Medicare alternative payment program updates for 2026

The Centers for Medicare & Medicaid Services (CMS) did not make extensive changes to their various alternative payment programs for 2026. But there are still some that participating practices should know.

Medicare Shared Savings Program

CMS finalized the removal of the quality score health equity adjustment and the Screening for Social Drivers of Health (Quality ID: 487) from the Alternative Payment Model Performance Pathway (APP) Plus measure set. They will continue to phase in additional measures as previously planned. Beginning in 2026, the set will include Colorectal Cancer Screening (Quality ID: 113) as well as Clinician and Clinician Group Risk-Standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions (Quality ID: 484). CMS has updated the Consumer Assessment of Healthcare Providers and Suppliers (CAHPS) for the Merit-based Incentive Payment System (MIPS) to include a web-based survey mode. Additionally, they revised the definition of a beneficiary eligible for Medicare Clinical Quality Measures so there is greater overlap with the list of beneficiaries that are assignable to the accountable care organization.

Quality Payment Program (QPP)

CMS will move forward with a previously finalized requirement regarding MIPS Value Pathway (MVP) subgroup reporting. Beginning in 2026, multispecialty groups that wish to report an MVP as a group will need to form subgroups. In general, multispecialty groups will no longer be able to report MVPs as a single group. However, multispecialty groups with the small practice status (15 or fewer eligible clinicians) may still report an MVP as a single group. Groups attest to their specialty composition (i.e., single or multispecialty with small practice status) during the MVP registration process.

MVPs remain optional but may be useful if you’re planning to perform Advanced Primary Care Management (APCM) services. To bill for APCM, you must either report the Value in Primary Care MVP, or participate in an MSSP or a Realizing Equity, Access, and Community Health (REACH) accountable care organization. If you are in a multispecialty practice with more than 16 eligible clinicians, you will need to either form a subgroup to report the Value in Primary Care MVP or report as individuals. Otherwise, you may continue to report via traditional MIPS but would not meet the performance reporting requirement for APCM services

As in other years, CMS made updates to the quality measure, improvement activities, and promoting interoperability (PI) inventories. They did not add any new cost measures. However, they updated the total per capita cost measure. A few updates of note include:

• Removing Screening for Social Drivers of Health (Quality ID: 487).
• Updating the High Priority Practices Safety Assurance Factors for Electronic Health Record Resilience (SAFER) Guide measure to require use of the 2025 SAFER Guides instead of the 2016 SAFER Guides.
• Adding a second attestation component to the Security Risk Analysis measure in the PI category. In addition to attesting “yes” to having completed an analysis, clinicians will also need to attest “yes” to having conducted security risk management as required under the risk management component of the HIPAA Security Rule.

Finally, CMS is providing additional stability to MIPS by setting the performance threshold at 75 points through the 2028 performance period.

— Erin Solis, Manager, Practice & Payment at the American Academy of Family Physicians

Posted on Dec. 4, 2025