2027
Whether this policy would impact your decision to report an MVP while traditional MIPS is still an option

RFI on Medicare Procedural Codes

CMS is also considering a policy that would use Medicare procedural billing codes to identify the MVP relevant to a clinician’s specialty and require them to report that MVP. They are also considering requiring clinicians to report specific measures within the MVP, based on their billed procedural codes.

Additional Information on this RFI

CMS feels this policy would ensure that clinicians report an MVP relevant to their specialty and scope of care, and that the resulting data would lead to more meaningful comparisons for patients.

Specifically, CMS is requesting feedback on the following:

Other ways to encourage clinicians to report MVPs relevant to their specialty
Which data sources to use to assign clinicians to an MVP
Whether it would be appropriate to use billing codes from Medicare Part B claims data from two years prior to the performance year (to align with the determination period used for MIPS eligibility)
Whether to set a volume threshold to be assigned to a particular MVP (e.g., 20 cases)
How much time clinicians would need to prepare for reporting an MVP that is required based on Medicare Part B claims data

RFI on Well-Being and Nutrition Measures

CMS is seeking input on well-being and nutrition measures for future MIPS years. Specifically, they are looking for feedback on tools and measures related to overall health, happiness, and satisfaction in life. This could include aspects of emotional well-being, social connections, purpose, and fulfillment.

How to Share Feedback with CMS

We encourage you to share your feedback directly with CMS on these RFIs and the 2026 proposals by commenting on the 2026 Quality Payment Program (QPP) proposed rule.

Click on “Submit a Public Comment” and fill out the form. You can attach a file with your comments or type them in the comment box. Be sure to submit your comments before the deadline on September 12, 2025, at 11:59 pm ET.

Keep an eye out for our next blog, where we’ll provide more details on how to comment on the 2026 proposed rule.

Next Steps

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Written By: Sarrah Hakim, MHSA