CMS wants to retire traditional MIPS, and the agency's 2027 Quality Payment Program proposals carry signals no Medicare Advantage organization should ignore. Our team attended the July 29 CMS webinar on the proposed policies, released in the calendar year 2027 Physician Fee Schedule proposed rule, and these are our takeaways for MA. The rule applies to Traditional Medicare Part B clinicians, but three themes, digital quality measurement, prior authorization automation, and measure alignment, will shape how MA plans and their provider networks work together. Comments are due September 14.
What CMS proposed
The rule accelerates the shift from traditional MIPS to MIPS Value Pathways, or MVPs. CMS proposes to sunset traditional MIPS after the 2028 performance year. Beginning in 2029, MVPs become the sole MIPS reporting option for clinicians outside Advanced Alternative Payment Models. Three new MVPs covering diabetes, hypertension, and hospitalist care would bring the total to 30 for 2027.
CMS also proposes a new MIPS core measure requirement. Clinicians, excluding small practices, would report at least one core measure, defined as a measure found in both MVPs and traditional MIPS. An unreported core measure scores zero points.
On the technology side, CMS proposes an electronic prior authorization measure in the Promoting Interoperability category. The measure starts as a 10-point bonus in 2027 and becomes required in 2028. A companion measure for prescription drugs would begin in 2028. CMS also issued a request for information on the transition timeline for FHIR-based digital quality reporting.
The rule updates Qualifying APM Participant policy as well. QP determinations would apply at the TIN-NPI level rather than the NPI level. And thresholds whipsaw. Under the Consolidated Appropriations Act of 2026, the payment amount threshold drops to 50 percent and the patient count threshold to 35 percent for performance year 2026, then both snap back to 75 percent and 50 percent in 2027.
Why MA plans should pay attention
QPP does not regulate MA. The signals still matter.
Electronic prior authorization is the clearest one. The proposed MIPS measure is the provider-side complement to the Interoperability and Prior Authorization final rule (CMS-0057-F), which requires MA plans to stand up FHIR prior authorization APIs by January 2027. Once providers earn MIPS points for submitting requests electronically, expect volume through those APIs to climb and tolerance for fax and portal workflows to fall. Your endpoints, response times, and payer-side automation need to be production ready.
The FHIR reporting RFI confirms the agency's direction toward digital quality measurement across programs, including where Stars is headed. Investments in FHIR-based data exchange will pay off on both books of business.
Measure alignment is the third signal. The new hypertension and diabetes MVPs mirror Stars measures such as controlling blood pressure and HbA1c control, and the core measure concept pushes toward a Universal Foundation-style common set. Plans with value-based contracts have an opening to align contract measures with MVP core measures, reduce provider abrasion, and let network clinicians run one quality workflow across both books of business.
Sunsetting traditional MIPS plus first-year public reporting of MVP data also means richer, more comparable clinician-level performance data on Care Compare, a useful input for network design, tiering, and value-based partner selection.
What provider organizations face
Groups with mixed MA and fee-for-service panels have decisions to make now. Traditional MIPS ends after 2028, so groups need to select MVPs and build reporting infrastructure, ideally infrastructure feeding MA quality contracts too. Certified EHR technology upgrades for electronic prior authorization must land by 2028. The QP threshold snapback makes QP status much harder to achieve in performance year 2027, so organizations balancing MA risk arrangements against Medicare ACO participation should model whether their fee-for-service volume still supports QP status. Many clinicians will fall back into MIPS. TIN-NPI level determinations add another wrinkle for clinicians who split time across entities, since status will no longer follow them across TINs.
The bottom line
The thread running through the rule is convergence. CMS is standardizing measures, digitizing quality reporting, and automating prior authorization across Traditional Medicare and MA. Organizations treating these as one interoperability and quality investment rather than separate compliance exercises will come out ahead.
Questions to weigh before the September 14 comment deadline: Are your prior authorization APIs ready for the volume a scored MIPS measure will drive? Do your value-based contract measures align with the proposed MVP core measures? Does your network strategy account for the richer clinician performance data coming to Care Compare?
These conversations will continue at RISE West 2026, September 2-4 at the Manchester Grand Hyatt San Diego, where more than 500 senior Medicare Advantage leaders will gather days before the comment window closes.