On July 14, CMS released a proposed rule updating the Medicare Physician Fee Schedule and Quality Payment Program (QPP) for the 2026 calendar year (Proposed Rule). This article—part one of a multi-part series—focuses on the QPP, providing an overview of key proposals and examining their potential impact on allergists. There are no significant proposed changes to the traditional Merit-based Incentive Payment System (MIPS) for 2026, as CMS seeks to maintain stability within the program. CMS estimates that a large number of small and solo practices will receive penalties, due in part to the burdensome process and the extensive amount of resources required to participate.
As a refresher, under MIPS, eligible clinicians will receive a positive, neutral, or negative payment adjustment based on their performance across four categories: Cost, Quality, Improvement Activities (IA), and Promoting Interoperability (PI). 2026 performance category weights for Quality, Cost, IA, and PI will remain the same as in 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 clinician’s final score to the performance threshold. A clinician will receive a positive adjustment if the final score exceeds the performance threshold. A clinician will receive a neutral adjustment if the final score meets the performance threshold. A clinician will receive a negative adjustment if the final score is below the performance threshold. CMS proposes to maintain its current performance threshold at 75 points through the 2028 performance period. The College applauds the agency for not proposing to increase the threshold for the 2026 performance period.
2026 final score estimates
CMS is estimating that the median final MIPS score for 2026 will be 89.47, with 84.04% of eligible clinicians receiving a positive payment adjustment, 4.03% of eligible clinicians receiving a neutral payment adjustment, and 11.92% of eligible clinicians receiving a negative payment adjustment. However, solo practitioners and small practices will continue to receive the most penalties:
| Estimated median final score | 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
CMS is proposing to remove the following quality measures from the Allergy/Immunology Specialty Measure Set beginning in 2026:
- Screening for Social Drivers of Health: Percent of patients 18 years and older screened for food insecurity, housing instability, transportation needs, utility difficulties, and interpersonal safety.
- Connection to Community Service Provider: Percent of patients 18 years or older who screen positive for one or more of the following health related social needs (HRSNs): food insecurity, housing instability, transportation needs, utility help needs, or interpersonal safety; and had contact with a Community Service Provider (CSP) for at least one of their HRSNs within 60 days after screening.
- Adult COVID-19 Vaccination Status: Percentage of patients aged 18 years and older seen for a visit during the performance period that are up to date on their COVID-19 vaccinations as defined by CDC recommendations on current vaccination.
Accordingly, for 2026, the proposed Allergy/Immunology Specialty Measure Set would include 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
CMS proposes to update candidate event and attribution rules for the TPCC measure beginning in 2026. The TPCC measure is a population-based cost measure that evaluates a patient’s overall cost of care. CMS is proposing to exclude events initiated by an advanced care practitioner if all other non-advanced care practitioners in their group are excluded based on specialty exclusion criteria, and to require second candidate events to be an evaluation and management (E/M) or other primary care service.
PI performance category: New measure suppression policy
CMS has recognized the need for greater flexibility in how measures are used to calculate scores and otherwise determine whether MIPS-eligible clinicians meet the definition of a meaningful EHR-user under the PI performance category. Accordingly, beginning in 2026, CMS is proposing a new measure suppression policy. The policy would provide CMS with the flexibility to suppress—not score— a measure for circumstances outside the control of the MIPS eligible clinician. In determining whether circumstances warrant suppression of a measure, CMS will consider:
- 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 circumstances affecting the measure such that calculating the measure score would lead to misleading or inaccurate results
- Out-of-date or conflicting technical standards
- Technical or operational capacity of required partners
- Other factors as determined by CMS.
While the measure would not be scored, it would still be required to be reported.
In accordance with the new measure suppression policy, CMS proposes to suppress the Electronic Case Reporting measure. Although MIPS participants must still report on the measure, the measure would not be scored for the 2025 performance period. CMS reasoned that because the CDC has halted the onboarding of new health care organizations for electronic case reporting, pausing the Electronic Case Reporting measure will give CMS time to address related issues.
MIPS Value Pathways (MVPs)
CMS has established a new reporting option that may eventually replace the existing MIPS program. This reporting option—MVPs—includes a subset of measures and activities that are related to a particular specialty or medical condition. CMS has not yet confirmed when the traditional MIPS program will end, and at which point MVPs would become mandatory. However, CMS anticipates that it may be ready to fully transition to MVPs by the 2029 performance period. The College has advocated against sunsetting the traditional MIPS program and transitioning to MVP reporting.
To date, CMS has not established an allergy-specific MVP. In the 2025 QPP final rule, CMS established the Pulmonology Care MVP beginning with the 2025 performance period. However, that MVP does not offer sufficient reporting options for allergists. The College will continue to advocate for the most appropriate reporting options for allergists under the MVP program.
More information about the 2026 QPP proposed rule can be found in CMS’ 2026 Quality Payment Program Proposed Rule Fact Sheet and Policy Comparison Table (PDF).
We will submit comments to CMS and continue to advocate for allergists and their patients.
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS
