By the EHR Association’s Value-Based Care and Quality Programs Workgroup
In CMS’s 2026 Medicare Physician Fee Schedule Final Rule, one theme stands out clearly: the joint goals of stability and steady transformation.
While the agency is not upending the Quality Payment Program (QPP) or the Hospital Inpatient Quality Reporting (IQR) Program, it is continuing to refine them with updates that reflect CMS’s ongoing effort to simplify, modernize, and prepare healthcare for a future in which MIPS Value Pathways (MVPs) and advanced interoperability expectations are the norm. Doing so means fewer shifts and, as a result, easier adaptation for EHR systems and clinical workflows, reducing the effort required for annual measure changes. The EHR Association applauds CMS’s effort to simplify the program and reduce burden.
Continuity Coupled with Evolution for Eligible Clinicians (MIPS and Advanced APMs)
While CMS is keeping the MIPS performance threshold at 75 points through 2028—offering a measure of predictability in a program that has seen frequent recalibration—the structure of MIPS continues to shift.
MVPs, CMS’s long-term vision for a more clinically coherent and less burdensome MIPS, expanded in 2026, with the addition of six covering diagnostic and interventional radiology, neuropsychology, pathology, podiatry, and vascular surgery.
MVPs, CMS’s long-term vision for a more clinically coherent and less burdensome MIPS, expanded in 2026, with the addition of six covering diagnostic and interventional radiology, neuropsychology, pathology, podiatry, and vascular surgery. All existing MVPs were updated as well, bringing the total number available for reporting to 27.
CMS also refined how clinicians engage with MVPs. Groups will now need to attest to their specialty composition during registration, and small multispecialty practices retain the flexibility to report as a group without forming subgroups. Third-party intermediaries, such as QCDRs and Qualified Registries, will have a one-year runway before they must support newly finalized MVPs that are applicable to their MVP participants—meaning the 2026 additions must be supported by 2027.
In the areas of quality and cost, CMS has made subtle, but meaningful, shifts:
- Expanded the quality measure inventory by five, removed 10, and made substantive updates to 30.
- Removed health equity from the definition of a “high priority measure.”
- Beginning with the 2025 performance period (affecting the 2027 payment), benchmarks will align with the cost measure methodology, with median performance anchored at 7.5 points.
- Expands the APM Performance Pathway (APP) Plus measures set to include colorectal cancer screening and a risk-standardized hospital admission measure for patients with multiple chronic conditions.
- Adjusted the Total Per Capita Cost (TPCC) measure to avoid attributing costs to highly specialized groups based solely on advanced practice clinician billing.
Ultimately, the short-term impact on EHRs from these updates remains to be seen. However, we are hopeful that while this will serve as a transition year, we will see fewer changes and additions to measures in the future.
Ultimately, the short-term impact on EHRs from these updates remains to be seen. However, we are hopeful that while this will serve as a transition year, we will see fewer changes and additions to measures in the future.
Additionally, to improve Advanced APM participation, CMS is updating the Improvement Activities inventory with three additions, seven modifications, and eight removals, as well as:
- Replacing the “Achieving Health Equity” subcategory with “Advancing Health and Wellness,” signaling a broader framing of population-level improvement.
- Simplifying the process of determining Qualifying APM Participant (QP) status for clinicians in Advanced APMs by making QP determinations at both the APM Entity level and the individual clinician level.
- Standardizing the calculation methodology and assigning QP status based on whichever calculation is most favorable to the clinician.
Promoting Interoperability
Interoperability expectations continue to rise across both MIPS and Medicare’s Promoting Interoperability (PI) Program for hospitals and CAHs. Starting in 2026, all participants must report a continuous 180-day EHR reporting period. CMS is also:
- Strengthening the Security Risk Analysis requirement to include attestations to both conducting a risk analysis and performing ongoing risk management activities, aligning more explicitly with HIPAA’s Security Rule.
- Updating the SAFER Guides requirement to include annual self-assessments by hospitals and CAHs using all eight 2025 SAFER Guides, and High-Risk Priority Practices Guides for MIPS clinicians—reducing ambiguity and allowing EHRs to better support this one version.
- Continuing an optional TEFCA-based public health reporting measure.
- Establishing a new measure-suppression policy for MIPS PI and the Medicare PR Program.
Additionally, due to the CDC’s temporary pause on onboarding new organizations for electronic case reporting, CMS will suppress scoring for that measure for the 2025 performance period. However, clinicians and hospitals must still attest and will receive full credit.
Updates to the Hospital Inpatient Quality Reporting (IQR) Program
For hospitals, the most significant changes begin with the CY 2024 reporting period, which determines FY 2026 payment updates. CMS is removing four measures, including Hospital Commitment to Health Equity and two measures related to social drivers of health. This reflects CMS’s broader recalibration of health equity–specific reporting requirements across programs.
Several measures are being refined rather than removed. For example, the complication rate measure for elective hip and knee arthroplasty will now include Medicare Advantage patients and use ICD-10 codes for risk adjustment. The performance period is also shortened from three years to two.
Hybrid measures for readmissions and mortality are being updated to lower submission thresholds and reduce the required proportion of Core Clinical Data Elements to 70% of discharges—changes intended to ease reporting while maintaining measure integrity.
Looking Ahead: FHIR-based CQMs
CMS recently released for public comment its draft Fast Healthcare Interoperability Resources® (FHIR®) Digital Quality Measures (dQMs) for consideration in future use in CMS Quality Reporting Programs. While our analysis of the draft continues, it is important for clinicians and hospitals to keep FHIR-based dQMs on their radar.
While our analysis of the draft continues, it is important for clinicians and hospitals to keep FHIR-based dQMs on their radar.
In general, the Association believes there are advantages to digital quality measures. Because they use more structured data, they can deliver greater value and relevance. They also open multiple paths to easier sourcing of clinical data from different sources, while the uniformity of FHIR standards enables measurement of results and insights.
Further, just as most health IT vendors are already working to support dQMs, there are actions clinicians and hospitals can take now, including getting a head start on developing an organization’s FHIR data strategy. It can take longer than anticipated, and even traditional quality use cases and operations can benefit from having standardized clinical data in FHIR.
A good starting point is to review HL7 FHIR resources related to digital quality measures, such as those available on the eCQI Resource Center. There are also several early actions that offer value beyond compliance with future mandates around digital quality measures, such as clinical data mapping.
Finally, participate in the public comment period, which closes February 25, 2026. It is the only way to ensure CMS hears all stakeholder voices.
Additional Resources
To learn more about the CY 2026 Medicare PFS Final Rule and QPP policy changes, we suggest the following resources:
EHRA Blog 