The Centers for Medicare & Medicaid Services (CMS) has released the Calendar Year (CY) 2026 final rule for the Medicare Physician Fee Schedule (MPFS), which also includes proposals related to the Quality Payment Program (QPP). Policies outlined in the rule will take effect January 1, 2026. The following AAO-HNS overview provides details regarding the rule’s key QPP provisions impacting the field of otolaryngology.
For questions regarding provisions impacting otolaryngology-head and neck surgery, contact the AAO-HNS Health Policy Advocacy team: [email protected].
Scoring and Data Completeness
- Performance Threshold: To provide continuity and stability to program Merit-based Incentive Program (MIPS) participants, CMS has opted to maintain the current performance threshold at 75 points for the CY 2026 performance year (2028 MIPS payment year) through the CY 2028 performance year (2030 MIPS payment year).
Quality Performance Category
- Removal of Health Equity from High Priority Definition: CMS finalized the removal of health equity from the definition of a high priority measure. The definition of a high priority measure is now “an outcome (including intermediate-outcome and patient-reported outcome), appropriate use, patient safety, efficiency, patient experience, care coordination, or opioid quality measure.”
- New and Modified Measures: CMS finalized five new quality measures, including measures on hepatitis C, type 2 diabetes screening, and patient-reported falls. None are directly related to otolaryngology-head and neck surgery.
- Total Per Capita Cost (TPCC) Measure: CMS modified the TPCC measure candidate event and attribution criteria to limit instances where TPCC is attributed to highly specialized groups based solely on the billing of advanced care practitioners. CMS will now exclude candidate events initiated by an advanced care practitioner Taxpayer Identification Number-National Provider Identifier (TIN-NPI) if all other non-advanced care practitioner TIN-NPIs in their group are excluded based on the specialty exclusion criteria.
- Informational-Only Feedback Period: CMS established a 2-year informational-only feedback period for new cost measures, allowing clinicians to receive feedback on their score(s) and find opportunities to improve performance before a new cost measure affects their MIPS final score.
MIPS Value Pathways (MVPs)
- New MVPs: Six new MVPs were finalized (including diagnostic radiology, interventional radiology, neuropsychology, pathology, podiatry, and vascular surgery).
- ENT MVP Updates: CMS reinstated AAO16: Age-Related Hearing Loss: Audiometric Evaluation and removed Screening for Social Drivers of Health from the ENT MVP.
- Subgroup Reporting: Beginning January 1, CMS will allow groups to self-attest to their specialty composition (single vs. multispecialty) during the MVP registration process, rather than having CMS make this determination. Furthermore, CMS has finalized a policy that will waive the requirement for multispecialty groups with the small practice special status (15 or fewer clinicians) to register as subgroups if they don’t want to report as individuals. Subgroup reporting will remain optional for multispecialty small practices.
- Traditional MIPS Transition to MVPs: In the final rule, CMS reiterated its intent to sunset traditional MIPS and fully transition to MVPs by the CY 2029 performance period (2031 MIPS Payment Year). At this time, MVPs will become mandatory for most otolaryngologist-head and neck surgeons, unless they are eligible to report via the Alternative Payment Model (APM) Performance Pathway (APP). AAO-HNS continues to advocate for adequate testing and specialty-specific refinement before a full transition.
