CMS wants your input on the 2026 Proposed Rule for MIPS
By Besse Medical
You can make comments and submit feedback by Friday, September 12, 2025, at 5 p.m. ET at CMS’ website http://www.regulations.gov. On the CMS site, you will file Code CMS-1832-P with comments addressing the support or opposition of a proposal, along with supporting reasons (legal, clinical or program experience). CMS will also accept supporting articles or references with your comments.
Some of the proposed changes include:
- Under the current MIPS reporting, you are required to complete a Security Risk Assessment (SRA) annually and attest under the Promoting Interoperability category. Next year, you could be required to attest that you are conducting management activities like checking on any potential threats which could break confidentiality of patients and your electronic health information. You would be required to write out the identified threats and create activities to prevent or manage those threats.
- In general, CMS is considering the future use of the Health Level 7 Fast Healthcare Interoperability Resource (FHIR) standard for CMS programs and is looking for comments on how you use that technology.
- CMS is also proposing that your practice can determine how your practice or group can attest to their specialty composition during the MVPs (MIPS Value Pathways) registration. Multispecialty groups have been proposed to report as subgroups or individuals if reporting MVPs, but CMS has proposed that groups can attest to their specialty designation, and any small multispecialty practices (15 or fewer clinicians) are still able to register as a group rather than a subgroup.
The MIPS Consulting Team, a team of experienced account managers and project coordinators, can partner with your practice to ensure you are maximizing your potential reimbursements from CMS, and offering insights into your workflow processes to help you move towards better performance. To consider working with them, email info@intrinsiq.com.
