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CMS published the 2027 QPP Proposed Rule on the 14th of July 2026, inside the 2027 Medicare Physician Fee Schedule (file code CMS-1848-P), and a final rule is expected before the end of the year. Practices that wait for the final version to start planning will be working against the clock. Several of these changes affect MIPS reporting as early as the current 2026 performance year.
Already in Motion: 2026 Performance Year
Two clauses apply retroactively to current data collection activities. The currently mandatory ONC Direct Review attestation and the optional ONC-ACB Surveillance attestation are two ONC-related attestations that CMS wishes to remove from the Promoting Interoperability category. For 2026 performance data filed during the 2027 filing period, both would be removed.
The thresholds for Qualifying APM Participant (QP) and Partial QP status would also temporarily decrease for 2026 due to the Consolidated Appropriations Act, 2026: QP thresholds would drop from 75% to 50% (payment amount method) and 50% to 35% (patient count method), while Partial QP thresholds would ease similarly. Clinicians who were on the verge of qualifying but fell short of the previous requirements might want to review their figures.
Headline Change In 2027 QPP Proposed Rule: A Sunset Date for Traditional MIPS
For years CMS signaled that MIPS Value Pathways (MVPs) would eventually take over. This rule sets the date: traditional MIPS would end after the 2028 performance period. From 2029 on, clinicians outside a MIPS APM would report exclusively through an MVP. Those in a MIPS APM keep the APM Performance Pathway (APP) or APP Plus.
Compare that to CMS’s 2026 QPP rule, which added six new MVPs (diagnostic radiology, interventional radiology, neuropsychology, pathology, podiatry, and vascular surgery) and only floated the idea of standardizing MVP reporting through requests for feedback. This year’s rule moves past feedback-gathering into an actual deadline, a sign CMS considers the transition largely settled rather than still up for debate.
Three more MVPs are proposed for 2027: Diabetic Disease, Hypertension, and Hospitalist. All 27 existing MVPs would also be revised, with new core measures added, outdated measures dropped, and the Rehabilitative Support for Musculoskeletal Care MVP renamed to simply Rehabilitative Support. Virtual groups, currently barred from reporting an MVP at all, would gain that option in 2029.
The main point: 2027 and 2028 are the runway. Practices still reporting traditional MIPS should pick a target MVP now, not in 2028.
2027: Quality Measures Get Restructured
The most consequential change to MIPS reporting itself is a new “core measure” designation, proposed for 78 measures. It replaces the current requirement to report at least one outcome measure or, when no outcome measure applies, a high-priority measure. Out of the six necessary quality criteria, traditional MIPS reports would only need one core metric. Among their four, MVP reporters would require one. Small practices are exempt, and anyone without an applicable core measure can attest to that and report a different measure instead.
Miss this requirement without qualifying for an exemption or attestation, and one required quality measure scores zero. It’s an unforced error CMS is essentially daring practices to avoid. The high-priority measure designation disappears entirely under this proposal.
The quality measure inventory shrinks slightly, from 190 measures in 2026 to a proposed 180 in 2027 QPP Proposed Rule. Twenty measures are proposed for removal, several because they’re “topped out” or no longer maintained by their measure steward. Five new PROMIS-based functional outcome measures for orthopedic patients would replace seven older FOTO-based ones. Cardiology, nephrology, anesthesiology, and audiology also pick up new measure options. Anyone reporting a measure on the removal list needs a backup plan before 2027 data collection begins.
One piece of good news buried in the scoring rules: topped-out core measures currently capped at 7 points would be scored up to a full 10 under the defined benchmark, a real upside for practices already performing near 100% on those measures. The overall MIPS performance threshold holds steady at 75 points through 2028, with no change there.
Improvement Activities see a modest refresh, with six additions, including one specifically on AI use in patient care, and 11 removals. The Cost category is essentially untouched, with no new measures, no removals, and cost still worth 30% of the total score.
2028: The Deadline
Prior Authorization was previously finalized as a required PI measure starting in 2027. This rule would soften that, making it optional and bonus-eligible in 2027 and mandatory starting 2028, while adding a second required measure, Electronic Prior Authorization for Prescription Drugs, also starting 2028. Both require EHR technology with specific FHIR-enabled, ONC-certified modules, so 2027 is really the year to confirm your EHR vendor supports them, even though reporting isn’t mandatory yet.
The Security Risk Analysis measure, a PI fixture for years, is proposed for removal starting 2027, though separate HIPAA security risk analysis obligations remain unaffected.
There’s One More Structural Shift in 2027 QPP Proposed Rule Where QP Status Applies
CMS also wants to move Qualifying APM Participant determinations from the NPI level down to the TIN/NPI level. Today, once a clinician reaches QP status, the MIPS exemption follows them across all TINs they bill under. Under this proposal, the exemption would apply only at the specific TIN where they actually achieved QP status. For doctors who divide their time among several practices, only some of which participate in an Advanced APM, that is a significant shift.
Building a 2027 QPP Proposed Rule Checklist
With the comment period open through September 14, none of this is final. But the pattern across two consecutive rulemaking cycles, 2026’s feedback requests followed by 2027’s firm deadlines, suggests CMS isn’t reversing course. A reasonable starting checklist:
- Check your current quality measures against the proposed core measure and removal lists
- Shortlist an MVP, giving the three new 2027 options a real look, especially Diabetic Disease and Hypertension, if nothing fit before
- Ask your EHR vendor about FHIR-enabled prior authorization support ahead of the 2028 mandate
- Swap out any Improvement Activity on the removal list before 2027 data collection starts
- If you bill under multiple TINs, map out which one carries your Advanced APM participation
Practices that treat this 2027 QPP Proposed Rule as a planning document, rather than waiting for the final version, get an extra reporting year to adjust before traditional MIPS reporting goes away for good.
