What Is the Proposed MIPS Sunset?
As of August 2026, CMS has proposed ending traditional MIPS quality reporting after the 2028 performance period and making MIPS Value Pathways (MVPs) the primary reporting option for clinicians who do not participate in a MIPS Alternative Payment Model. The proposal appears in the CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P), published July 14, 2026, with public comments due by September 14, 2026. If finalized, the last year a family medicine practice can report through traditional MIPS will be 2028, with the final MIPS payment adjustment applied in 2030.
Timeline: Traditional MIPS would end after the 2028 performance period. MVPs become the required reporting pathway starting with the 2029 performance period. The comment deadline is September 14, 2026.
Who this affects: Every family medicine physician, nurse practitioner, and physician assistant currently reporting through traditional MIPS who is not already in an Advanced APM or reporting through the APM Performance Pathway.
What to do first: Identify whether your practice reports traditional MIPS today, review the MVP options that align with family medicine, and evaluate whether joining an ACO is a better path before the 2027 reporting year begins.
What CMS Proposed on July 14
On July 14, 2026, CMS released the CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P). Among its provisions, CMS proposes to sunset traditional MIPS beginning with the 2029 performance period. That means the 2028 performance year would be the last year clinicians can report quality measures, improvement activities, and promoting interoperability through the traditional MIPS reporting framework. After that, MIPS Value Pathways become the primary reporting option for clinicians outside of MIPS APMs.
CMS also proposes adding three new MVPs focused on diabetes, hypertension, and hospital-based care. These condition-specific pathways signal where CMS wants reporting attention directed: toward the chronic conditions that drive cost and outcomes across Medicare populations. For family medicine, the diabetes and hypertension MVPs overlap heavily with the daily patient panel.
The proposed rule is not final. Public comments are due by September 14, 2026, and CMS is expected to publish the final rule later this fall. Measure specifications and timelines could shift before anything is locked. But CMS has been signaling this move for years, and the proposal puts a firm date on what was previously an open-ended transition.
Who Does the MIPS Sunset Affect?
The proposed sunset affects every clinician currently reporting through traditional MIPS who is not already participating in an Advanced Alternative Payment Model. In family medicine, that includes physicians, nurse practitioners, physician assistants, and clinical nurse specialists who meet the MIPS eligibility threshold: more than 90,000 dollars in Medicare Part B allowed charges, more than 200 covered professional services, and care for more than 200 Medicare beneficiaries during the determination period.
Clinicians who already report through the APM Performance Pathway because they participate in a qualifying ACO or Advanced APM are not affected in the same way. Their reporting structure continues under the APM track. The sunset specifically eliminates the traditional MIPS option, which is the pathway most independent family medicine practices use today.
One question we hear constantly from practice managers is whether MIPS even matters to their bottom line. The answer is yes. MIPS payment adjustments are applied to Medicare Part B claims two years after the performance period. A practice that fails to report in 2028 would face a negative adjustment on every Medicare claim in 2030. The penalty can reach negative 9 percent of Medicare Part B payments, which for a family medicine practice billing 300,000 to 500,000 dollars in annual Medicare volume means 27,000 to 45,000 dollars at risk.
| Performance Year | Reporting Status | Payment Year |
|---|---|---|
| 2026 | Traditional MIPS and MVPs both available | 2028 |
| 2027 | Traditional MIPS and MVPs both available; new MVPs added | 2029 |
| 2028 | Last year for traditional MIPS (proposed) | 2030 |
| 2029 | MVPs only; traditional MIPS no longer available (proposed) | 2031 |
What Is a MIPS Value Pathway?
A MIPS Value Pathway is a streamlined reporting framework that organizes quality measures, improvement activities, and cost measures around a specific clinical topic or condition. Instead of selecting individual measures from the full MIPS inventory, a clinician or group picks an MVP that aligns with their specialty or patient population and reports the measures bundled inside it.
CMS launched MVPs in 2023 as an alternative to traditional MIPS, and each year since it has added new pathways and modified existing ones. For the 2027 performance period, CMS proposes adding three new MVPs for diabetes, hypertension, and hospital-based care, bringing the total to over 30 available pathways. Family medicine aligns most naturally with the existing primary care and chronic disease management MVPs, and the new diabetes and hypertension pathways map directly to the conditions family physicians manage every day.
The key difference from traditional MIPS: in an MVP, the measures are pre-selected and clinically connected, so the reporting burden is narrower and the measures are more relevant to what the clinician actually does. CMS views this as a step toward making quality reporting meaningful rather than a compliance exercise. Whether it achieves that in practice depends on the measure specifications and the reporting infrastructure the practice has in place.
What Does This Mean for Family Medicine Billing?
The billing impact of the MIPS sunset falls into three buckets: reporting workflow changes, payment adjustment risk, and the decision about whether to move into an MVP or an ACO.
Reporting workflows will change because the measure sets inside MVPs are different from what most practices currently report under traditional MIPS. A family medicine practice that has been reporting the same six quality measures for years will need to map those measures to an MVP, identify any gaps, and confirm that its EHR or registry can extract and submit the data in the required format. This is not a coding change, but it is a billing operations change, because the quality data feeds directly into whether the practice receives a positive, neutral, or negative payment adjustment.
In our experience matching providers with billing partners, the practices most at risk from this transition are mid-size family medicine groups that have been on autopilot with traditional MIPS: they report, they score above the threshold, and nobody looks at it again until next year. Those practices have not evaluated MVPs, have not assessed whether their EHR supports MVP reporting, and have not modeled what happens to their payment adjustment if they fail to transition in time.
The payment adjustment risk is real. A practice that does not report through an eligible pathway in 2029 would face the maximum negative adjustment on all Medicare Part B claims in 2031. For family medicine, where E/M codes like CPT 99213 and 99214 make up the bulk of Medicare volume, that penalty hits the highest-volume claims hardest.
The MIPS sunset means your quality reporting pathway is changing whether you are ready or not. If your practice cannot identify which MVP fits your patient panel, confirm your EHR supports the transition, or model the payment adjustment risk, a billing partner that handles MIPS reporting daily can close those gaps before the 2027 reporting year begins. Get matched with vetted family medicine billing companies, free.
How to Prepare for the MVP Transition
The transition from traditional MIPS to MVPs is not a switch you flip on January 1. It requires planning that should start now, during the comment period, so your practice is positioned before the 2027 performance year begins. These are the steps that move a family medicine practice from autopilot MIPS to MVP-ready.
1. Identify your current reporting pathway. Confirm whether your practice reports traditional MIPS as an individual, a group, or through the APM Performance Pathway. If you are already in an Advanced APM, the sunset may not change your workflow. If you report traditional MIPS, you are the target of this proposal.
2. Review the available MVPs for family medicine. CMS publishes the full list of MVPs on the QPP website. Identify which pathways align with your patient population: the primary care and chronic disease management MVPs are the natural fit, and the proposed diabetes and hypertension MVPs may also apply.
3. Map your current quality measures to an MVP. Compare the measures you currently report under traditional MIPS against the measures bundled into your target MVP. Identify any gaps where you will need to add a new measure or change a reporting method.
4. Confirm your EHR or registry supports MVP reporting. Not every EHR platform has built MVP-specific reporting workflows yet. Check with your vendor now, not in December, to confirm that measure extraction and submission will work for the MVP you select.
5. Evaluate whether an ACO is a better path. About 75 percent of primary care physicians already participate in an ACO, according to analysis cited in Medical Economics. If your practice is not in one, the MVP sunset may be the trigger to evaluate whether joining an ACO simplifies reporting and improves your payment trajectory.
6. Submit a public comment by September 14. The proposed rule is accepting comments through September 14, 2026. CMS modified a similar proposal in 2019 after significant stakeholder feedback. Your input matters.
Common Misreadings of This Proposal
Providers often come to us after reading a headline about a CMS proposed rule and drawing conclusions that do not match the actual proposal. Here are the mistakes we are already seeing with the MIPS sunset announcement.
Thinking MIPS is ending entirely. It is not. MIPS as a program continues. What ends is the traditional reporting option. MVPs are part of MIPS. The program is transitioning, not disappearing.
Assuming the sunset is final. This is a proposed rule. CMS proposed a similar transition timeline in previous years and adjusted it based on comments. The comment period closes September 14, 2026, and the final rule is expected later this fall. Nothing is locked until the final rule publishes.
Believing the transition does not affect 2027. Even though the sunset date is after the 2028 performance period, CMS is adding new MVPs and encouraging early adoption starting in 2027. Practices that wait until 2028 to evaluate MVPs will have less time to test reporting workflows and resolve EHR issues.
Ignoring the payment adjustment math. A practice that fails to report through a valid pathway faces a negative adjustment of up to 9 percent on all Medicare Part B payments. For a family medicine practice with 400,000 dollars in annual Medicare volume, that is 36,000 dollars in lost revenue applied to every E/M claim for the entire payment year.
Conflating MVPs with ACOs. An MVP is a reporting pathway inside MIPS. An ACO is a care delivery and payment model. You can report an MVP without being in an ACO. The two are related but not the same, and the right choice depends on your practice’s size, payer mix, and appetite for shared financial risk.
In-House MIPS Reporting vs. a Billing Partner
Across the billing companies we vet, the practices that handle the MIPS-to-MVP transition smoothly are the ones whose billing partner already manages quality reporting as part of the billing relationship. The partner tracks measure performance throughout the year, flags gaps before the submission deadline, and models the payment adjustment impact so the practice knows exactly where it stands.
The practices that struggle are the ones where MIPS reporting is handled by one person internally, often the practice manager, who assembles the data once a year in the fourth quarter. That workflow barely works for traditional MIPS. It will not work for MVPs, which require a tighter alignment between the clinical measures reported and the claims being submitted.
If your practice is evaluating whether to handle the MVP transition in-house or bring in a partner, our guide on how to find the right family medicine billing service covers the criteria that matter most, including whether the partner handles quality reporting alongside claims.
Frequently Asked Questions
Is traditional MIPS ending?
CMS has proposed ending traditional MIPS after the 2028 performance period. If finalized, clinicians would report through MIPS Value Pathways starting with the 2029 performance period. The proposal is in the CY 2027 PFS proposed rule, and public comments are due by September 14, 2026. MIPS as a program continues; only the traditional reporting option would be removed.
What is a MIPS Value Pathway?
A MIPS Value Pathway is a streamlined quality reporting framework that bundles quality measures, improvement activities, and cost measures around a specific clinical topic. Instead of choosing individual measures from the full MIPS inventory, clinicians select an MVP aligned with their specialty. CMS views MVPs as more clinically relevant and less burdensome than traditional MIPS reporting.
When is the MIPS sunset deadline?
If finalized, the last year for traditional MIPS reporting would be the 2028 performance period, with the final payment adjustment applied in 2030. MVPs would become the required reporting pathway starting with the 2029 performance period. The comment period on the proposed rule closes September 14, 2026.
How much is the MIPS payment penalty?
The maximum negative MIPS payment adjustment is 9 percent of all Medicare Part B payments for the applicable payment year. A family medicine practice billing 400,000 dollars in annual Medicare volume would lose up to 36,000 dollars if it fails to report through a valid pathway. The penalty applies to every Medicare Part B claim for the entire payment year.
Which MVPs apply to family medicine?
Family medicine aligns with the primary care and chronic disease management MVPs currently available. CMS proposes adding new MVPs for diabetes and hypertension in 2027, both of which map directly to conditions family physicians manage daily. The full list of available MVPs is published on the CMS Quality Payment Program website.
Can I still report traditional MIPS in 2027?
Yes. Under the proposed rule, traditional MIPS remains available through the 2028 performance period. Both traditional MIPS and MVPs would be available for 2027 and 2028 reporting. The sunset would take effect for the 2029 performance period, meaning 2029 would be the first year where only MVPs are an option.
Does the MIPS sunset affect nurse practitioners and PAs?
Yes. The MIPS sunset applies to all MIPS-eligible clinicians, including nurse practitioners, physician assistants, and clinical nurse specialists who meet the low-volume threshold. If they currently report through traditional MIPS and are not in an Advanced APM, they will need to transition to an MVP by the 2029 performance period.
Next Steps
New to E/M coding for family medicine? Start with our guide on CPT code 99213, the most frequently billed E/M code in primary care.
Evaluate your MVP options. Review the CMS QPP website for the full list of available MIPS Value Pathways and identify which one fits your practice’s patient panel.
Submit your comment. The public comment period on the CY 2027 PFS proposed rule closes September 14, 2026. Details on how to submit are in the proposed rule.
Ready to hand the transition off? Get matched with a billing company that handles MIPS reporting and MVP transition planning alongside your claims.
Traditional MIPS is on a countdown. Whether you transition to an MVP, join an ACO, or need help figuring out which path fits your practice, the planning starts now. Family Med Billers connects family medicine practices with vetted billing companies that manage quality reporting alongside claims, so the MIPS transition does not become another task on your practice manager’s plate. More than 2,000 providers matched across all 50 states, over 15 years in medical billing, and rates starting as low as 2.95 percent. Finding a match is 100 percent free for providers.
