MIPS reporting deadline guide (2027)
The 2026 MIPS performance year submission window is open. Here is what to submit, common errors that cost you money, and how the 2028 payment adjustments work.
The submission window
The 2026 MIPS performance year data submission window opens in January 2027 and closes March 31, 2027 under the CMS Quality Payment Program, governed by the CY2026 QPP Final Rule (finalized as part of the CY2026 PFS Final Rule, CMS-1832-F). If you miss this deadline, you automatically receive the maximum negative payment adjustment on your 2028 Medicare claims. For most eligible clinicians, that is a 9% cut.
There is no extension. There is no grace period. CMS does not send reminders. If you are a MIPS-eligible clinician or group, this deadline is one of the most financially consequential dates on your calendar.
What to submit
MIPS has four performance categories: Quality (30% weight), Promoting Interoperability (25%), Improvement Activities (15%), and Cost (30%). Cost is calculated by CMS from your claims data, so you do not submit anything for that category. See the QPP MIPS Reporting Options page for the full list of submission pathways (traditional MIPS, MVPs, and APM Performance Pathway).
For Quality, submit data on at least six measures including one outcome measure. For Promoting Interoperability, submit your EHR-generated numerator and denominator data. For Improvement Activities, attest to at least two high-weight or four medium-weight activities you completed during the performance year.
- Quality: 6+ measures including 1 outcome measure (30% of score)
- Promoting Interoperability: EHR-generated data (25% of score)
- Improvement Activities: 2 high-weight or 4 medium-weight activities (15% of score)
- Cost: Calculated by CMS from claims, no submission needed (30% of score)
Common last-minute errors
The most expensive error is submitting for the wrong TIN/NPI combination. If your practice has changed billing entities, added providers, or restructured, verify that you are submitting under the correct identifiers. A submission under the wrong TIN means your actual TIN has zero data, which triggers the maximum penalty.
Other common errors include selecting measures where your denominator is too small (minimum 20 patients for most measures), failing to include an outcome measure, and not meeting the full 12-month reporting period requirement.
Test your submission before the deadline. CMS provides a feedback tool that validates your data before final submission. Use it. Fixing errors after March 31 is not possible through normal channels.
How to check your score
After you submit, CMS processes your data and provides a preliminary score through the QPP portal, typically 4-6 weeks after submission. Log in to qpp.cms.gov and review your score across all four categories.
If your preliminary score looks lower than expected, review the feedback report for specific measures where you lost points. Some issues can be addressed through a targeted review request, but the window is narrow.
The appeal process
If you believe your score contains errors, CMS offers a targeted review process. You have 60 days from the posting of your final score to request a review. This is not a general appeal; you must identify specific data errors or processing mistakes.
Common successful appeals include cases where CMS attributed claims to the wrong provider, where data submission was confirmed by your registry but not reflected in CMS systems, or where a hardship exemption was approved but not applied to your score.
2028 payment adjustment timeline
Your 2026 performance year score determines your 2028 Medicare payment adjustment. Scores below the performance threshold receive a negative adjustment (up to -9%). Scores above the threshold receive a positive adjustment. Exceptional performers may receive an additional bonus from the exceptional performance pool.
The adjustments apply to all Medicare Part B claims from January 1, 2028 through December 31, 2028. For a practice billing $500,000 in Medicare Part B, the difference between the maximum penalty and a positive adjustment is $45,000-$90,000 in a single year.
What to do now
Verify your TIN/NPI combination in the <a href="https://qpp.cms.gov" target="_blank" rel="noopener noreferrer">QPP portal</a> and confirm it matches your current billing setup.
Confirm you have at least six quality measures with adequate patient denominators (minimum 20) including one outcome measure.
Complete your Promoting Interoperability data export from your EHR and validate the numerators and denominators.
Attest to your Improvement Activities and verify you meet the minimum threshold (2 high-weight or 4 medium-weight).
Submit your data through the QPP portal or your qualified registry before March 31 and save the confirmation receipt.
Set a reminder to check your preliminary score in the QPP portal 4-6 weeks after submission.
Who this affects
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