MIPS readiness checklist for practices

Before January 1, 2026, practices should establish the foundation for MIPS reporting. This includes eligibility review, reporting pathway selection, measure planning, EHR readiness, role assignment, and documentation standards.

• Verify 2026 MIPS eligibility for each applicable clinician and TIN/NPI combination
• Confirm whether the clinician or group is required to participate, opt-in eligible, voluntarily reporting, excluded, or participating through an Advanced APM pathway
• Review the 2026 low-volume threshold: more than $90,000 in Medicare Part B covered professional services, more than 200 Medicare Part B patients, and more than 200 covered professional services
• Confirm whether reporting will be individual, group, subgroup, virtual group, or APM Entity
• Decide whether Traditional MIPS, MVP, APP, or another applicable pathway will be reviewed
• Review the 2026 standard category weights: Quality 30%, Cost 30%, Improvement Activities 15%, and Promoting Interoperability 25%
• Review the 2026 performance threshold of 75 points
• Select quality measures that match specialty, patient population, denominator volume, and documentation workflows
• Confirm whether the practice needs 6 Traditional MIPS quality measures or 4 MVP quality measures from the selected MVP
• Confirm each selected quality measure can meet 75% data completeness
• Review whether Promoting Interoperability applies, may be reweighted, or requires a hardship exception review
• Confirm CEHRT status and EHR reporting capability before the performance year begins
• Assign internal ownership for eligibility, Quality, Improvement Activities, Promoting Interoperability, Cost awareness, and submission preparation

Eligibility should not be assumed based on prior-year participation. A clinician may have different eligibility status under different TIN/NPI combinations, and final eligibility should be verified through official QPP resources.

Once the 2026 performance year begins, the focus should shift from planning to operational setup. The goal is to make sure documentation, EHR capture, denominator tracking, and performance monitoring are working before too much of the year has passed.

• Confirm that quality measure denominator events are being captured correctly from the start of the year
• Confirm numerator actions are documented in the correct structured fields or supported documentation locations
• Build a tracking workflow for denominator, numerator, exclusions, exceptions, case minimum, benchmark status, and data completeness
• Monitor 75% data completeness for each selected quality measure
• Start monthly or quarterly performance reviews instead of waiting until year-end
• Select the required number of Improvement Activities based on reporting pathway, practice size, and applicable QPP status
• Confirm that individual Improvement Activities are no longer assigned high or medium weights beginning with the 2025 performance period
• Confirm Improvement Activities documentation requirements before the 90-day activity period begins
• Review PI measure setup, exclusions, attestations, CEHRT status, and security risk analysis documentation
• Confirm who will validate EHR reports before submission preparation
• Confirm access to the selected submission pathway and responsible party

A mid-year review helps identify data gaps, documentation issues, workflow problems, and reporting pathway concerns while there is still time to correct them. This review should be more than a performance score check. It should confirm whether the practice is capturing the right patients, documenting the right actions, and meeting the right 2026 QPP requirements.

• Recheck 2026 QPP eligibility and reporting pathway assumptions
• Review whether the practice is still using the correct Traditional MIPS, MVP, APP, or other applicable pathway
• Confirm whether MVP registration is required and whether the April 1 to November 30, 2026 registration window applies
• Review quality measure denominator volume, numerator performance, exclusions, exceptions, case minimum, and benchmark availability
• Confirm each selected quality measure is still on track for 75% data completeness
• Identify providers, locations, visit types, or workflows causing missing numerator documentation
• Confirm Improvement Activities have either been completed for the required 90-day period or are scheduled with enough time remaining
• Confirm Promoting Interoperability has started or will start early enough to meet the 180 continuous day requirement
• Note that July 5, 2026 is the last day to start a 180-day PI performance period that runs through December 31, 2026
• Review whether PI reweighting, exclusions, hardship exceptions, or special status considerations may apply
• Review Cost category exposure, even though Cost is generally calculated from Medicare administrative claims
• Document mid-year findings, workflow corrections, and responsible owners

Some MIPS requirements depend on minimum performance periods. Practices should not wait until late in the year to confirm these windows.

• Quality generally runs for the full 12-month performance period from January 1 through December 31, 2026
• Improvement Activities generally require a continuous 90-day performance period unless the activity description states otherwise
• October 3, 2026 is the last day to begin a continuous 90-day Improvement Activities period that runs through December 31, 2026
• Promoting Interoperability generally requires at least 180 continuous days of CEHRT data during calendar year 2026
• July 5, 2026 is the last day to begin a 180-day PI period that runs through December 31, 2026
• Practices should validate EHR reports, PI attestations, security risk analysis documentation, and activity documentation before these windows close

If these windows are missed, the issue may not be fixable during submission preparation. That is why readiness should be monitored throughout the year.

After the 2026 performance year ends, the focus shifts to validating data, organizing documentation, confirming completeness, and preparing the final submission through the practice's selected reporting pathway.

• Confirm the QPP submission window dates for 2026 performance data
• Treat March 31, 2027 as the final submission deadline unless official QPP guidance changes
• Confirm the selected reporting pathway and reporting level before submission preparation is finalized
• Confirm whether the practice is submitting as an individual, group, subgroup, virtual group, or APM Entity
• Validate quality measure numerator, denominator, exclusions, exceptions, case minimum, benchmark status, and data completeness
• Confirm each submitted quality measure meets the 75% data completeness requirement
• Confirm Improvement Activities were completed and documented for the required continuous 90-day period
• Confirm PI reports, exclusions, required attestations, security risk analysis documentation, and CEHRT information
• Confirm whether Cost is expected to be scored or reweighted
• Confirm access to the submission platform or selected reporting pathway
• Allow enough time for review before the deadline
• Keep copies of submitted data, confirmation records, and supporting documentation

Submission is not the end of the MIPS readiness cycle. After the submission window closes, practices should retain documentation, monitor official QPP feedback, review final scores when available, and use lessons learned to improve the next performance year.

• Save submission confirmations and supporting documentation
• Monitor official QPP communications for final score and feedback release
• Review final performance feedback when it becomes available
• Compare final category results against internal expectations
• Review whether any scoring issue may require targeted review within the applicable QPP timeline
• Evaluate whether measure selection, documentation workflows, EHR configuration, or reporting pathway decisions should change for the next year
• Begin next-year eligibility review when QPP updates become available
• Document lessons learned for the next performance year