MIPS archive

Eligibility criteria

The low volume threshold remains the same as in 2026 and includes 3 aspects of covered professional services:

1. Allowed charges

2. Number of Medicare patients who receive services

3. Number of services provided

You must participate in MIPS (unless otherwise exempt) if, in both 12-month segments of the MIPS Determination Period, you:

• 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 opt-in policy also remains the same. It allows physicians or groups who meet one or two of the low-volume threshold criteria to opt-in to participate in MIPS and receive a final score and payment adjustment.

Payment adjustment

The 2026 performance period payment adjustment remains at 9% applied to reimbursements in 2028.

Minimum threshold

Minimum points needed to avoid penalty: 75 points (no change).

Maximum threshold

The additional MIPS payment adjustment for exceptional performance ended after the 2023 performance period, with 2022 being the last year clinicians could earn the bonus.

MIPS category breakdowns

Quality: 30% of MIPS score

• No change in category weight

• Total of 190 quality measures available for the 2026 performance period

• Data completeness remains at 75% through the 2028 performance period.

  • Small practices (15 providers or fewer) receive 3 points for not meeting data completeness

  • Large practices (16 providers or more) receive 0 points for not meeting data completeness

• Performance period: Jan. 1 – Dec. 31, 2026.

• Submission methods: claims (for small practices), registry, QCDRs such as the Academy’s DataDerm^™ with EHR integration, and your practice’s EHR.

Improvement Activities: 15% of MIPS score

• No change in category weight.

• 99 improvement activities for 2026.

• Traditional MIPS reporting for IA:

  • Clinicians, groups, and virtual groups that are part of a small practice, rural, non-patient facing, or health professional shortage area special status must attest to one activity.

  • All other clinicians, groups, and virtual groups must attest to two activities.

• Performance period: 90-day continuous performance period between Jan. 1 – Dec. 31, 2026.

• Added three new activities, modified seven existing, and removed eight existing improvement activities.

• Group participation threshold remains the same (50% participation of clinicians in group).

• Submission methods: CMS or QCDR.

Promoting Interoperability: 25% of MIPS score

• No change in category weight.

• Performance period: continuous 180-days between Jan. 1 – Dec. 31, 2026.

• Submission methods: registry, QCDR, EHR.

• Data submission must include CMS EHR Certification ID (CEHRT ID) from the Certified Health IT Production List (CHPL) (no change from 2024).

• Security Risk Analysis (SRA) measure modification (NEW): CMS is requiring a second attestation statement to this measure.

• Optional bonus measure (NEW): CMS is adding a new option “Public Health Reporting Using Trusted Exchange Framework and Common Agreement (TEFCA)”.

Cost: 30% of MIPS score

• No change in category weight.

• No action required by the eligible clinician.

• A maximum cost improvement score of 1 percentage point as established in 2023.

Performance category reweighing due to third-party intermediary submission failures

CMS now 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.

Reporting type

Individual: Under an NPI number and TIN where they reassign benefits; report via claims, registry, or EHR.

Group: Two or more clinicians (by NPIs) who have reassigned their billing rights to a single TIN; report via claims, registry, or EHR.

• Small practices, excluding those participating in MIPS as part of a virtual group, must submit data as a group in any performance category to indicate that they wish to be scored as a group for Medicare Part B claims.

Small practice and special status accommodations

CMS defines a small practice as having 15 or fewer MIPS-eligible clinicians billing under a single TIN. Accommodations for small practices include:

• 3 points for measures that do not meet data completeness of 75%

• Claims-based reporting available

• 6 bonus points added to numerator of quality category

• Automatic redistribution of the PI performance category weight for any small practice that does not submit data for the performance category

MIPS Value Pathways (MVPs)

CMS continues to move toward replacing traditional MIPS with MIPS Value Pathways (MVPs), which is intended to be a more streamlined, specialty-relevant, and patient-focused reporting model. While CMS considers MVPs central to the long-term Quality Payment Program (QPP) strategy, participation remains optional in 2026.

The MVP for dermatology is called “Dermatological Care.”

• MVP participation is optional in the 2026 performance year.

  CMS reaffirmed that MVPs would become mandatory in the future, but no implementation date has been set.

• 27 MVPs are available for voluntary reporting in 2026, including one for dermatology.

• Clinicians report from a limited set of MIPS quality measures, including one outcome or high-priority measure, are scored on a cost measure only if the case minimum is met, and report IA from a limited list, while PI is reported as in traditional MIPS.

• Clinicians also may participate in MVPs via single-specialty subgroups, multispecialty groups, individual MIPS-eligible clinicians, subgroups, and APM entities.

  • Large multispecialty groups (16 clinicians or more) must divide into subgroups or report as individuals to participate in an MVP.

• Clinicians can participate in both traditional MIPS and the dermatology 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 Clinical Data Registry.

• Learn more by visiting the QPP page on MVPs.

QPP hardship exceptions

Extreme and uncontrollable circumstances

• Aligning EUCs with extraordinary circumstance exceptions (ECE) for automatic application when appropriate.

• Application-based EUCs also available as needed.

Promoting interoperability performance category hardship exception

• Automatic redistribution of the Promoting Interoperability performance category weight for any small practice that does not submit data for the performance category.

• Applications also available as needed.

Telehealth

Direct supervision

Starting January 2026, CMS is permanently revising the definition of “direct supervision” to allow supervising physicians or other qualified practitioners to be virtually present via real-time, interactive audio-video technology (excluding audio-only).

Teaching physician

Beginning in 2026, CMS will permanently allow teaching physicians to join telehealth visits virtually with residents and patients when the service is furnished virtually. In-person supervision remains required for face-to-face visits in metropolitan areas.

Home address

CMS’s current policy allowing providers to bill from their enrolled practice location while delivering telehealth from home expires Dec. 31, 2025. The final rule does not extend this flexibility but provides instructions for suppressing the physician’s home address in PECOS. Suppressing their home address will allow physicians to protect their privacy after the flexibility ends.

Geographic and originating site

Medicare beneficiaries can receive telehealth services from any location in the U.S., including their home.

Retroactive payment will be applied for services provided on or after Oct. 1, 2025.

Additional MIPS resources

• CMS 2026 final rule fact sheet

• Full text of the 2026 Final Rule

• AAD quality measure selection tool

• Read our analysis of the 2026 Medicare Physician Fee Schedule