CMS Moves to Retire Traditional MIPS After 2028
The Centers for Medicare & Medicaid Services is moving to end traditional MIPS after the 2028 performance year and replace it with MIPS Value Pathways, or MVPs, beginning in 2029 for clinicians outside Advanced Alternative Payment Models. The proposal lands after a decade of physician frustration with a program that was meant to link payment to quality, but instead often rewarded paperwork discipline, practice infrastructure, and the ability to survive compliance burden.
CMS is not abandoning the logic of MIPS. It is repackaging it.
Buried in the CY 2027 Medicare Physician Fee Schedule proposed rule is a clear signal that the agency has decided the old architecture has run its course. Traditional MIPS would sunset after 2028, and MVPs would become the only reporting option for most clinicians not already sheltered in an APM. The shift is operationally significant, but the more important fact is conceptual: CMS is keeping the same measurement philosophy and changing the wrapper around it.
For many physicians, the core complaint has never been difficult to understand. A program built on self-selected measures, complex reporting rules and budget-neutral redistribution cannot easily distinguish a clinic delivering excellent care from a clinic with a stronger administrative back office. In primary care, the most substantial published analysis, involving roughly 80,000 physicians in JAMA, found that MIPS scores were inconsistently associated with real-world process and outcome performance. Physicians caring for more medically complex and socially vulnerable patients tended to score lower. Parallel work involving hospital-based clinicians found no relationship between MIPS scores and postoperative complications.
The numbers behind the program’s burden are equally hard to defend. Published estimates place participation at about $13,000 per physician per year and around 200 hours of physician, clinical, and administrative staff time. That is a large amount of labor for a system that has not consistently demonstrated a meaningful link between score and quality. In practical terms, the program has functioned less like a clinical improvement tool and more like a compliance levy attached to a scoring formula.
The financial asymmetry is especially stark. A perfect score of 100 has carried a positive adjustment of roughly 1% in recent payment years, while a failing score still exposes clinicians to the full statutory 9% penalty. A solo physician can spend months chasing a 1% upside while sitting under a potential 9% loss. The math explains why the program has produced so much skepticism in independent practices, especially small and rural ones.
Solo and small practices have borne a disproportionate share of the pain. CMS experience reports have shown that roughly half of solo clinicians and close to a third of clinicians in small practices were penalized, versus well under 15% of eligible clinicians overall. Rural clinicians fared worse as well. Those figures do not describe a system finely tuned to reward quality. They describe a system that more reliably detects who has staff and software to navigate the maze.
MVPs Narrow the Menu, But Not the Underlying Logic
CMS proposes three new MVPs for 2027 — diabetes, hypertension, and hospitalist care — bringing the total to about 30. The diabetes and hypertension pathways track closely with Medicare Advantage Star Ratings measures, including blood pressure control and hemoglobin A1C control. That alignment may be the strongest practical feature of the redesign, because it allows a practice to build one quality workflow rather than several parallel reporting systems. In an overloaded office, reducing duplicated measurement can matter as much as any numerical incentive.
The proposed rule also adds a core measure requirement. At least one reported quality measure would need to come from a designated core set, or the clinician loses points on one required measure. Small practices would be exempt, and clinicians could attest that no core measure applies and substitute another. The practical effect is to push reporting toward a narrower and more standardized set of metrics. Whether that creates better measurement or simply a more orderly spreadsheet depends on how faithfully the benchmarks separate real performance from ceiling effects.
CMS is also making substantial changes to Improvement Activities. Several existing activities would be removed, including glycemic screening and referral services, care-transition documentation and operational improvements, care coordination agreements for tracking patients across settings, bilateral electronic exchange between primary care and behavioral health for shared patients, engagement of patients and caregivers in care planning, and depression prevention and treatment interventions. In their place, CMS proposes activities such as using data to improve workflow, improving diagnostic performance, systematic screening for nutrition and other nonclinical needs, advance care planning conversations, lifestyle approaches to diabetes remediation, and clinician use of artificial intelligence to improve patient care.
One sentence captures the tension: CMS is measuring blood pressure and glucose control while devaluing much of the coordination work that makes those outcomes possible.
That shift matters at the bedside because chronic disease control does not emerge from a single encounter. It depends on medication reconciliation, referral tracking, communication across settings, patient follow-through, and the kind of administrative continuity that keeps a care plan from falling apart between visits. Removing credit for those tasks while tightening output measures risks pushing clinicians toward what is easiest to count rather than what is hardest to do well.
The proposed removal of the security risk analysis requirement from Promoting Interoperability follows the same pattern. The requirement would disappear from the attestation process, but it remains mandatory under HIPAA. The regulatory obligation does not vanish; only the MIPS acknowledgment does. Any compliance vendor suggesting otherwise is selling a false simplification.
The Prior Authorization Measure Exposes the Real Friction
CMS also is proposing to move away from the current prior authorization quality measure and replace it with a registry-based version that would evaluate use of a prior authorization query function. A prior authorization alternative measure would also be available under MVPs in some settings. The update reflects an attempt to capture real workflow burden more precisely, since prior authorization remains one of the most visible friction points in everyday outpatient practice.
Still, the broader question remains unresolved by design. CMS has proposed a replacement for MIPS, but not a repair of the core problem that made MIPS unpopular in the first place. The scoring philosophy still depends on small differentials, selective measure reporting, and payment adjustments that are too small to reward excellence and too punitive to ignore failure. For independent physicians, especially those in smaller practices, the redesign may reduce some administrative clutter without changing the basic burden of being judged by a system that often confuses documentation capacity with clinical quality.
The sunset of MIPS closes one chapter, but it does not resolve the central tension between measurement and medicine. The next phase will reveal whether MVPs reduce the administrative drag on clinicians or simply make it easier to package the same incentives in a cleaner format.