MIPS data collection and submission basics

For the 2026 performance year, MIPS data collection generally runs from January 1, 2026 through December 31, 2026. After the performance year ends, clinicians and practices generally submit applicable MIPS data during the submission window from January 2, 2027 through March 31, 2027.

Data collection should not wait until the submission window. By that time, the practice should already know which pathway it is using, which measures apply, whether quality measures meet data completeness, whether Improvement Activities are documented, whether Promoting Interoperability data was collected for the required period, and whether submission materials are ready.

• 2026 performance year: January 1 through December 31, 2026
• 2026 data submission window: generally January 2 through March 31, 2027
• Quality data is generally collected across the full 12-month performance year
• Improvement Activities generally require a continuous 90-day performance period
• Promoting Interoperability generally requires at least 180 continuous days of CEHRT data
• Cost is generally calculated from Medicare administrative claims when applicable
• Submission preparation should begin before the performance year ends

Quality data collection depends on the reporting pathway and measure collection type. For 2026 Traditional MIPS, practices generally report 6 quality measures, including 1 outcome measure or high-priority measure, or a complete specialty measure set when applicable. For 2026 MVP reporting, participants generally report 4 quality measures from the selected MVP, including 1 outcome measure or high-priority measure.

Quality data is generally collected for the full 12-month performance period from January 1 through December 31, 2026. Each reported quality measure must generally meet the 75% data completeness requirement, meaning performance data must be reported for at least 75% of denominator-eligible cases for that measure.

• Traditional MIPS generally requires 6 quality measures
• MVP reporting generally requires 4 quality measures from the selected MVP
• At least 1 outcome or high-priority measure is generally required when applicable
• Quality data is generally collected for the full 2026 calendar year
• Each selected measure should be checked against its denominator, numerator, exceptions, exclusions, and documentation requirements
• Each reported quality measure must generally meet 75% data completeness
• Practices should confirm whether measures are being collected as eCQMs, MIPS CQMs, QCDR measures, Medicare Part B claims measures, or another applicable collection type

The practice should not only track performance rate. It should also track denominator volume, numerator performance, denominator exceptions, exclusions, case minimum, benchmark availability, and data completeness.

For 2026, Improvement Activities generally require the practice to perform and document the required number of activities for a continuous 90-day period during the performance year, unless the activity description states otherwise.

Beginning with the 2025 performance period, individual improvement activities are no longer assigned high or medium weights. For Traditional MIPS, practices generally attest to 2 improvement activities. Small practices and certain clinicians generally only need 1 improvement activity. For MVP reporting, participants generally attest to 1 improvement activity from the selected MVP or attest to Patient-Centered Medical Home status when applicable.

• Improvement Activities generally require a continuous 90-day performance period
• The last continuous 90-day period in 2026 begins October 3, 2026
• Individual activities are no longer high-weighted or medium-weighted
• Traditional MIPS generally requires 2 activities
• Small practices and certain clinicians generally require 1 activity
• MVP reporting generally requires 1 activity from the selected MVP
• Documentation should show what was performed, when it was performed, who was responsible, and how the activity was maintained

Promoting Interoperability is EHR-dependent and generally requires certified electronic health record technology. For 2026, practices must generally collect data for the required PI measures for at least 180 continuous days during the calendar year, unless the category is reweighted or an applicable exception applies.

PI data should be reviewed before the performance period begins because EHR configuration, CEHRT status, measure setup, exclusions, attestations, patient access workflows, e-prescribing workflows, health information exchange, public health reporting, and security risk analysis documentation can all affect readiness.

• PI generally requires CEHRT
• PI generally requires at least 180 continuous days of data collection
• July 5, 2026 is the last day to start a 180-day PI performance period
• Required measures and attestations should be reviewed before the PI period begins
• Applicable exclusions and reweighting situations should be reviewed early
• The practice should retain supporting documentation for PI measures and attestations
• EHR reports should be validated before the submission window

The Cost category is generally calculated from Medicare administrative claims when applicable. Practices usually do not submit separate Cost category data, but Cost should still be part of readiness planning because it can materially affect the final MIPS score.

• Cost is generally claims-calculated by CMS when applicable
• Practices usually do not submit separate Cost data
• Cost measures may be broad episode-based measures or specialty-specific episode measures
• Cost may be reweighted if no applicable cost measures can be calculated
• Practices should understand which patient populations, episodes, and claims patterns may influence cost attribution
• Cost performance should be reviewed as part of the broader MIPS readiness strategy

Available submission methods depend on the reporting pathway, measure collection type, reporting level, and the practice's chosen vendor or system. Practices should confirm the applicable submission method before the performance year is too far underway.

• Traditional MIPS, MVPs, and APP may have different reporting and submission requirements
• MVP reporting requires registration during the 2026 MVP registration window from April 1 through November 30, 2026
• If using CAHPS for MIPS with an MVP, registration timing should be reviewed separately
• Quality data may be submitted through available mechanisms such as a registry, QCDR, qualified EHR, Medicare Part B claims for applicable measures, or direct submission methods when available
• Improvement Activities are generally attested through the applicable submission pathway
• Promoting Interoperability data is generally submitted with required measure data and attestations from CEHRT workflows
• Cost is generally calculated from Medicare administrative claims and is not separately submitted by the practice
• Practices should confirm submission method, reporting level, and measure collection type before data collection is too far underway

For the 2026 performance year, submission preparation should begin well before the January 2 to March 31, 2027 submission window. By the time the window opens, the practice should have selected its reporting pathway, finalized measure mapping, reviewed denominator capture, validated EHR reports, organized Improvement Activities documentation, reviewed PI documentation, and confirmed the applicable submission method.

• Confirm eligibility and reporting pathway before finalizing measures
• Confirm whether reporting will be individual, group, subgroup, virtual group, or APM Entity
• Confirm whether Traditional MIPS, MVP, or APP applies
• Validate quality measure denominators, numerators, exceptions, and exclusions
• Confirm 75% data completeness for each reported quality measure
• Organize Improvement Activities documentation for the required 90-day period
• Validate PI reports and required attestations
• Confirm the EHR's CEHRT status and CMS EHR Certification ID when applicable
• Confirm whether Cost will be scored or reweighted
• Confirm submission method and responsible party before the submission window opens

Most MIPS reporting issues happen because the practice starts data review too late or tracks performance without also tracking denominator capture, data completeness, documentation, and submission requirements.

• Denominator capture gaps: eligible encounters are not consistently flagged for selected measures
• Numerator documentation gaps: required actions are performed but not documented in the correct structured field
• Data completeness gaps: the measure has performance data but does not meet the 75% reporting requirement
• Measure specification gaps: the team does not understand denominator exclusions, denominator exceptions, or numerator logic
• EHR configuration gaps: reports are not configured before the performance period advances too far
• PI workflow gaps: CEHRT, measure setup, exclusions, attestations, or security risk analysis documentation are not ready
• Improvement Activities gaps: activities are performed but supporting documentation is incomplete
• Submission pathway gaps: the practice selects measures before confirming collection type and submission method
• Late review gaps: issues are discovered after the performance year when they are harder to correct

A strong 2026 workflow should include monthly or quarterly data review, denominator validation, documentation feedback, EHR report checks, and a submission readiness review before the performance year ends.