MIPS in 2027: What CMS’s Proposed Rule Means for Your Practice

CMS released its proposed Calendar Year 2027 Physician Fee Schedule rule in July 2026, and buried inside it is a set of Quality Payment Program changes that will reshape how practices report MIPS for years to come. The comment period is open through September 14, 2026, with a final rule expected later this fall — which means practices still have a window to weigh in, but not much time to wait around before planning next year’s reporting strategy.

What’s proposed to change for 2027

The proposal doesn’t touch MIPS performance category weights, but it does shift what counts as compliant reporting in a few real ways:

• No more required outcome or high-priority measure. Starting in 2027, clinicians would no longer have to submit at least one outcome or high-priority measure as part of their Quality score — a rule that’s tripped up plenty of practices scrambling each year to find an applicable measure that actually fit their specialty.
• Three new MVPs. CMS is proposing new MIPS Value Pathways for diabetic disease, hypertension, and hospitalist care, on top of updates to all 27 previously finalized MVPs.

If your practice already handles MIPS/MACRA quality reporting in-house, these are the kind of measure-set changes that are easy to miss until submission season — and expensive to discover late.

The bigger shift: traditional MIPS is on its way out

The headline change isn’t really about 2027 at all — it’s about what comes after. CMS is proposing to sunset traditional MIPS reporting after the 2028 performance period. Starting with performance year 2029, clinicians who aren’t participating in a MIPS APM would have exactly one reporting option left: MIPS Value Pathways.

That’s a two-year runway, not a two-year grace period. Practices that wait until the traditional pathway actually disappears to figure out which MVP fits their specialty mix will be starting from zero in a year when there’s no fallback option left.

A new mandatory program most practices haven’t heard of yet

MIPS isn’t the only reporting change on the way. The same proposed rule introduces the Ambulatory Specialty Model (ASM) — a mandatory, condition-specific payment model launching in 2027 with no opt-out for selected clinicians.

Unlike MIPS, which practices can generally choose how (and whether) to participate in, ASM assigns clinicians based on random selection within specific Core-Based Statistical Areas. For 2027, CMS has proposed two cohorts: roughly 3,400 clinicians treating heart failure and roughly 5,200 treating low back pain.

If your practice includes clinicians who manage either condition, it’s worth finding out now whether you fall inside one of the selected regions — mandatory model participation is a very different planning problem than a reporting pathway you can opt into on your own timeline.

What to do before the final rule lands

• Submit a comment if the proposed changes affect your specialty. The window closes September 14, 2026, and CMS does read specialty-specific feedback before finalizing.
• Start mapping your patient population against the specialty-specific MVPs now, even before MVPs become the only option — a trial year gives you a real performance baseline instead of a cold start.
• Check your ASM cohort exposure if your practice treats heart failure or low back pain patients.
• Don’t wait for the final rule to start data collection. Most measure sets need a full performance year of data, and “the rule isn’t final yet” isn’t a reason CMS accepts for incomplete reporting.

Quality reporting only pays off if the data collection is happening in the background all year, not scrambled together in Q4. Our MIPS/MACRA Quality Reporting service tracks measure selection, MVP fit, and submission deadlines as part of the standard revenue cycle work we do for every client — so a rule change like this becomes a planning conversation, not a fire drill.