The Centers for Medicare and Medicaid Services (CMS) has officially released the 2027 Quality Payment Program (QPP) final rule. The 2,468-page final rule (opens in a new tab) contains many changes that will take place in the 2027 MIPS performance year and beyond.
This blog breaks down the finalized changes to the QPP and MIPS for 2027.
Performance Threshold
CMS previously finalized maintaining the current threshold to avoid a penalty at 75 points through 2028.
Category Weights
There are no changes to performance category weights in 2027.
Quality Category
Reporting Requirements
CMS has finalized that beginning in 2027, clinicians are no longer required to submit an outcome or high priority measure. There is no longer a high priority designation for measures; instead, clinicians are required to submit at least one measure from a set of designated “MIPS Core Measures.” If none of the Core Measures apply to the clinician, they have the option to attest to this and select a different measure. Small practices are exempt from the Core Measures requirement.
Measure Scoring
Similar to the current scoring rule regarding the outcome/high priority measure requirement, CMS has finalized that clinicians who do not submit at least one Core Measure (and are not exempt or have not attested to there being no Core Measures relevant to them) will receive a 0/10 score on 1 of the 6 required Quality measures.
Additionally, Core Measures will not be subject to the topped out measure scoring method. Instead, they will receive defined benchmarks calculated using the same method applied to measures belonging to specialty sets with limited measure choice and a high proportion of topped out measures (see table below).
Click on the dropdown to see the Quality measures that will be scored using the defined topped out measure benchmarks.
Measures Scored Using Topped Out Measure Benchmarks
Quality Measures Scored Using Defined Topped Out Measure Benchmarks
The following measures will be scored using the defined topped out measure benchmarks:
- 127: Diabetes Mellitus: Diabetic Foot and Ankle Care, Ulcer Prevention – Evaluation of Footwear (MIPS CQM)
- 144: Oncology: Medical and Radiation – Plan of Care for Pain (MIPS CQM)
- 145: Radiology: Exposure Dose Indices Reported for Procedures Using Fluoroscopy (MIPS CQM)
- 249: Barrett’s Esophagus (Medicare Part B Claims, MIPS CQM)
- 250: Radical Prostatectomy Pathology Reporting (Medicare Part B Claims, MIPS CQM)
- 351: Total Knee or Hip Replacement: Venous Thromboembolic and Cardiovascular Risk Evaluation (MIPS CQM)
- 360: Optimizing Patient Exposure to Ionizing Radiation: Count of Potential High Dose Radiation Imaging Studies: Computed Tomography (CT) and Cardiac Nuclear Medicine Studies (MIPS CQM)
- 364: Optimizing Patient Exposure to Ionizing Radiation: Appropriateness: Follow-up CT Imaging for Incidentally Detected Pulmonary Nodules According to Recommended Guidelines (MIPS CQM)
- 395: Lung Cancer Reporting (Biopsy/Cytology Specimens) (Medicare Part B Claims, MIPS CQM)
- 396: Lung Cancer Reporting (Resection Specimens) (MIPS CQM)
- 397: Melanoma Reporting (Medicare Part B Claims, MIPS CQM)
- 405: Appropriate Follow-up Imaging for Incidental Abdominal Lesions (MIPS CQM)
- 406: Appropriate Follow-up Imaging for Incidental Thyroid Nodules in Patients (Medicare Part B Claims, MIPS CQM)
- 440: Skin Cancer: Biopsy Reporting Time - Pathologist to Clinician (MIPS CQM)
- 477: Multimodal Pain Management (MIPS CQM)
The following measure scoring rules will remain in effect:
- Large practices (>15 clinicians) will continue to be scored on a 1–10-point scale for measures meeting data completeness and case minimum.
- Small practices will continue to receive a 3-point floor (i.e., they will be scored on a 3–10-point scale).
Bonuses
- No change to the small practice bonus or the improvement score bonus.
Measures
CMS has finalized the following changes to the 2027 Quality measure inventory:
- 10 new measures
- 20 measure removals
- 43 existing measures with substantive changes
Data Completeness Threshold
- This will remain at 75% for performance years 2027–2028.
Cost Category
Cost Measure Inventory
There are no new cost measures or removals for the 2027 performance year.
Improvement Activities
Improvement Activities List
There are several changes to the list of improvement activities (IAs), including:
- 6 new IAs:
- Use of Data to Improve Practice Workflows
- Understand and Improve Diagnostic Performance
- Systematic Screening and Intervention for Nutrition and Other Health-Impacting, Non-Clinical Issues
- Advance Care Planning Conversations to Support Patient Wellness and Care Preferences
- Clinician Use of Artificial Intelligence (AI) to Improve Patient Care
- Lifestyle Approaches to Diabetes Remediation
- 5 changes to existing IAs
- 11 removals:
- BMH_5: MDD Prevention and Treatment Interventions
- CC_10: Care Transition Documentation Practice Improvements
- CC_11: Care Transition Standard Operational Improvements
- CC_12: Care Coordination Agreements That Promote Improvements in Patient Tracking Across Settings
- PSPA_2: Participation in MOC Part IV
- CC_16: Primary Care Physician and Behavioral Health Bilateral Electronic Exchange of Information for Shared Patients
- BE_15: Engagement of Patients, Family, and Caregivers in Developing a Plan of Care
- PM_19: Glycemic Screening Services
- PM_20: Glycemic Referring Services
- EPA_4: Additional Improvements in Access as a Result of QIN/QIO TA
- PM_2: Anticoagulant Management Improvements
Promoting Interoperability (PI)
There are many changes to the PI category. Unless otherwise specified, changes will take effect in 2027.
ONC/ASTP Direct Review and ONC-ACB Surveillance Attestations
CMS has finalized the removal of the required ONC/ASTP Direct Review and the optional ONC-ACB Surveillance attestations from the PI category beginning with the 2026 performance period.
Security Risk Analysis
CMS is removing the Security Risk Analysis (SRA) requirement from the MIPS PI category. Note that the SRA is required under HIPAA and thus still needs to be completed, even though it has been finalized for removal from MIPS.
New Electronic Prior Authorization Measure
Under this measure, for at least one medical item or service (excluding drugs), clinicians are required to attest “yes” to having requested a prior authorization electronically through a Prior Authorization API using CEHRT.
This measure will be an optional bonus measure for 2027 and mandatory for 2028. CMS has finalized that clinicians will receive 10 bonus points for reporting this measure.
Beginning in 2028, the measure will not only become mandatory but also have additional requirements. Clinicians will have to use CEHRT to electronically discover applicable coverage requirements, complete required documentation, submit the prior authorization request, and receive the payer response through a Prior Authorization API.
New Electronic Prior Authorization for Prescription Drugs Measure
Under this measure, for at least one prescription drug, clinicians are required to attest “yes” to having used CEHRT to complete a prior authorization request.
This measure will be mandatory beginning in 2028.
MIPS Value Pathways (MVPs)
CMS has finalized sunsetting traditional MIPS and making MVP reporting mandatory beginning with the 2031 performance year, rather than the proposed 2029 performance year.
For the 2027 performance year, CMS has finalized 3 new MVPs: Diabetic Disease, Hospitalist, and Hypertension.
CMS has also finalized applying the “MIPS Core Measures” requirement to MVP reporting. Each MVP has a set of designated Core Measures. At least 1 of the 4 required quality measures submitted for MVP reporting must be a Core Measure. If none of the Core Measures apply to the clinician, they have the option to attest to this and select a different measure. Small practices are exempt from the Core Measures requirement.
Next Steps
- Share this information with your colleagues.
- Check back in the coming weeks for information on how to register for our 2027 MIPS Final Rule webinar, where we will cover these changes in detail and answer your questions.
- If you are an Anatomy IT client, contact your MIPS Expert if you have any questions.
- If you are not an Anatomy IT client, contact us (opens in a new tab) to learn more about our MIPS Success Plan and to reap the rewards of our combined decades of experience.
If you have any questions on this, let us know!
Written By: Sarrah Hakim, MHSA
About the Author: Sarrah is the Director of Health Policy at Anatomy IT.