CMS’s 2026 Proposed Rule marks a decisive turn in the nation’s shift toward value-based care with implications for reimbursement, reporting strategy, and how providers define success in Medicare. The most headline-worthy change is arguably the introduction of dual conversion factors that directly reward participation in the Merit-Based Incentive Payment System (MIPS).

In addition to payment updates, CMS is proposing wide-reaching changes across MIPS, MIPS Value Pathways (MVPs), the Medicare Shared Savings Program (MSSP), and the Alternative Payment Model (APM) portfolio.

Here’s what you need to know.

CMS Proposes Dual Conversion Factors For the first time, CMS proposes two separate conversion factors for physician payment under the Medicare Physician Fee Schedule:

• $33.42 for the non-QP conversion factor (+3.3% from the current conversion factor of $32.35)
• $33.59 for the QP conversion factor (+3.8% from the current conversion factor of $32.25)

While the difference may seem modest, it represents the strategic signal that clinicians who participate in MIPS or APMs will earn higher reimbursement than those who don’t.

This proposed increase in the conversion factor could result in thousands of additional revenues. For organizations on the fence about quality reporting, this change makes the incentive for participation far more tangible.

Key Updates to MIPS 2026 Alongside the fee schedule proposal, CMS released major updates to the Quality Payment Program (QPP) that will reshape the MIPS experience in 2026 and beyond.

Here are the proposed changes:

• Six new MVPs proposed, bringing the total to 27
• Mandatory subgroup reporting for clinicians who elect MVPs
• Specialty self-attestation instead of CMS validation for subgroup composition
• Exemption for small multi-specialty groups (≤15 clinicians) from mandatory subgrouping
• Performance threshold remains at 75 points through 2028
• New cost measures to be calculated (but not scored) for a two-year feedback window
• Measure 487 (“Screening for Social Drivers of Health”) proposed for removal
• Health Equity Adjustment to be discontinued starting with 2025 performance year
• New web-based CAHPS survey option proposed for MIPS

In other words, CMS is doubling down on data granularity, provider-level accountability, and flexibility for smaller groups, while quietly removing some of the more controversial or administratively burdensome measures at the same time.

MVP Growth and Strategic Alignment With the MVP framework gaining traction, the 2026 proposal accelerates its evolution:

• MVPs will require subgroup reporting where elected
• Groups must attest to their specialty composition
• CMS won’t validate that specialty (placing responsibility on the group)

However, small groups are shielded from the added burden. Here’s a strategic tip: Start preparing for MVP reporting today. The sooner you align your performance strategy with MVP logic, the more confident and consistent your submissions will be once subgrouping becomes the norm.

What’s New in MSSP & APMs Changes to the Medicare Shared Savings Program (MSSP) and APM frameworks are also on deck.

• ACOs may have fewer years in one-sided risk arrangements
• More flexibility around the 5,000 beneficiary attribution target
• A New CMMI test model: a five-year Ambulatory Specialty APM for managing high-cost chronic conditions

Why is this important? CMS continues to push more organizations toward two-sided risk, while testing specialty-based APMs that could redefine value-based contracting in the future.

Working with A Reporting Strategy Partner This 2026 proposal reinforces a message we’ve been sharing with clients for years: proactive reporting is about compliance, performance, and maximizing positive payment adjustments.

Working with Quantician Means:

• Tailored measure selection across MIPS and MVPs
• Turnkey MVP subgroup and specialty strategy
• Expert navigation of MSSP, APP, and APM pathways
• Full-service submission and audit-ready documentation
• Real-time dashboards to track performance year-round

The Bottom Line: Act Now, Succeed Later The 2026 proposed rule is a call to action. For practices still operating in a reactive, fee-for-service world, this dual-conversion structure is a wake-up call. For those already aligned with MIPS or APMs, it’s a chance to sharpen your strategy and capture the financial and clinical upside.

Get ahead now. Partner with Quantician to ensure your organization is ready to perform at the highest possible level.