MIPS After 2028: What the Proposed Changes Mean for Hospitalist Groups

CMS has proposed ending traditional MIPS after the 2028 performance period. Starting in 2029, MIPS Value Pathways (MVPs) would be the only MIPS reporting option for clinicians who are not in an Advanced Alternative Payment Model (APM). For hospitalist groups that still report traditional MIPS, that leaves two performance years to choose an MVP, test it and confirm it works before it becomes mandatory. 

These changes are part of the CY 2027 Physician Fee Schedule proposed rule. Comments closed September 14, 2026, and CMS expects the final rule later this fall. Until then, the dates below are CMS’s stated direction, not final policy. Nothing changes for the 2026 performance year. 

A pathway built for hospital medicine 

For 2027, CMS proposes three new MVPs: Diabetic Disease, Hypertension and Hospitalist. The Hospitalist MVP would be the first built specifically around hospital medicine, centered on care coordination and the cost and quality of care delivered to hospitalized patients. 

Today, hospitalists have no dedicated MVP. Groups either report traditional MIPS using the Hospital Medicine specialty measure set, which includes four quality measures (heart failure ACE inhibitor/ARB/ARNI therapy, heart failure beta-blocker therapy, advance care planning and documentation of current medications), or evaluate MVPs designed for other specialties and look for the closest fit. 

The quality measures, cost measures and improvement activities inside the Hospitalist MVP have not been detailed in public summaries. They will appear in the final rule and the CMS Quality Payment Program resource library. Measure sets can shift between proposed and final, so pay attention to any changes that come out later this year. 

What an MVP changes about reporting 

An MVP uses the same four categories as traditional MIPS. The difference is selection. Under traditional MIPS, a group chooses six quality measures from an inventory of roughly 190 and attests to improvement activities from a broad menu. An MVP replaces that with a short, specialty-matched set, typically four quality measures and one improvement activity, plus a population health measure CMS calculates from claims. Cost is still calculated from claims, but limited to the cost measures relevant to that MVP. 

A fixed set of about four measures is simpler to build into charge capture and coding workflows than a pick list drawn from nearly 200. It also leaves less room to choose the measures your clinicians already document well. 

Subgroup reporting depends on how the group bills. A single-specialty hospitalist group under its own Taxpayer Identification Number (TIN) can report an MVP as a whole group. A hospitalist program that shares a TIN with other specialties, which is common in hospital-employed models, will need to decide on a subgroup structure. CMS now lets groups self-attest their specialty composition at MVP registration, which makes that decision easier to document. Someone still has to own it. 

The 2027 rule that applies either way 

The more immediate change is the proposed MIPS core measure requirement. CMS would designate 78 quality measures as core measures. Whether a group reports traditional MIPS or an MVP, at least one of its required quality measures must come from that list. A group that does not include one would receive zero out of 10 points for one of its required measures. Small practices are exempt, and clinicians with no applicable core measure can attest out. If this is finalized, measure-selection logic needs a firm rule that a core measure is always in the reported set. 

Other proposed 2027 changes to track: 

• The performance threshold stays at 75 points through the 2028 performance year. 

• The quality measure inventory drops from 190 to 180, with 20 measures removed and 43 substantively updated. Check whether any of the four Hospital Medicine measures are on the removal list once final specifications publish. 

• Improvement Activities adds six options, including activities on AI use, nutrition, advance care planning and diagnostic performance, and removes 11. 

• In Promoting Interoperability, Electronic Prior Authorization becomes optional in 2027 and Security Risk Analysis is removed. This category is voluntary for most hospital-based clinicians but applies to hospitalists billing under a group TIN that includes ambulatory clinicians. 

How to use 2027 and 2028 

The practical step for 2027 is to shadow-report: submit one option and track the other internally. Running traditional MIPS and the Hospitalist MVP side by side shows which produces the better score and which places less burden on hospitalists and coding staff. 

A planning list for hospitalist groups: 

1. Confirm how your group bills: its own TIN or a shared multispecialty TIN. 

1. Review the Hospitalist MVP measure set as soon as the final rule publishes. 

1. Check the four Hospital Medicine measures against the 2027 removal list. 

1. Build the core measure requirement into measure selection. 

1. Assign an owner for the subgroup decision, if one applies. 

Technical setup is only part of the work. A fixed measure set changes what hospitalists document and what coders look for on each encounter. Groups that start adjusting those workflows in 2027 will have two full performance years of practice before MVP reporting is required. 

Complete encounter data comes first 

Every quality measure depends on the same encounter data that drives the revenue cycle. When charges are entered days late, incomplete or reconstructed from memory, the documentation behind those encounters is weaker too. medaptus Charge Pro captures hospitalist charges at the point of care, so the encounter record is complete before it reaches coding and reporting. See how physician groups use it in our case studies, and talk with medaptus about tightening charge capture before your group moves to an MVP.