MIPS Reporting for Small Practices 2026: The No-Jargon Guide

What MIPS Is and Who Must Report

MIPS—the Merit-based Incentive Payment System—is CMS's quality reporting framework under the Quality Payment Program (QPP). It determines payment adjustments to Medicare Part B fee-for-service reimbursement: practices that score above the performance threshold get a positive payment adjustment; those below it face penalties.

You are subject to MIPS if:

• You bill Medicare Part B for covered professional services
• You are a physician, PA, NP, CNS, or CRNA
• You exceed the low-volume threshold (currently: >$90,000 in Medicare Part B allowed charges AND >200 Medicare patients AND >200 covered professional services in the determination period)

If you fall below any one of those three thresholds, you are exempt from MIPS reporting for the year. This exemption is a meaningful relief valve for solo physicians with small Medicare panels—check your status annually via the QPP portal (qpp.cms.gov) using your NPI.

2026 Performance Categories and Weights

MIPS 2026 Performance Category Weights

Category	Weight	Maximum Points
Quality	30%	30 points
Promoting Interoperability (PI)	25%	25 points
Improvement Activities (IA)	15%	15 points
Cost	30%	30 points
Total	100%	100 points

Note: Small practices (fewer than 15 clinicians) may receive bonus points under the small practice designation. Reweighting may apply if you cannot report PI due to a CEHRT hardship exception.

The Performance Threshold: What You Need to Avoid a Penalty

CMS sets the performance threshold annually. For 2026 performance year (affecting 2028 payments), the threshold is 75 points. Practices scoring:

• Below 1 point: Maximum negative adjustment (-9% in 2026)
• 1–74 points: Negative adjustment (scaled from maximum to 0)
• 75 points: Neutral (no adjustment)
• 76–100 points: Positive adjustment (scaled)
• Exceptional performance (above 89 points): Additional bonus from the exceptional performance pool

The maximum positive adjustment is budget-neutral against penalties collected—it varies year to year. In recent years, top performers have received +1.5% to +2.0% positive adjustments.

Quality Category: Choosing Your Six Measures

You must report at least 6 quality measures, including at least one outcome measure or high-priority measure. You report on these measures for the full 12-month performance period (or at least 12 months for registry-based submission).

For a primary care practice, the lowest-burden measures with the highest likely performance scores:

1. Measure #001: Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%): This is an inverse measure—your score improves when fewer of your diabetic patients have A1c >9%. Achievable for any practice managing diabetes well.
2. Measure #236: Controlling High Blood Pressure: Percentage of patients 18–85 with diagnosed hypertension whose most recent BP <140/90. Highly achievable with good BP management.
3. Measure #317: Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented: Documents BP screening at eligible visits. Straightforward to report.
4. Measure #134: Preventive Care and Screening: Screening for Depression and Follow-Up Plan: PHQ-2 or PHQ-9 screener at eligible visits, with follow-up plan for positives.
5. Measure #321: CAHPS for MIPS Survey: Patient experience survey conducted via a CMS-approved vendor. Can substitute for 1 quality measure and earns additional bonus points if administered.
6. Measure #112: Breast Cancer Screening: Mammography rate for eligible female patients. Works well for practices with a high proportion of female patients 50–74.

Promoting Interoperability: The EHR Category

PI requires a certified EHR technology (CEHRT) and specific electronic health information exchange activities. Key objectives and minimum reporting thresholds:

• Security Risk Analysis: Required; must be completed in the performance year. Not a numeric measure—binary yes/no.
• e-Prescribing: Report at least 1 eligible electronic prescription. Most modern EMRs accomplish this automatically.
• Query of Prescription Drug Monitoring Program (PDMP): Required for practices prescribing controlled substances; minimum threshold applies.
• Support Electronic Referral Loops by Sending Health Information: Percentage of patient transitions where you send electronic health information.
• Provide Patients Electronic Access to Their Health Information: Percentage of patients who can access their records via a patient portal.

Small practices (1–15 eligible clinicians) can apply for a PI hardship exception if your CEHRT does not support PI measures or you face a significant hardship (e.g., extreme weather, security breach). The exception reweights PI to 0% and redistributes to Quality.

Improvement Activities: The Easiest 15 Points

IA is the most achievable MIPS category. You must attest to completing at least 2 medium-weight activities (10 points each) or 1 high-weight activity (20 points) for at least 90 continuous days during the performance year. Maximum score is 40 points, capped at 15 MIPS points.

High-value activities for primary care practices:

• IA_BE_14: Engage patients and families to guide improvement in the organization (High weight): Document patient feedback processes and use them to improve care.
• IA_CC_1: Implementation of use of specialist reports in primary care (Medium weight): Document that you review specialist reports and integrate findings into care plans.
• IA_PM_13: Chronic care and preventive care management for empaneled patients (Medium weight): Run proactive care gap closure programs (e.g., outreach for overdue screenings).
• IA_PSPA_7: Completion of training and receipt of approved waiver for provision of medication-assisted treatment for opioid use disorders (High weight): If you have or obtain a waiver for buprenorphine/naloxone treatment.

Cost Category: You Cannot Control It Directly

The Cost category accounts for 30% of your MIPS score and is calculated by CMS from your Medicare claims data. You do not report anything for Cost. CMS calculates your Total Per Capita Cost (TPCC) and/or Medicare Spending Per Beneficiary (MSPB) and compares it to national and specialty peers.

What you can do: ensure your care is efficient and that patients get needed services without excess utilization (unnecessary ER visits, avoidable readmissions). Proactive chronic disease management and care gap closure directly reduce high-cost utilization and improve your Cost score over time.

The Lowest-Burden MIPS Reporting Path for a Solo Practice

1. Verify your low-volume threshold status in October (QPP portal)
2. If reporting required: select your 6 quality measures in November and configure your EMR to track them starting January 1
3. Complete your HIPAA Security Risk Analysis by March (use a documented, signed risk analysis framework)
4. Attest to 2 Improvement Activities by October 1 (at least 90 days)
5. Submit data to CMS via your CEHRT or registry by March 31 of the following year

Many EMRs support direct MIPS submission to CMS. Verify your EMR is CEHRT-certified and supports direct submission—this eliminates the need for a third-party registry.

MIPS and Your EMR

Krasyn is built on a CEHRT-certified foundation and supports MIPS quality measure tracking, PI attestation, and Improvement Activity documentation. The quality dashboard shows your real-time performance on tracked measures so you are never surprised at year-end. See the MIPS features.