Last week I got a call from a hospital that employs two practitioners in their Hospital Based Outpatient Wound Center (HOPD). The clinic manager and the hospital quality officer said that they have employed these practitioners for years, and that, “We just heard about MIPS.” I hear a lot of terrifying stories like this from practitioners and the organizations that employ them. Why is this story terrifying? The Merit Based Incentive Payment System (MIPS) in its current form (CMS kept re-naming various programs) has been in effect for NINE YEARS – since January 1, 2017 – although CMS laid out the rules for MIPS in 2016. During that time, CMS has continued to increase the potential penalties for not reporting so that in 2020, practitioners who were required to participate in MIPS and ignored it started losing up to 9% of their Medicare Part B claims. Thus, 2026 is the 6th year that practitioners could lose up to 9% of their Medicare claims under MIPS, a program that has been in place for a decade, and yet many practitioners and organizations are only just now finding this out. As boring as the topic, is, I will continue to post blogs about it to serve as a resource. CMS is also releasing more resources – most recently a newsletter for small practices.
The Quality Payment Program (QPP) Small Practices Newsletter is a monthly resource that provides small practices (15 or fewer clinicians) with program updates, upcoming QPP milestones, and resources to support their continued participation and success in QPP, including the Merit-based Incentive Payment System (MIPS). The newsletter is disseminated on the second Tuesday of each month. Sign up for newsletter emails: Centers for Medicare & Medicaid Services (CMS)
Check Out Your 2026 MIPS Eligibility:
- Enter your 10-digit National Provider Identifier (NPI) in the QPP Participation Status Tool and review your preliminary 2026 MIPS eligibility status. Your preliminary 2026 eligibility status informs whether you need to collect data this year.
- Here’s a bog post from me with an explanation about how to interpret your QPP status.
For More Information:
- Learn How MIPS Eligibility Is Determined on the QPP website and review the 2026 MIPS Eligibility and Participation User Guide (PDF, 3MB) and the 2026 Small Practice Eligibility and Participation FAQs (PDF, 517KB).
- If you’re eligible, review the 2026 Small Practices Quick Start Guide to get started selecting measures and activities. Visit the Explore MVPs page to learn more about the available MVPs for the 2026 performance period.
Resources for Small Practices from CMS:
- 2026 Part B Claims Quality Measure Reporting Quick Start Guide (PDF, 2MB), as described above, has been updated to provide detailed reporting and scoring examples for Quality ID 226.
- 2026 Quality Benchmarks User Guide with Scoring Examples (PDF, 1MB), as described earlier, has been updated to specify that for the 2026 performance period, Measure 141 (Part B claims) will receive a historical benchmark based on 2024 performance.
- 2026 MIPS Reporting Options At-A-Glance for Small Practices (PDF, 436KB) provides an overview of MIPS reporting options for small practices in the 2026 performance year.
- Small Practices Guide: Getting Started with MIPS CQM Reporting (PDF, 1MB) walks through the steps needed for small practices to complete and submit MIPS CQM measures under MIPS; this resource has been updated to include links to 2026 performance year resources.
- Small Practices Guide: Getting Started with eCQM Reporting (PDF, 970KB) walks through the steps needed for small practices to complete and submit electronic clinical quality measures (eCQMs) under MIPS; this resource has been updated to include links to 2026 performance year resources.
Additional Reading:
Here are links to blog posts with additional explanation in relation to wound care:
- The Quality Payment Program and What it Means for the Future of Wound Management & HBOT – Caroline Fife M.D. (This article is old but provides the entire history of the QPP program through the lens of wound care)
- “Do I Have To Do MIPS?” (How To Understand Your QPP Status) – Caroline Fife M.D.
- What I’d Fix About MIPS if I Were Queen – Caroline Fife M.D.
- How a Non-Pressure Ulcer Cost Measure Could Help or Hurt Your MIPS Score (and Your Medicare Payments) – Caroline Fife M.D.
- CMS Suspends 8 MIPS Improvement Activities – Caroline Fife M.D.
- MIPS Basics – Watch it on Today’s Wound Clinic – Caroline Fife M.D.
- 2023 QPP Performance Data are Out: 14.56% of Practitioners Will See a Penalty in Their 2025 Medicare Payments – Caroline Fife M.D.
- Medicare’s Quality Payment Program vs. Wound Care Practitioners – Caroline Fife M.D.
