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- Pathology Included in 2026 MIPS Value Pathways Candidates
On December 11, the Centers for Medicare and Medicaid Services (CMS) released its 2026 MIPS Value Pathways (MVPs) candidates for a 45-day comment period, closing on January 24. This release does not represent official proposal of the candidate MVPs for CY2026; the CMS is soliciting public feedback on these drafts in advance of potentially including them in the 2026 Medicare proposed rule. In the past, every candidate MVP released for public comment in the winter has been proposed as part of the following rulemaking cycle.
On the list is a Pathology MVP, which includes publicly-available Quality Payment Program (QPP) measures owned by the CAP, proprietary CAP quality clinical data registry (QCDR) measures, and proprietary QCDR measures from another registry - a billing company called MSN Healthcare. Based on feedback from the CAP earlier this year, the CMS modified the Improvement Activities included in the MVP.
However, the CMS declined to accept the CAP’s suggestion that additional CAP QCDR measures be added to the MVP. There are four CAP QCDR measures and four MSN QCDR measures.
The MVP candidates may be proposed in future rulemaking, but the decision to propose an MVP in rulemaking will be determined by the CMS. The CMS defines a candidate as "a draft MVP submitted to CMS for consideration in future rulemaking." Any future changes to finalized MVPs can occur through the Maintenance Process for MVPs. MVPs are voluntary. If this MVP is finalized, pathologists will have it as a reporting option in Medicare’s Quality Payment Program. By 2029, the CMS will sunset traditional MIPS in favor of MVPs, thus making MVP reporting mandatory.
The CAP will write and submit comments on the candidate Pathology MVP.