The Quality Payment Program (QPP) is entering a transitional phase. The fact that MIPS has remained remarkably unchanged in 2026 is no accident. CMS is shifting its focus towards something new with the goal of creating a model that is more challenging, more clinically meaningful, and with higher financial returns for the best performers. Sound familiar? It should, this is what MIPS was SUPPOSED to be before falling wildly short. Well CMS has learned from that experience and has turned its sites to MVPs (MIPs Value Pathways), an alternative reporting option to MIPS, offering a smaller, more specialty-specific set of measures and Improvement activities. It’s anticipated in the next few years, traditional MIPS will end and MVPs will be used as a stepping stone to something new.
For the first time this year Pathology has an MVP available for reporting, which means you now have the choice of reporting via traditional MIPS or the Pathology MVP or both, receiving the higher of the two scores and creating a low-risk opportunity to test MVP participation. Under an MVP you are scored on your top four performing quality measures instead of the traditional six under MIPS. You may register for an MVP any time between April and November 2026, with no obligation to submit after registering. Looking ahead a few years, CMS is expected to introduce more competitive models, similar to the Ambulatory Specialty Model (ASM) beginning in 2027, where mandatory quality measures are chosen for you and performance is benchmarked directly against peers within your specialty.
To prepare for this evolving landscape, begin aligning your quality strategies now. First, begin tracking your performance on the quality measures within the Pathology MVP with the goal of achieving strong performance on at least four measures over the next one to two years. This will ensure readiness as MVPs become more central to reporting. Second, engage in the development of meaningful, specialty-specific quality measures. You are uniquely positioned to shape the future of performance measurement, so please submit ideas to MSN’s QCDR Measure Development Workgroup by filling out our New Measure Idea Submission Form.
MSN is actively supporting Pathologists through this transition and our QCDR’s aim is to make MVP participation as seamless as possible. Our QCDR Measure Development Workgroup has developed nine pathology-specific quality measures to date, with eight available for reporting in 2026, giving participants expanded flexibility and strategic options. This includes four measures currently incorporated into the Pathology MVP and only available through MSN’s QCDR (QMM21, QMM25, QMM29, and QMM30). We continuously monitor regulatory updates and CMS proposals to ensure our clients remain ahead of program changes and positioned for success. We will assist our QCDR clients with MVP registration (more details to follow this summer) and handle submission under the MVP for no additional charge. As the QPP evolves, our goal is to equip you with the tools, insights, and support needed to not only remain compliant, but to thrive in the next generation of value-based care.
Marissa Pearce
MHS
Executive Director of Quality Payment Programs
Marissa is MSN’s Executive Director of Quality Payment Programs. She has over 20 years of experience in financial analytics, practice management, and reimbursement on both the provider and facility sides. Marissa earned her degree in Accounting from the University of Maryland and her Master’s in Healthcare Finance and Management from Johns Hopkins. She works to guide her clients through the intricacies of value-based purchasing models, allowing them to achieve program goals while preserving their time for what matters most – caring for patients.
