August Newsletter
Updates from CMS
2025 MIPS Final Scores and Targeted Review Timeline
CMS anticipates releasing final MIPS scores for the 2025 performance year in late September 2026. Once final scores are published, AffordableQR will reach out and let you know your results. When Scores are released, the Targeted Review period will open. If your practice will benefit from a targeted review, AffordableQR is here to help and will submit a request to review your final score.
Key dates to remember:
- 2025 MIPS Final Scores expected: Late September 2026
- Targeted Review Period Opens: Upon release of final scores
- 2027 MIPS Payment Adjustments Released: Approximately one month after final scores are published
- Targeted Review Deadline: 30 days after payment adjustments are released
2027 Physician Fee Schedule Proposed Rule Released
CMS has released the Calendar Year (CY) 2027 Medicare Physician Fee Schedule (PFS) Proposed Rule, which includes significant proposed changes to both the Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs).
CMS is proposing several notable changes, including:
- Sun setting traditional MIPS reporting after the 2028 performance year (this means that everyone will be required to report using an MVP)
- Introducing three new MVPs beginning in the 2027 performance year:
- Diabetic Disease MVP
- Hypertension MVP
- Hospitalist MVP
- Modifying all 27 previously finalized MVPs
- Replacing the current outcome/high-priority measure requirement in the Quality category with a new MIPS Core Measure requirement
- Revising Promoting Interoperability reporting requirements during the 2026, 2027, and 2028 reporting periods
- Modifying the APM Performance Pathway Plus (APP Plus) quality measure set
- Introducing Medicare Electronic Clinical Quality Measures (Medicare eCQMs) as a new collection type for Accountable Care Organizations participating in the Medicare Shared Savings Program
- Applying Qualifying APM Participant (QP) and Partial QP determinations at the TIN/NPI level rather than the NPI-only level
CMS Requests for Information (RFIs)
CMS is also seeking feedback on several future policy considerations, including:
- Transitioning the Quality Payment Program to FHIR-based digital quality reporting, including timelines and implementation considerations
- Whether MVP score normalization should be introduced to improve scoring fairness across MVPs
- Potential alternatives and improvements to the current star rating assignment methodology for administrative claims measures
Submit Comments on the CY 2027 PFS Proposed Rule by September 14, 2026
Stakeholder feedback is a critical part of the rulemaking process. CMS is accepting public comments on the CY 2027 Medicare Physician Fee Schedule Proposed Rule through September 14, 2026.
When submitting comments, reference:
File Code: CMS-1848-P
Ways to Submit Comments
Electronically
- Submit comments through https://www.regulations.gov
Regular Mail
- Centers for Medicare & Medicaid Services Department of Health and Human Services
Attention: CMS-1848-P P.O. Box 8016 Baltimore, MD 21244-8016
Express or Overnight Mail
- Centers for Medicare & Medicaid Services Department of Health and Human Services
Attention: CMS-1848-P Mail Stop C4-26-05 7500 Security Boulevard Baltimore, MD 21244-1850
CMS does not accept fax submissions.
Complete the CMS Experience Survey
CMS is requesting feedback regarding participant experiences with the Quality Payment Program.
Please take a few minutes to complete the survey:
🔗 Complete the CMS Experience Survey
Your feedback helps CMS evaluate current processes and guide future program improvements.
Seeing CO-237 on Your Medicare Remittance Advice?
If you are currently seeing adjustment code CO-237 on your Medicare remittance advice, your practice is experiencing a MIPS payment penalty that is being applied to eligible Medicare claims throughout 2026.
CO-237 indicates that CMS reduced your Medicare reimbursement because your 2024 MIPS final score fell below the performance threshold required to avoid a payment adjustment.
These payment reductions can be substantial, reaching up to 9% of covered Medicare Part B services.
If you are seeing this on your adjustments, please reach out so that we can help create a plan of action.
Need Help Navigating All of This?
Whether you’re monitoring your current MIPS performance, evaluating payment adjustment risks, preparing for MVP participation, or responding to CMS policy changes, AffordableQR is here to help. Our team provides ongoing education, performance monitoring, reporting support, and submission services designed to help practices maximize performance while minimizing administrative burden.
Contact us today to discuss your organization’s reporting strategy and position your practice for success in future payment years.
