Medicare quality reporting continues to evolve as the Centers for Medicare & Medicaid Services (CMS) works to make performance measurement more relevant to clinical practice. For healthcare providers participating in the Merit-based Incentive Payment System (MIPS), understanding these changes is important for planning future reporting activities and maintaining an organized reporting process.
MIPS Value Pathways (MVPs) offer a more focused approach by connecting reporting requirements to specific medical specialties and clinical topics. Providers who currently report through Traditional MIPS may need to review their options, assess their reporting workflows, and understand how future policy changes could affect their practices.
CMS has also proposed a transition away from Traditional MIPS beginning with the 2029 performance period. However, this remains a proposal rather than a finalized requirement. CMS’s July 2026 announcement outlines the proposed direction.
This article explains the differences between Traditional MIPS and MVPs, what providers should expect during the transition, and how practices can prepare for future reporting requirements.
Traditional MIPS vs. MVPs: What Is Changing?
Traditional MIPS and MVPs are both reporting options within the Quality Payment Program. The main difference is how performance reporting is organized and how providers select the measures and activities applicable to their participation.
Traditional MIPS allows eligible clinicians to select from applicable measures and activities within the broader MIPS framework. MVPs organize reporting around a specific specialty or clinical topic, giving practices a more defined set of requirements to review.
This change is intended to make performance reporting more connected to the care providers deliver. However, the actual impact depends on the practice’s specialty, reporting method, available data, and selected pathway.
A Different Approach to Measure Selection
Under Traditional MIPS, providers review the available measures and select those that meet the program’s requirements and fit their practice. The selection process can require careful consideration of measure specifications, patient populations, and data availability.
MVPs provide a more structured starting point. Each pathway includes measures and activities associated with a particular clinical area. Providers can review the available options and determine whether a pathway fits their services and patient population.
For example, a surgical practice may evaluate an MVP designed around surgical care, while an emergency medicine practice may review a pathway related to emergency medicine. The relevant options depend on the finalized MVP inventory for the performance year.
This does not mean every measure will automatically suit every clinician in a specialty. Practices still need to review the specific requirements before deciding which reporting option is appropriate.
More Connection Between Measures and Clinical Practice
One goal of MVPs is to make performance measurement more meaningful by connecting related measures and activities within a clinical theme.
For providers, this means considering how the selected pathway relates to their everyday work. A suitable pathway should be relevant to the services delivered, the patients treated, and the information the practice can reliably collect.
This structure may also help practices understand how their reporting activities fit together. However, an MVP does not guarantee better performance or less administrative work. Providers must still meet applicable requirements and monitor their reporting processes throughout the performance year.
Differences in Reporting Requirements
MVP reporting follows pathway-specific requirements. Providers must review the applicable measures, activities, registration rules, and submission instructions for their selected MVP.
Some requirements also depend on participation type, practice size, reporting method, and special status. Practices should therefore avoid assuming that the same process will work for every MVP or every reporting year.
The safest approach is to review the official CMS guidance before making changes to an established reporting workflow.
What Providers Should Expect During the Transition
Moving from Traditional MIPS toward MVP reporting may require changes in how practices plan, collect, review, and submit performance data. The transition is not simply a matter of selecting a new reporting option. Providers should also consider the operational work needed to meet the applicable requirements.
Reviewing Available MVP Options
The first step is to identify the MVPs available for the relevant performance year and determine which ones align with the practice’s specialty and clinical services.
Providers should review the measures included in each relevant pathway, the associated reporting instructions, and the data required to complete reporting. They should also confirm that their participation type is eligible to report through the selected option.
Practices with multiple specialties may need additional planning because a single pathway may not represent every service they provide. In these situations, administrators should review the applicable CMS rules before deciding how reporting should be organized.
CMS maintains an official inventory of finalized pathways through its MVP reporting .
Changes to Reporting Workflows
A new reporting pathway can affect how information moves between clinical staff, administrative teams, and reporting systems.
Practices should review their current processes to identify which tasks can continue as they are and which may need adjustment. For example, a practice may need to update its data collection procedures, revise internal reporting checklists, or change how staff track missing information.
It is also important to establish clear responsibilities. Someone should be accountable for monitoring reporting requirements, checking data quality, tracking deadlines, and confirming that submissions are completed correctly.
Planning these responsibilities early can help practices avoid last-minute problems during the reporting period.
Greater Need for Data Readiness
Accurate and complete data remains essential when reporting through MVPs. Practices should understand where the required information is stored, how it is collected, and whether it can be retrieved in the format needed for reporting.
An electronic health record system may contain much of the required information, but that does not automatically mean all reporting requirements are covered. Some information may need additional review, validation, or support from a reporting vendor.
Before selecting a pathway, practices should identify potential gaps in their systems and documentation processes. Early checks can help staff address problems before the reporting deadline approaches.
Coordination Between Clinical and Administrative Teams
Successful reporting often depends on cooperation between people who collect clinical information and those who manage reporting requirements.
Clinicians may need to document information consistently, while administrative staff monitor reporting progress and identify incomplete records. Practice managers may coordinate deadlines, staff responsibilities, and communication with external reporting partners.
Clear ownership can make this work easier to manage. Practices should establish who reviews data, who resolves errors, and who confirms that all required reporting activities have been completed.
Preparing for Future Reporting Requirements
CMS continues to update the Quality Payment Program through rulemaking and annual guidance. Providers should understand the current reporting options while keeping future changes in view.
Understanding the Proposed 2029 Transition
In July 2026, CMS proposed sunsetting Traditional MIPS beginning with the 2029 performance period and transitioning eligible clinicians toward MVP reporting. Under the proposal, clinicians generally would have through the end of 2028 to transition, with an exception described for certain MIPS Alternative Payment Model (APM) participants reporting through the APM Performance Pathway (APP).
The proposal also includes plans to expand the available MVP inventory. These proposed changes indicate the direction CMS is considering for future performance reporting.
However, providers should not treat the proposed timeline as a finalized requirement. The proposal must be distinguished from existing rules, and practices should monitor CMS announcements and the applicable final rule before making decisions based on a future deadline.
For the latest information, consult the official CMS announcement and the Quality Payment Program Resource Library.
What Providers Should Monitor Next
Providers should follow changes that directly affect their participation and reporting responsibilities. These may include updates to MVP availability, registration deadlines, pathway requirements, reporting methods, and implementation timelines.
Practices should also distinguish between finalized requirements for the current performance year and proposed changes intended for future years. This helps prevent unnecessary workflow changes based on policies that may be revised before finalization.
Regularly reviewing official CMS resources is a practical way to keep reporting plans current.
How Providers Can Prepare for MVP Reporting
Practices do not need to wait for a future policy deadline to review their reporting readiness. A few practical steps can help them understand their options and identify areas that need attention.
1. Review current reporting obligations. Confirm MIPS eligibility, participation status, and the requirements that apply to the practice for the relevant performance year.
2. Explore available MVPs. Review the finalized CMS inventory and identify pathways that align with the practice’s specialty and clinical services.
3. Assess existing data and systems. Determine whether the practice can collect, validate, and report the information required by a potential MVP.
4. Identify workflow gaps. Review current documentation and reporting processes to find missing information, unclear responsibilities, or tasks that need to be updated.
5. Assign reporting responsibilities. Establish who will oversee pathway selection, data checks, deadlines, and submission activities.
6. Monitor CMS updates. Check official guidance regularly, especially when planning for future performance years or responding to proposed policy changes.
These steps can help practices make informed decisions without assuming that every provider must immediately move away from Traditional MIPS.
Common Transition Mistakes to Avoid
Choosing an MVP Without Reviewing Its Requirements
A pathway may appear relevant to a specialty but still include requirements that need careful evaluation. Practices should review the complete pathway specifications before selecting an option.
Delaying Preparation Until Reporting Season
Waiting until the end of the performance year can make it harder to correct missing data or adjust reporting processes. Early planning gives practices more time to identify and address issues.
Assuming Every Specialty Has the Same Options
MVP availability and requirements vary by pathway and performance year. Providers should consult the applicable CMS inventory rather than rely on general descriptions.
Treating Proposed Changes as Final
CMS proposals can change before finalization. Practices should use proposed timelines for planning purposes while relying on finalized rules and current official guidance to determine their actual obligations.
Frequently Asked Questions
What Is the Main Difference Between Traditional MIPS and MVPs?
Traditional MIPS uses the broader MIPS reporting framework, while MVPs organize applicable measures and activities around a specific specialty or clinical topic. Both are reporting options within MIPS.
Are MVPs Available for the 2026 Performance Year?
Yes. CMS lists finalized MVPs for the 2026 performance year. Providers should review the available pathways and confirm which requirements apply to their participation type.
Is Traditional MIPS Ending in 2029?
CMS proposed sunsetting Traditional MIPS beginning with the 2029 performance period in July 2026. This should be described as a proposal unless and until the applicable policy is finalized.
How Can Providers Identify a Suitable MVP?
Providers should compare available pathways with their specialty, clinical services, patient population, data capabilities, and reporting obligations. They should also review the official requirements for the relevant performance year.
What Should Practices Do Before Moving to MVP Reporting?
Practices should confirm their current obligations, review relevant MVPs, assess their data and reporting workflows, assign responsibilities, and follow CMS guidance for finalized requirements and future changes.
Conclusion
The shift toward MIPS Value Pathways reflects CMS’s effort to organize performance reporting around more clinically relevant specialties and topics. For providers, understanding this approach can help with reporting decisions, workflow planning, and preparation for future program changes.
Practices should begin by reviewing their current reporting obligations and identifying MVPs that fit their services. They should also assess data readiness, clarify staff responsibilities, and monitor official CMS guidance.
Most importantly, providers should distinguish current requirements from proposed future changes. Early preparation can help practices respond to finalized policies with a clearer plan and fewer avoidable disruptions.
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