On Nov. 5, CMS published the 2026 final rule, including updates to the Quality Payment Program (“QPP”). The College submitted comments on the corresponding proposed rule on Sept. 12.
Under traditional MIPS, allergists receive a positive, neutral, or negative payment adjustment based on their performance across four categories: Cost, Quality, Improvement Activities (IA), and Promoting Interoperability (PI). CMS assigns specific weights to each category when calculating the final performance score. For the 2026 performance year, category weights for Quality, Cost, IA, and PI will remain unchanged from 2025.
- 30% for the Quality performance category
- 30% for the Cost performance category
- 15% for the IA performance category
- 25% for the PI performance category
Proposed performance threshold
When calculating the MIPS payment adjustment, CMS compares the final score to the established performance threshold. Clinicians whose final scores exceed the threshold will receive a positive adjustment. Those whose scores meet the threshold will receive a neutral adjustment, and those whose scores fall below the threshold will receive a negative adjustment. CMS has finalized its proposal to maintain the 75-point performance threshold through the 2028 performance period. ACAAI commends CMS for choosing not to increase the threshold for the 2026 performance year.
2026 final score estimates
CMS estimates that the median final MIPS score for 2026 will be 89.47, with approximately 84.04% of eligible clinicians receiving a positive payment adjustment, 4.03% receiving a neutral adjustment, and 11.92% receiving a negative adjustment. However, solo practitioners and small practices will likely continue to receive the most penalties:
| Estimated median final | Estimated % receiving a penalty | |
|---|---|---|
| All MIPS eligible clinicians | 89.47 | 11.92% |
| All Solo practitioners | 75.00 | 49.16% |
| All small practices | 87.53 | 21.04% |
Quality performance category
Beginning with the 2026 performance period (and future years), CMS is removing the following quality measure from the Allergy/Immunology Specialty Measure Set:
- Screening for social drivers of health
- Connection to community service provider
- Adult COVID-19 vaccination status
Accordingly, the Allergy/Immunology Specialty Measure Set will include only the following measures:
- Adult Immunization Status
- Adult Sinusitis: Antibiotic Prescribed for Acute Viral Sinusitis (Overuse)
- Adult Sinusitis: Appropriate Choice of Antibiotic: Amoxicillin With or Without Clavulanate Prescribed for Patients with Acute Bacterial Sinusitis (Appropriate Use)
- Closing the Referral Loop: Receipt of Specialist Report
- Documentation of Current Medications in the Medical Record
- Gains in Patient Activation Measure (PAM) Scores at 12 Months
- HIV Annual Retention in Care
- HIV Viral Suppression
- Optimal Asthma Control
- Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented
- Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
- Use of High-Risk Medications in Older Adults
Cost performance category: total per capita cost (TPCC) measure
Beginning in the 2026 performance period, CMS will update the candidate event and attribution rules for the TPCC measure. The TPCC measure is a population-based cost measure that evaluates a patient’s overall cost of care.
PI performance category: new measure suppression policy
Beginning with the 2026 performance period, CMS is adopting a measure suppression policy that will not assess the performance of a suppressed measure. This new policy will allow MIPS eligible clinicians to receive the maximum available points or full credit for a measure. Under this policy, if certain circumstances occur (based on the factors below), CMS may suppress the affected measure. However, the affected measure must still be reported. In determining whether certain circumstances warrant suppression, CMS will consider one or more of the following factors:
- The nature, breadth, and duration of the circumstance’s effect on MIPS eligible clinicians’ ability to fulfill the measure requirement
- The availability of certified health IT modules to fulfill the measure
- The circumstance affects the measure such that calculating the measure score would lead to misleading or inaccurate results, which may include performance or compliance
- Out-of-date or conflicting technical standards
- Technical and operational capacity of required partners.
- Other factors as determined by CMS.
MIPS Value Pathway (MVPs)
CMS has established a new reporting option that may eventually replace the existing MIPS program. CMS has not yet confirmed when the traditional MIPS program will end, at which point MVPs would become mandatory. The College’s Advocacy Council continues to advocate against sunsetting the traditional MIPS program and transitioning to MVP reporting.
To date, CMS has not established an allergy-specific MVP. ACAAI and AAAAI will be submitting a proposed Allergy/Immunology MVP to CMS in February of 2026. The College’s Advocacy Council will continue to advocate for the most appropriate reporting options for allergists under the MVP program.
Read more details on the 2026 QPP Final Rule.
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
