Last updated: November 2026
A MIPS reporting program is the standing process by which a practice picks quality measures, captures the data, submits it on time and checks the result each year under the Merit-based Incentive Payment System, 42 CFR Part 414 Subpart O. MIPS compares each MIPS eligible clinician's final score with a performance threshold to set a positive, zero or negative payment adjustment factor. The current regulation sets that threshold at 75 points for the 2027 payment year and for the 2028 through 2030 payment years. Integral Healthcare Solutions (IHS) is a consulting firm. It drafts the measure-selection worksheet, owner map, data-capture workflow and submission calendar, and your clinicians approve the measure choices.
This is program development work, one of three IHS practice lines with accreditation consulting and compliance services. It is not legal advice. We read every section cited here in the current eCFR text (GPO, built November 4, 2026) on November 5, 2026. If CMS amends the rule, the amended text controls.
What is MIPS and what does the regulation set?
The regulation sets who is in, what a submission must contain, when it is due, the threshold and the adjustment. The quality measures come from CMS: as applicable, section 414.1330(a) lists measures on the MIPS final list established by CMS through rulemaking, approved QCDR measures, facility-based measures and MIPS APM measures.
Who is in MIPS and who is out
"Except as specified in paragraph (b) of this section, MIPS applies to payments for covered professional services furnished by MIPS eligible clinicians on or after January 1, 2019." (section 414.1310(a)) For a year, paragraph (b)(1) excludes an eligible clinician who is a Qualifying APM Participant; who is a Partial Qualifying APM Participant and does not elect to participate in MIPS as a MIPS eligible clinician; or who does not exceed the low volume threshold.
Beginning with the 2023 payment year, section 414.1305 defines the low-volume threshold as applying to an individual eligible clinician or group that, during the MIPS determination period, has allowed charges for covered professional services of 90,000 dollars or less, furnishes covered professional services to 200 or fewer Medicare Part B-enrolled individuals, or furnishes 200 or fewer covered professional services to Medicare Part B-enrolled individuals. Beginning with the 2021 payment year, an individual eligible clinician or group that exceeds at least one, but not all, of those criteria and elects to participate is treated as a MIPS eligible clinician for that payment year (section 414.1310(b)(1)(iii)(A)). A new Medicare-enrolled eligible clinician is not treated as one until the subsequent year and the performance period for that subsequent year (section 414.1310(c)).
What a submission must contain and who may send it
Under section 414.1325(a)(1), clinicians, groups, virtual groups, subgroups and APM Entities must submit data for the quality, improvement activities and Promoting Interoperability categories, except as provided in paragraph (a)(2) or under sections 414.1370 or 414.1365(c), as applicable. "For the quality performance category, a data submission must include numerator and denominator data for at least one MIPS quality measure from the final list of MIPS quality measures." (section 414.1325(a)(1)(i)). For improvement activities, a submission must include a response of "yes" for at least one activity in the inventory (section 414.1325(a)(1)(ii)). Promoting Interoperability has its own required elements (section 414.1325(a)(1)(iii)).
"Except for the Medicare Part B claims submission type, the data may also be submitted on behalf of the individual MIPS eligible clinician, group, virtual group, subgroup, or APM Entity by a third party intermediary described at § 414.1400." Under section 414.1400(a)(1), those are a QCDR, a qualified registry, a CMS-approved survey vendor and, only before the CY 2025 performance period/2027 payment year, a health IT vendor.
When the data is due
For the direct, login and upload, login and attest, and CMS Web Interface submission types, the deadline is March 31 following the close of the applicable performance period or a later date as specified by CMS (section 414.1325(e)(1)). Beginning with the 2023 payment year, the quality and cost performance period is the full calendar year that occurs 2 years prior to the payment year, except as otherwise specified for administrative claims-based measures (section 414.1320(e)(1)). By IHS arithmetic, 2026 data feeds the 2028 payment year.
How the threshold and the adjustment work
"A performance threshold will be specified for each MIPS payment year." (section 414.1405(b)) The rule states the values: 75 points for the 2026 payment year, 75 for 2027 and 75 for 2028 through 2030 (section 414.1405(b)(9)(iii) and (b)(10)). A final score at or above the threshold earns a zero or positive adjustment on a linear sliding scale: 0 percent at the threshold, the applicable percent at a final score of 100; a scaling factor not to exceed 3.0 may be applied to positive adjustments for budget neutrality (section 414.1405(b)(3)). A final score below the threshold earns a negative adjustment on a linear sliding scale: 0 percent at the threshold, the negative of the applicable percent at a final score of 0; scores from zero up to one-fourth of the threshold receive the full negative of the applicable percent. The applicable percent is 9 percent for payment year 2022 and each later year (section 414.1405(c)).
What happens after you submit
Clinicians and groups that submit data must certify at submission, to the best of their knowledge, that it is true, accurate and complete (section 414.1390(b)). CMS audits selectively each year: a selected clinician or group must share requested data within 45 days of the request, or an alternate timeframe agreed with CMS, and provide primary source documents as requested (section 414.1390(a)). All clinicians and groups that submit MIPS data must retain it for 6 years from the end of the performance period (section 414.1390(d)). A targeted review of the adjustment calculation may be requested from the day CMS makes the final score available until 30 days after publication of the adjustment factors, a period CMS may extend; decisions are final (section 414.1385(a)).
Who needs it and what triggers it
An eligible practice usually needs a program build for one of these reasons:
- A negative adjustment, which a final score below the threshold produces (section 414.1405(b)(2)).
- A change of submission route or intermediary (sections 414.1325 and 414.1400).
- A CMS data request after selection for audit, which starts a 45-day clock (section 414.1390(a)(1)).
How IHS helps
IHS builds the process around your measures and data, and your staff run it. Dr. Thomas G. Goddard, founder of IHS, leads the work. These steps are IHS method, not CMS requirements:
- Check your clinician and group roster against section 414.1310.
- Draft the measure-selection worksheet: candidate measures from the CMS final list, each with its data source and owner, for your clinicians to approve.
- Build the owner map: who captures the data, who checks it, who submits.
- Document the data-capture workflow from the EHR or registry to the submission file, including the direct or intermediary decision.
- Set the submission calendar back from the submission date, with a quarterly check.
- Assemble the audit file: source documents, certification and a 6-year retention schedule.
What you supply. Your clinicians approve measure choices. Your EHR and registry data owners supply the data, and your practice manager runs the calendar.
The real limit. IHS does not submit data, calculate your score, predict your adjustment or act as a third party intermediary, and supplies no software. Measure lists for your performance year come from CMS Quality Payment Program materials.
What to have ready
Each item ties to 42 CFR Part 414 Subpart O, read November 2026.
- A roster checked against sections 414.1310 and 414.1305.
- At least one MIPS quality measure from the final list, with numerator and denominator data (section 414.1325(a)(1)(i)).
- A "yes" response for at least one improvement activity (section 414.1325(a)(1)(ii)).
- The Promoting Interoperability elements (section 414.1325(a)(1)(iii)).
- A decision on direct submission or an approved intermediary (sections 414.1325 and 414.1400).
- The submission date: March 31 after the performance period, or a later CMS date (section 414.1325(e)(1)).
- Your last final score and adjustment, set against the threshold (section 414.1405).
- Source documents, the certification and a 6-year retention plan (section 414.1390).
- Named owners for the data, the check and the submission.
The free introductory call turns that list into a calendar.
How it compares
The rule allows more than one route and status. The table records what the text says and recommends none.
| Route or status | What the text says |
|---|---|
| Direct, or login and upload | Individual quality category submission types (section 414.1325(b)(1)) |
| Medicare Part B claims | From the 2021 payment year, small practices only; not through an intermediary (section 414.1325(a)(1), (b)(1)) |
| Third party intermediary | QCDR, qualified registry, CMS-approved survey vendor or, before the CY 2025 performance period/2027 payment year, a health IT vendor (section 414.1400(a)(1)) |
| Qualifying or Partial Qualifying APM Participant | Excluded; a Partial Qualifying APM Participant is excluded unless it elects to participate in MIPS (section 414.1310(b)(1)(i)-(ii)) |
What it costs
Authority fees: the sections cited here set no fee for taking part in MIPS.
Consulting: IHS scopes each engagement after a free introductory call, and this page carries no IHS figure.
Internal staff time: your clinicians, data owners and practice manager.
What this is not
- It does not calculate or predict a MIPS score or adjustment, and guarantees no result.
- It is not legal advice, and IHS is a consulting firm, not a law firm.
- IHS does not submit data to CMS. Your practice or its approved intermediary does.
Frequently asked questions
What is MIPS and who must take part?
MIPS is the Merit-based Incentive Payment System, which sets a payment adjustment for clinicians based on a final score. It applies to MIPS eligible clinicians, except as specified in section 414.1310(b).
Who is excluded from MIPS?
For a year, an eligible clinician is excluded who is a Qualifying APM Participant, who is a Partial Qualifying APM Participant and does not elect to participate in MIPS, or who does not exceed the low volume threshold (section 414.1310(b)(1)).
What is the minimum quality data a MIPS submission must contain?
A data submission must include numerator and denominator data for at least one MIPS quality measure from the final list of MIPS quality measures (section 414.1325(a)(1)(i)).
Can a third party submit MIPS data for our practice?
Yes, through a third party intermediary described in section 414.1400, except for the Medicare Part B claims submission type (section 414.1325(a)(1)). IHS is not an intermediary and does not submit data.
What is the MIPS performance threshold?
Section 414.1405(b) states 75 points for the 2026 payment year, 75 for 2027 and 75 for the 2028 through 2030 payment years (42 CFR 414.1405). If CMS amends the rule, the amended text controls.
What happens if our MIPS final score is below the threshold?
It earns a negative adjustment on a linear sliding scale, up to the negative of the applicable percent, which is 9 percent for payment year 2022 and each later year (section 414.1405(b)(2) and (c)).
What happens if CMS audits us or we disagree with our score?
A clinician or group selected for audit must share requested data within 45 days or an alternate timeframe agreed with CMS (section 414.1390(a)). A targeted review of the calculation of the payment adjustment factors may be requested from the day CMS makes the final score available until 30 days after publication of the adjustment factors, a period CMS may extend (section 414.1385(a)).
Who chooses our measures, and what does IHS draft?
Your clinicians choose and approve the measures. IHS drafts the measure-selection worksheet, owner map, data-capture workflow, submission calendar, quarterly check and audit file, and scopes each engagement after a free introductory call.