As our readers will know, CMS created the Quality Payment Program (QPP) several years ago as a follow-on iteration from what was then called PQRS. The QPP represents the federal government’s attempt to attach some level of reimbursement value to the caliber of the clinician’s work—as defined by certain “quality measures.” This pay-for-performance model has been part of the Medicare payment matrix for some years now, and 2026 will see a continuation of this effort.
Merit-Based Incentive Payment System
Most anesthesia and chronic pain providers who participate in the QPP do so via the Merit-based Incentive Payment System (MIPS). Based on an analysis of the proposed rule by the American Society of Anesthesiologists (ASA), as well as a fact sheet on the QPP published by CMS, the following represents what anesthesia providers can expect for the 2026 version of MIPS.
For the 2026 reporting year:
- CMS is proposing to maintain the performance threshold at 75 points through calendar year (CY) 2028. 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%, and the cost performance category will be weighted by 30%. Promoting interoperability and Improvement Activities performance categories will maintain their respective 25% and 15% weights.
- It should be noted here that most providers are not required to perform the Promoting Interoperability category, with its 25% being pushed to the Quality category.
- In addition, the Cost category has no obligation attached to it. It is calculated automatically.
- CMS proposes to remove QID424: Perioperative Temperature Management.
- CMS will maintain the data completeness threshold for the MIPS Quality Performance Category at 75% for the 2026 through 2028 performance years.
- CMS proposes adding three anesthesiology quality measures to those eligible for alternative benchmarking: QID430 (PONV), QID463 (POV), QID477 (multimodal pain management).
MIPS Value Pathway
Anesthesiologists will continue to have the opportunity to report via the Anesthesiology MIPS Value Pathway (MVP) in 2026. CMS believes the MVP will alleviate some of the reporting burdens that anesthesiologists and other physicians encounter in the MIPS program.
For 2026, CMS has proposed the removal of two quality measures from the MVP:
- QID424: Perioperative Temperature Management
- QID487: Screening for Social Drivers of Health
CMS is also proposing the removal of two Improvement Activities from the MVP:
- 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.
Alternative Payment Models
The proposed rule creates the Ambulatory Specialty Model (ASM), a mandatory alternative payment model (APM) that was developed based on the MVP framework. The model, proposed for 2027 through 2031, would target 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.
Again, this is only a proposal and would not start until 2027. If finalized, we will present more details concerning this particular APM at that time.
For more information on the QPP, you can contact the ASA’s Department of Quality and Regulatory Affairs (QRA) at qra@asahq.org, or you can peruse the CMS fact sheet on the 2026 QPP at the following link: CMS Fact Sheet on the Quality Payment Program .