ICYMI: After years of College advocacy, CMS adopts the CPT definition of a dose for 95165. Read more about this long and hard-fought accomplishment.
On Nov. 4, 2026, CMS released the 2027 Medicare Physician Fee Schedule/Quality Payment Program (QPP) final rule, which governs the Merit-based Incentive Payment System (MIPS) program and its transition to MIPS Value Pathways (MVPs). This article summarizes this key provision of the final rule and its impact on allergy practices. Other provisions of the 2027 Medicare Physician Fee Schedule final rule will be covered in subsequent issues of College Insider.
Performance threshold
The performance threshold will remain at 75 points in 2027. This means allergists must earn 75 MIPS points in 2027 to avoid a negative payment adjustment. A clinician’s final MIPS score is compared to the “performance threshold” to calculate the clinician’s MIPS payment adjustment:
(1) Positive adjustment, if the final score exceeds the performance threshold
(2) Neutral adjustment, if the final score meets the performance threshold
(3) Negative adjustment, if the final score is below the performance threshold
| Your 2027 (and 2028) Final Score | Payment Impact for MIPS Eligible Clinicians for the 2029 (and 2030) MIPS Payment Year |
|---|---|
| 0.00 – 18.75 points | -9% payment adjustment |
| 18.76 – 74.99 points | Negative payment adjustment (between -9% and 0%) |
| 75.00 points (Performance threshold – 75.00 points) | Neutral payment adjustment (0%) |
| 75.01 – 100.00 points | Positive payment adjustment (scaling factor applied to meet statutory budget neutrality requirements) |
- ACAAI and its Advocacy Council supported CMS’s decision not to increase the performance threshold for the 2027 performance period.
Data completeness criteria
CMS will maintain the data completeness threshold at 75% for 2027. Practices must submit quality data for at least 75% of eligible cases for each reported measure.
- ACAAI and its Advocacy Council supported maintaining the data completeness threshold at 75% for the 2027 performance period.
Removal of quality measure
Beginning in the 2027 performance period, CMS will remove Quality Measure #332, which evaluates whether amoxicillin, with or without clavulanate, is prescribed as first-line treatment for acute bacterial sinusitis.
- ACAAI and its Advocacy Council respectfully disagreed and urged CMS to retain Quality Measure #332, as the measure is distinct from Quality Measure #331 and relevant to quality reporting for allergists.
Allergy/Immunology Specialty Measure Set
For the 2027 performance period, the Allergy/Immunology Specialty Measure Set will include the following quality measures:
- Optimal Asthma Control
- Adult Sinusitis: Antibiotic Prescribed for Acute Viral Sinusitis (Overuse)
- Adult Immunization Status
- Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
- Closing the Referral Loop: Receipt of Specialist Report
- Documentation of Current Medications in the Medical Record
- Use of High-Risk Medications in Older Adults
- Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented
- Gains in Patient Activation Measure (PAM®) Scores at 12 Months
- HIV Viral Suppression
- HIV Annual Retention in Care
Requirement to report an outcome or high priority measure
Beginning with the 2027 performance period, CMS will remove the current quality measure data submission requirement of one outcome measure (or, if an outcome measure is not available, one high priority measure) for traditional MIPS and MVPs.
- ACAAI and its Advocacy Council supported the removal of the requirement.
Sunsetting traditional MIPS
CMS will extend traditional MIPS through 2030 and will require MVP reporting beginning in 2031 for clinicians who do not participate in a MIPS Alternative Payment Model (APM).
- ACAAI and its Advocacy Council have advocated against sunsetting the traditional MIPS program and transitioning to mandatory MVP reporting. To date, CMS has not established an allergy-specific MVP.
MVP Reporting for Allergists
CMS declined the joint ACAAI and AAAAI request to create an allergy-specific MVP and did not accept our requested modifications to the Pulmonology Care MVP or Quality Care for the Treatment of Ear, Nose, and Throat Disorders (ENT) MVP. As a result, there are currently no appropriate MVP reporting options for allergy/immunology.
The College has repeatedly expressed concerns to CMS regarding the lack of an applicable MVP for allergy/immunology. ACAAI will continue to advocate for the most appropriate reporting options for allergists under the MVP program.
Requirement to report a MIPS core measure
For traditional MIPS, beginning in the 2027 performance period, clinicians must report at least six quality measures, including at least one core measure. For MVPs, clinicians must report, if applicable, four quality measures, including one core measure available in the MVP.
If a clinician does not have an available and applicable MIPS core measure, they must attest during the data submission period that a core measure is not available and applicable for them to report. According to CMS, “measures that are available and applicable would be determined by the alignment of the measure with the clinician’s case-mix, scope of care, and ability to implement.” Instead of reporting a core measure, the clinician would be required to choose another quality measure.
CMS will assign zero measure achievement points for one quality measure if clinicians reporting traditional MIPS or MVP do not submit a MIPS core measure and do not attest during data submission that they do not have an available and applicable MIPS core measure.
- ACAAI and its Advocacy Council urged CMS not to finalize the core measure reporting requirement.
Small practices are exempt from the MIPS core measure requirement and would not need to submit an attestation. To clarify, for traditional MIPS, clinicians in small practices must still submit data on at least six measures, if applicable. For MVPs, clinicians in small practices must still report, if applicable, at least four quality measures included in the MVP.
- ACAAI and its Advocacy Council supported the small practices exemption in the event that CMS moved forward with this policy.
Currently, CMS caps scoring for topped out measures at seven measure achievement points in the second consecutive year that CMS identifies the measure benchmark as “topped out.” Under the final rule, core measures will not be subject to the seven-point cap. Instead, they will be scored according to the defined topped out measure benchmark (with a 10-point maximum).
- ACAAI and its Advocacy Council supported this policy in the event that CMS moved forward with the core measure requirement.
Automatic extreme and uncontrollable circumstances (EUC) reweighting
Currently, performance category weights may be redistributed to another performance category(ies) in circumstances where clinicians are subject to, or located in an area affected by, an EUC (e.g., FEMA-designated major disaster). CMS determines if a clinician is located in an area affected by an EUC based on the practice location address listed in the Provider Enrollment, Chain and Ownership System (PECOS). Under the final rule, beginning with the 2027 performance period, the agency will use whatever data is most current and reliable to determine if a clinician is located in an EUC area.
- ACAAI and its Advocacy Council supported this change. Use of multiple data sources will increase the ability of the EUC exception to accurately identify the clinicians that qualify for the exception due to location-based circumstances that disrupt their ability to participate in quality reporting.
Reweighting in cases where data isn’t submitted by a third-party intermediary
Beginning with the 2025 performance period, clinicians will be able to submit reweighting requests on or before Dec. 31 due to scenarios where a third-party intermediary did not submit data on their behalf in accordance with the applicable data submission deadlines. This is an extension from Nov. 1 to Dec. 31 of the year preceding the relevant MIPS payment year.
Promoting Interoperability
CMS finalized the following changes, organized by the year in which they apply:
2026 performance period
- Practices no longer need to submit the required ONC Direct Review attestation or the optional ONC-ACB Surveillance attestation. These attestations should not be included with 2026 data submissions.
2027 performance period
- The Security Risk Analysis measure is removed.
- The Electronic Prior Authorization measure becomes optional and can earn bonus points.
2028 performance period
- The Electronic Prior Authorization measure becomes required.
- A new Electronic Prior Authorization for Prescription Drugs measure takes effect.
The Advocacy Council – ADVOCATING FOR ALLERGISTS AND THEIR PATIENTS.
