Finalized Changes to MIPS Value Pathway for Ophthalmology in 2026

The Centers for Medicare and Medicaid Services (CMS) finalized updates to the Complete Ophthalmologic Care MVP for the 2026 performance year.

Although MVP reporting is currently voluntary, CMS has expressed the intention of sunsetting traditional MIPS and transitioning to MVPs entirely in the future. In the 2025 MIPS proposed rule, CMS requested feedback on the possibility of making MVPs mandatory as early as 2029.

Anatomy IT will continue to advocate for MVPs to be optional and for improvements to the Complete Ophthalmologic Care MVP to make it possible for all ophthalmic subspecialties to be successful.

In this blog, we’ll break down what MVPs are, how to report them, and what changes were finalized in the 2026 Complete Ophthalmological Care MVP.

What is a MIPS Value Pathway (MVP)?

CMS introduced MVPs as an alternative reporting option to traditional MIPS in 2023. According to CMS, MVPs aim to simplify MIPS, reduce reporting burden, and help patients make more informed decisions when choosing their clinicians.

Each MVP has its own specific set of quality measures, improvement activities (IAs), and cost measures, and you are limited to those measures and activities when reporting the MVP. The Promoting Interoperability (PI) category is included as part of a “foundational layer,” meaning that PI requirements are the same for every MVP. Also included in the foundational layer is a population health measure, which contributes to your overall Quality score.

Can I Report an MVP Through a Registry?

Since 2023, Qualified Registries (QRs) and Qualified Clinical Data Registries (QCDRs), such as the Intelligent Research in Sight (IRIS) Registry, have been required to support all measures in the Quality, IA, and PI categories of the MVPs relevant to their clinicians. They are not required to support the Cost category, Population Health measures, QCDR measures, or the CAHPS for MIPS Survey.

How Are MVPs Different from Traditional MIPS?

The table below highlights the differences by category between reporting traditional MIPS versus reporting an MVP.

If you choose to report both traditional MIPS and an MVP, CMS will assign you the higher of the two scores.

How Do I Report an MVP?

To report an MVP for the 2026 performance year, you must register between April 1, 2026, and November 30, 2026, at 8 pm ET. Registration is available through your QPP account.

At the time of registration, you must include the following information:

The MVP you are choosing to report,
Any administrative claims measures you would like to be included as 1 of your 4 required Quality measures,
Whether you are planning to count the CAHPS for MIPS Survey measure towards 1 of the 4 required Quality measures, and
Your participation level (group, subgroup, individual, APM).

If you are reporting at the group level, you will have the chance to attest to being a single-specialty group or a small multi-specialty group (15 or fewer clinicians).

If you report at the group level and are part of a large multi-specialty group (more than 15 clinicians), you are required to report at the subgroup level in 2026.

If you are an Anatomy IT client, we will discuss whether to report an MVP during your kickoff call.

What Are the 2026 Changes to the MVP for Ophthalmology?

CMS finalized the following changes to the 2026 Complete Ophthalmologic Care MVP:

Removed 1 quality measure:
487: Screening for Social Drivers of Health *
Removed 2 improvement activities:
PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B *
AHE_9: Implement Food Insecurity and Nutrition Risk Identification and Treatment Protocols *

*These measures were also removed from traditional MIPS.

To see all the measures and activities included in the 2026 Compete Ophthalmologic Care MVP, click on the category names below.

Complete Ophthalmologic Care Measures (Specific to This MVP)

Complete Ophthalmologic Care MVP Quality Measures

12: Primary Open-Angle Glaucoma (POAG): Optic Nerve Evaluation
19: Diabetic Retinopathy: Communication with the Physician Managing Ongoing Diabetes Care (high priority)**
117: Diabetes: Eye Exam
130: Documentation of Current Medications in the Medical Record (high priority)**
141: Primary Open-Angle Glaucoma (POAG): Reduction of Intraocular Pressure (IOP) by 20% OR Documentation of a Plan of Care (outcome)**
191: Cataracts: 20/40 or Better Visual Acuity Within 90 Days Following Cataract Surgery (outcome)**
226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
303: Cataracts: Improvement in Patient’s Visual Function Within 90 Days Following Cataract Surgery (outcome)**
304: Cataracts: Patient Satisfaction Within 90 Days Following Cataract Surgery (high priority)**
374: Closing the Referral Loop: Receipt of Specialist Report (high priority)**
384: Adult Primary Rhegmatogenous Retinal Detachment Surgery: No Return to the Operating Room Within 90 Days of Surgery (outcome)**
385: Adult Primary Rhegmatogenous Retinal Detachment Surgery: Visual Acuity Improvement Within 90 Days of Surgery (outcome)**
389: Cataract Surgery: Difference Between Planned and Final Refraction (outcome)**
499: Appropriate Screening and Plan of Care for Elevated Intraocular Pressure Following Intravitreal or Periocular Steroid Therapy
500: Acute Posterior Vitreous Detachment Appropriate Examination and Follow-up
501: Acute Posterior Vitreous Detachment and Acute Vitreous Hemorrhage Appropriate Examination and Follow-up
503: Gains in Patient Activation Measure (PAM®) Scores at 12 Months (outcome)**
IRIS2: Glaucoma – Intraocular Pressure Reduction (outcome)**
IRIS13: Diabetic Macular Edema – Loss of Visual Acuity (outcome)**
IRIS39: Intraocular Pressure Reduction Following Trabeculectomy or an Aqueous Shunt Procedure (outcome)**
IRIS54: Complications After Cataract Surgery (outcome)**
IRIS58: Improved Visual Acuity After Vitrectomy for Complications of Diabetic Retinopathy Within 120 Days (outcome)**
IRIS61: Visual Acuity Improvement Following Cataract Surgery and Minimally Invasive Glaucoma Surgery (outcome)
AHW_1: Chronic Care and Preventative Care Management for Empaneled Patients
BE_4: Engagement of Patients Through Implementation of Improvements in Patient Portal
BE_6: Regularly Assess Patient Experience of Care and Follow Up on Findings
BE_25: Drug Cost Transparency
CC_9: Implementation of Practices/Processes for Developing Regular Individual Care Plans
CC_10: Care Transition Documentation Practice Improvements
CC_13: Practice Improvements to Align with OpenNotes Principles
EPA_7: Enhance Engagement of Medicaid and Other Underserved Populations
PM_16: Implementation of Medication Management Practice Improvements
PSPA_7: Use of QCDR Data for Ongoing Practice Assessment and Improvements
PCMH: Electronic Submission of Patient Centered Medical Home Accreditation
MVP: Practice-Wide Quality Improvement in MIPS Value Pathways
Cataract Removal with Intraocular Lens (IOL) Implantation

10-episode case minimum

Foundational Layer (Applies to All MVPs)

479: Hospital-Wide, 30-Day, All-Cause Unplanned Readmission (HWR) Rate for the Merit-Based Incentive Payment Systems (MIPS) Groups
484: Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions

All of the following attestations and measures are required (no exclusions):

Use of CEHRT
Actions to Limit or Restrict Interoperability of CEHRT
ASTP/ONC Direct Review
High Priority SAFER Guides Assessment
Security Risk Analysis
Provide Patients Electronic Access to Their Health Information

All of the following measures are required (unless claiming an exclusion):

e-Prescribing
Query of Prescription Drug Monitoring Program (PDMP)
Immunization Registry Reporting
Electronic Case Reporting

One of the following options is required:

Option 1: Support Electronic Referral Loops by Sending Health Information + Support Electronic Referral Loops by Receiving and Reconciling Health Information

Exclusions are available for both measures in this option.

You can optionally report on one of the following measures for up to 5 bonus points in the PI category:

Syndromic Surveillance Reporting
Clinical Data Registry Reporting
Public Health Registry Reporting
Public Health Reporting Using TEFCA

Is Reporting the Complete Ophthalmologic Care MVP in 2026 Worth It?

Yes. CMS is considering making MVP reporting mandatory starting in 2029. That means there are only a few MIPS performance years left to find flaws, gather data, and recommend improvements before MVPs become the only way in which you can participate in MIPS and avoid a penalty. By reporting the 2026 Complete Ophthalmologic Care MVP, you will:

Gain invaluable experience to prepare you for mandatory MVP reporting,
Not negatively impact your MIPS payment adjustment as long as you also report traditional MIPS (even if you score poorly in the MVP), and
Be able to provide real-world feedback to CMS to help them improve the MVP available to you before MVP reporting becomes mandatory. You can communicate with us to describe your experience with the MVP or you can tell CMS directly by commenting on the 2027 Medicare Physician Fee Schedule Proposed Rule this summer or by following the steps outlined here by CMS.

Next Steps

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Written By: **Sarrah Hakim, MHSA

About the Author: Sarrah is the Director of Health Policy at Anatomy IT.