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CMSMedicare Quality Programs
November 24, 2025
2026 Medicare PFS Final Rule: Quality Payment Program

2026 Medicare PFS Final Rule: Quality Payment Program

As part of the 2026 Medicare physician fee schedule (PFS) final rule, released on the last day of October, the Centers for Medicare & Medicaid Services (CMS) devoted much space to its Quality Payment Program (QPP) and all that individual and group providers must do to avoid certain penalties. To help summarize the changes that may impact our readers, we look to a fact sheet published by CMS, as well as a summation provided by the American Society of Anesthesiologists (ASA). Much of the below is taken from those documents.

2026 Medicare PFS Final Rule: Quality Payment Program

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Program Background

For those who are not familiar with the QPP, it entails federal initiatives to increase quality of care and outcomes by way of rewarding providers who meet certain quality metrics and penalizing those who fail to comply with program requirements. The rewards and penalties are financial in nature and are reflected in a percentage of reimbursement on Medicare claims.

The QPP is an umbrella structure encompassing two major sub-programs: (a) the Merit-based Incentive Payment System (MIPS), and (b) Alternative Payment Models (APMs). Generally, eligible clinicians and medical groups will choose to participate in the QPP, with most choosing to participate via MIPS. Keep in mind that to participate in an APM, you generally need to have at least 25% of your charges going through an existing Accountable Care Organization (ACO), which is why most participants opt for the MIPS route. In addition, some choose to participate as a group, while others choose to participate at the individual provider level. Remember also that the program’s compliance results are published publicly, which is why Coronis Health generally suggests participating as a group.

Finally, there is a distinction made by CMS between the reporting year and the year the rewards are actually paid out and penalties are assessed, which is essentially two years later. So, with 2026 MIPS reporting, providers would realize either their rewards or penalties in 2028. With that said, let’s take a look at what CMS has in store for the 2026 version of the QPP, with emphasis on MIPS.

MIPS Particulars

For the 2026 reporting year, here are the essentials to know:

  • The MIPS performance threshold remains at 75 points for 2026. Scoring below 75 points would result in a payment penalty in 2028.
  • By law, the weights of the different MIPS requirements will not change:
    • The quality performance category will be weighted at 30%
    • The cost performance category will be weighted by 30%
    • Promoting interoperability will be weighted at 25%
    • Improvement activities will be weighted at 15%
  • CMS removed quality measure QID424: Perioperative Temperature Management from the MIPS program, citing its topped-out status as the reason. According to the ASA, this CMS decision “will likely increase burdens on anesthesia groups as they seek to report other quality measures.”  We at Coronis Health believe this will, indeed, create some challenges with overall reporting, so we encourage you to stay tuned for more information in the days ahead as conversations restart in the wake of the government reopening.
  • CMS will maintain the data completeness threshold for the MIPS quality performance category at 75% for the 2026 through 2028 performance years.
  • CMS finalized adding three anesthesiology quality measures to alternative benchmarking (QID430, QID463, QID477). This is good news for us as the benchmarks are used for calculating the overall point contribution, and these measures have very tight differences between providers.

Anesthesiologists will continue to have the opportunity to report the Anesthesiology MIPS Value Pathway (MVP) in 2026. This is an alternative to “straight MIPS,” and CMS believes MVP will alleviate some of the reporting burdens that anesthesiologists and other physicians encounter in the MIPS program. Coronis Health, however, has not yet found this to be true, unless you are perfect in the measures reported.

For 2026, CMS has removed two quality measures from the MVP:

  • QID424: Perioperative Temperature Management
  • QID487: Screening for Social Drivers of Health

CMS removed two improvement activities from the MVP (which will have no impact on anesthesia):

  • IA_CC_2: Implementation of improvements that contribute to more timely communication of test results
  • IA_PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza and Hepatitis B. 

The 2026 final rule also mandates the Ambulatory Specialty Model (ASM), which was developed based on the MVP framework. The model, which would run from 2027 to 2031, targets specialists who frequently treat low back pain or heart failure in selected geographic areas. Eligible physicians, including anesthesiologists and pain management providers, will be assessed individually and subject to performance-based payment adjustments ranging from -9% to +9% in the first year. The ASA and other medical specialties opposed this model, citing the lack of applicable quality measures for anesthesiologists among other reasons.

For more information on the Quality Payment Program, you can visit https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2026-medicare-physician-fee-schedule-final-rule-cms-1832-f and scroll down to the bottom to see "For a fact sheet on the CY 2026 Quality Payment Program changes, visit:" and then click that link to download the pdf.