Navigating MIPS 2026: A survival guide for dermatology practices
Answers in Practice
By Olivia Barry, Manager, Practice Management, April 1, 2026
Each month, DermWorld tackles issues “in practice” for dermatologists. This month, practice management staff discuss navigating MIPS in 2026.
CMS has released the rules for the MIPS program for 2026 and continues to encourage use of MIPS Value Pathways (MVPs) designed for specific specialties, including dermatology. MVPs remain optional in 2026, but practices can gain an edge by reporting both traditional MIPS and the Dermatological Care MVP, since CMS will use the higher of the two scores.
However, navigating MIPS requirements remains complex, and success increasingly depends on having the right infrastructure in place. Certified electronic health record technology (CEHRT) plays a critical role in meeting Promoting Interoperability (PI) requirements, simplifying quality reporting, improving workflow, and strengthening overall MIPS performance.
To help practices prepare for 2026 and maximize their performance, leverage the AAD’s DataDerm™ registry. DataDerm integrates with many EHR systems to support reporting of traditional MIPS and the Dermatological Care MVP while helping you track and improve your results.
With the 2025 performance year behind us, now is the time to understand the 2026 requirements, key changes, and opportunities within the Dermatological Care MVP.
Payment adjustment
The penalty for not participating in 2026 will remain 9% as required by law. See the full program timeline below.
Eligibility criteria
You are required to participate if all of the following are true in both 12-month segments of the MIPS determination period (unchanged):
Bill more than $90,000 for Part B covered professional services, and
See more than 200 Part B patients, and
Provide 200 or more covered professional services to Part B patients
The voluntary opt-in option remains, allowing some clinicians, who otherwise would have been excluded under the low-volume threshold, the option to participate in MIPS. Eligible clinicians or groups will be able to opt-in if they meet or exceed at least one or two, but not all three, of the low-volume threshold criteria noted above.
Check if you are required to participate on the Quality Payment Program website.
AAD MIPS information
Performance thresholds
The threshold to avoid the penalty has remained the same. The minimum score to avoid the penalty is 75 points.
The additional MIPS payment adjustment for exceptional performance ended after the 2023 performance period.
Reporting types
Eligible clinicians will be able to continue to report individually, as groups, or virtual groups. Note: For the 2026 performance period, the virtual group election deadline was Dec. 31, 2025.
Performance categories
All category weights have remained the same but see additional details below for each.
Quality 30%
Data completeness threshold is 75%
(NEW) Removal of MIPS 487: Screening for Social Drivers of Health
(NEW) Removal of MIPS 498: Connection to Community Service Provider
Improvement Activities 15%
Performance period: 90-day continuous performance period between Jan. 1–Dec. 31, 2026. The last day to start a 90-day performance period is Oct. 3, 2026.
Group participation threshold remains at 50% of eligible clinicians and not all clinicians need to complete the activity at the same time.
Promoting Interoperability 25%
Performance period: 180-day continuous performance period between Jan. 1–Dec. 31, 2026, up from 90-days in previous years. The last day to start a 180-day performance period is July 5, 2026.
Data submission must include CMS EHR Certification ID (CEHRT ID) from the Certified Health IT Product List (CHPL).
(NEW) Security Risk Analysis (SRA) measure modification: CMS is requiring a second attestation statement for this measure.
(NEW) Optional measure: CMS is adding a new option “Public Health Reporting Using Trusted Exchange Framework and Common Agreement (TEFCA).”
Eligible clinicians are highly encouraged to adopt an EHR. If you have not already, find an EHR that fits your needs to optimize your practice workflow.
If you haven’t already done so, be sure to enroll in the AAD’s CMS-certified registry, DataDerm.
Cost 30%
No action is needed by the individual clinician/group as CMS automatically calculates this score.
AAD Career Launch
Check out the Academy’s new guide to success for early-career dermatologists.
Performance category reweighing due to third-party intermediary submission failures
CMS allows clinicians to request reweighting for Quality, IA, or PI if a third-party intermediary to whom the clinician delegated data submission fails to submit data on time.
Small practice accommodations
All small practice (15 or fewer clinicians) accommodations remain the same in 2026:
Claims-based reporting allowed for the Quality category although there are fewer quality measures that are reportable via claims.
3 points awarded per quality measure that do not meet the 75% data completeness requirement.
6 bonus points added to the numerator of the Quality category
Automatic redistribution (no application required) of the Promoting Interoperability performance category weight for any small practice that does not submit data for the performance category.
Note: CMS considers small practices as a special status. For more information on reporting accommodations for small practices and other special statuses, visit the Quality Payment Program (QPP) website.
When Promoting Interoperability is redistributed, Quality will be 40%, Cost 30%, and Improvement Activities 30%.
When Promoting Interoperability and Cost are both reweighted, Quality will be 50% and Improvement Activities 50%.
AAD EHR efficiency tools
Learn how to make EHRs work more effectively for your practice.
QPP hardship exceptions
Extreme and uncontrollable circumstances (EUCs)
MIPS-eligible clinicians, groups, and virtual groups may submit an application to reweight any or all MIPS performance categories if they have been affected by extreme and uncontrollable circumstances that impact these performance categories. To apply, visit the QPP website.
Promoting Interoperability (PI) performance category hardship exception
CMS will automatically redistribute the PI performance category weight for any small practice that does not submit data for the performance category. Clinicians can also complete an application as needed. To apply, visit the website.
MIPS Value Pathways (MVPs)
The new MVP for dermatology is called “Dermatological Care.” MVP participation is optional in the 2026 performance year.
Eligible clinicians report on a reduced number of quality measures (reporting on 4 measures versus 6) and improvement activities (attest to 1 activity regardless of special status). Like traditional MIPS, MVP participants must meet all the requirements of the Promoting Interoperability category (unless exempt) and are automatically scored on claims-derived cost and population health measures if case minimums are met.
Another unique feature of MVPs is the ability to report via subgroups, which are subsets of clinicians from the same TIN and may be useful for clinicians in multispecialty groups. Note that subgroup reporting will become mandatory for multispecialty practices that opt to participate via MVPs starting in 2026. Subgroup reporting is not permitted in traditional MIPS. Learn more.
Clinicians can participate in both traditional MIPS and the Dermatological Care MVP, with their score determined by whichever pathway results in a higher performance score. Both traditional MIPS and MVPs can be reported via AAD’s DataDerm.
Note that unlike traditional MIPS, MVP participation requires registration. The registration window for the 2026 performance year is April 1-Nov. 30, 2026.
Review the MVP requirements and details for the Dermatological Care MVP.
In 2026, dermatologists have an opportunity to further refine their MIPS strategy as CMS continues its shift toward MVPs. Dermatology practices can review the 2026 final rule highlights and decide whether traditional MIPS, an MVP, or both best-aligns with their workflows and performance goals. By leveraging the Academy’s step-by-step guide, interactive tools, and EHR resources, your practice can confidently meet reporting requirements, avoid penalties, and position itself for long-term success for MIPS performance.
Find more practice management resources in the AAD Practice Management Center.
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