QPP in the CY 2027 PFS final rule: traditional MIPS sunsets after CY 2030, Security Risk Analysis measure removed, electronic prior authorization measures required from CY 2028
Published November 8, 2026 · Coverage November 1–7, 2026, Pacific · Lower priority
CMS posted a Quality Payment Program (QPP) fact sheet and policy comparison table for the CY 2027 Physician Fee Schedule (PFS) final rule. CMS will sunset traditional Merit-based Incentive Payment System (MIPS) reporting after the CY 2030 performance period and require MIPS Value Pathways (MVP) reporting from CY 2031 for clinicians not in a MIPS Alternative Payment Model (APM). CMS removed the Security Risk Analysis measure for the CY 2027 performance period and made the Electronic Prior Authorization measure optional in CY 2027 and required starting in CY 2028.
Background
The fact sheet says CMS has long signaled that MVPs are the future reporting path for MIPS and that traditional MIPS would eventually no longer be a reporting option. In this final rule CMS modified its initial proposal on the sunset timeline, and it says the finalized policy allows an additional 2 years for MIPS eligible clinicians to identify the MVP most relevant to their practice.
Who this affects
MIPS eligible clinicians and groups, including hospital-employed groups; Shared Savings Program Accountable Care Organizations (ACOs).
Why it matters
Inference: quality and IT teams supporting employed groups can plan MVP selection on a 2031 timeline and start planning for electronic prior authorization measure reporting in 2028.
Required actions
- No action is due now. The fact sheet states future requirements by performance period for clinicians subject to MIPS: electronic prior authorization measures from the CY 2028 performance period, and MIPS Value Pathways as the only MIPS reporting option, for clinicians who do not participate in a MIPS APM, from the CY 2031 performance period, after traditional MIPS sunsets with the CY 2030 performance period.
Recommended action
- Map employed-group specialties to available MVPs before CY 2031.
Scope and timing
- Authority status
- Final
- Responsible owner
- Quality / Physician enterprise
- Publication date
- 2026-11-04 (fact sheet original posting, per its version history)
- Implementation date
- Traditional MIPS sunset after the CY 2030 performance period; MVP required from the CY 2031 performance period for clinicians who do not participate in a MIPS APM; e-prior-authorization measures required from the CY 2028 performance period
- Other dates
- 2026-11-05 (links to the final rule added); CY 2027 performance period begins 2027-01-01
Not established
The resource library record for the fact sheet carries no date; the fact sheet's own version history gives 11/04/2026 as its original posting and 11/05/2026 for added links. The 11/05 and 11/06 library dates belong to other records.
Sources
Complete edition and supplemental material
This article in the complete report →
Executive triage, source-coverage limitations, context and forward horizons remain in the complete report.
Read the entire Medicare & Medicaid Sweep report →