What the expanded MVP landscape means for EHR strategy, customer confidence, and long-term readiness.

MIPS Value Pathways were introduced to address the burden of traditional MIPS measure selection. Over time, CMS has continued to expand and refine MVPs, signalling a long-term shift toward more structured, specialty-aligned reporting.

For EHRs, this matters more than it did in 2025. Not because reporting rules have suddenly changed, but because MVPs are now where measure development, cost alignment, and clinical relevance are actively taking place. Traditional MIPS still exists, but MVPs are where CMS's attention is directed.

According to CMS’s 2026 Quality Payment Program updates, six new MVPs have been added, and 21 existing MVPs have been modified, expanding specialty coverage and tightening how quality, cost, and interoperability are grouped.

This shift is structural, not cosmetic, and EHRs are going to feel that impact first.

MVPs in 2026 are More Structured by Design

MVPs have always bundled Quality, Improvement Activities, Cost, and Promoting Interoperability performance categories into a single reporting pathway, but the 2026 updates reinforce that this structure is intentional and long-term. CMS continues to organize measures by clinical groupings and episodes of care, reducing flexibility around mixing unrelated measures and increasing the importance of alignment.

This results in reduced reporting burden:

Reporting 4 Quality measures versus 6
Attesting to only 1 Improvement Activity (regardless of practice size)

This does not mean CMS has reduced scoring flexibility or added new penalties. MVPs are designed to alleviate the overall MIPS reporting burden, enabling specialties to focus on their core competencies. What it does mean is that because MVP measures are tightly aligned with the specialty, participation in an MVP leaves fewer workaround options practices can use with traditional MIPS. When fewer alternative measures exist within a pathway, data completeness and workflow accuracy matter more.

For EHRs, this is not about compliance checklists. It is about whether the EHR supports the reality of how MVPs are assembled and scored.

New MVPs Signal Where CMS is Expanding Next

The addition of new MVPs in 2026 is one of the clearest indicators of CMS priorities. Newly finalized MVPs include Diagnostic Radiology, Interventional Radiology, Neuropsychology, Pathology, Podiatry, and Vascular Surgery, among others.

These are not edge specialties. They represent high-volume, data-intensive clinical areas with complex workflows and strong cost implications. CMS is effectively saying that MVPs are now mature enough to support these use cases.

For EHRs serving these specialties, MVP readiness now becomes a key component of EHR credibility. Customers may not ask detailed regulatory questions, but they do notice when MVP participation feels harder than it should.

MVP Cost Measures Now Being Considered Earlier

In 2026, CMS finalized a two-year information-only feedback period for new cost measures included in MVPs. During this period, clinicians will receive cost performance feedback without those measures affecting final MIPS scores.

It is an early signal. Cost data is already being calculated, reviewed, and operationalized inside MVPs. By the time those measures affect scoring, CMS expects workflows and data pipelines to be in place.

For EHRs, this creates an opportunity to help customers understand cost attribution earlier when it's in the informational stage. EHRs that offer clarity instead of confusion here will build trust with their customers.

Promoting Interoperability is Not Optional

Every MVP includes a foundational layer that applies across all specialties, including population health measures and Promoting Interoperability (PI) requirements. These PI requirements remain aligned with Traditional MIPS, relying heavily on certified EHR technology and consistent data exchange.

In 2026, CMS finalized updates to:

Security risk analysis measures,
SAFER Guides expectations
Added TEFCA-based public health reporting measure (optional for bonus)

None of this is dramatic on its own. Together, they reinforce that interoperability expectations are becoming more operational and less theoretical.

If PI workflows feel fragmented or manual, MVP participation will make those gaps more visible for the providers. PI efficiency squarely rests on the EHR’s shoulders and could become the deciding factor for dissatisfied providers to switch EHRs.

Where EHRs Can Make MVP Participation Easier

Most MVP challenges are not caused by misunderstanding CMS’s rules. They are caused by friction between measure logic, workflow design, and data availability.

This is where EHRs have real influence.

Supporting MVP-aligned measure mapping
Reducing ambiguity around eligible measures
Adjusting workflow to align with MVP data capture requirements

Helping customers understand which data is already being captured versus what needs adjustment is how EHRs can enhance the MVP participation experience for providers and practices.

Did you know many MVP issues can be resolved without changing the reporting strategy at all, simply by aligning workflows earlier in the year?

Curious how that works in practice? We can walk through it with you.

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A Quiet Shift that Rewards Prepared EHRs

CMS is not forcing MVP adoption yet, but the signal is clear. MVPs are where CMS is investing time in measure development and refinement. EHRs that treat MVPs as a future task, risk playing catch-up when customers start expecting smoother participation as the stakes increase in terms of effort and penalties.

The opportunity is not to teach customers how to report. The opportunity lies in removing friction before it becomes visible.

🔶 MVP Enrollment Begins on April 1, 2026 🔶