What Is the MIPS Podiatry Value Pathway for 2026?
As of August 2026, CMS requires podiatry practices billing Medicare Part B to participate in the Merit-based Incentive Payment System, and for the first time, a podiatry-specific MIPS Value Pathway is available for the 2026 performance year. The podiatry MVP is a streamlined reporting option that replaces the need to select from hundreds of generic quality measures with a curated set designed for foot and ankle care patterns. Practices that fail to meet the 75-point performance threshold face up to a 9% Medicare Part B payment penalty applied to every claim in 2028.
Registration deadline:
MVP registration through the CMS QPP portal closes November 30, 2026. Practices that miss the window default to traditional MIPS reporting.
Financial exposure:
The maximum penalty is 9% of Medicare Part B revenue, applied claim by claim for the full 2028 calendar year.
Who it affects:
Any podiatrist or podiatry group exceeding all three low-volume threshold elements must report MIPS data for the 2026 performance year.
What Changed for Podiatry in MIPS 2026
CMS finalized six new MIPS Value Pathways in the CY 2026 Physician Fee Schedule Final Rule, published November 5, 2025. One of those six is built specifically for podiatry. Before 2026, podiatrists reporting MIPS had to navigate the full traditional MIPS framework, selecting from hundreds of quality measures that often had little relevance to foot and ankle care. The new pathway groups quality, improvement activity, and cost measures into a single reporting set that reflects the work podiatry practices actually do.
A significant advocacy win came with the pathway’s design. The American Podiatric Medical Association successfully pushed CMS to exclude the Non-Pressure Ulcer Episode-Based Cost Measure from the podiatry MVP. That measure had been a source of concern because it attributed costs to podiatrists for care episodes they did not control, creating an unfair scoring disadvantage. Its removal means the cost category within the podiatry MVP uses measures more appropriately aligned with podiatric practice patterns.
The performance threshold remains set at 75 points out of 100, and CMS has confirmed this threshold holds through the 2028 performance year. The 2026 performance period runs January 1 through December 31, 2026, with data submission due by March 31, 2027. The resulting payment adjustment, positive or negative, hits every Medicare Part B claim processed throughout calendar year 2028.
Does the Podiatry MVP Apply to Your Practice?
The MIPS program applies to any eligible clinician or group that exceeds all three low-volume threshold elements during the determination period. For the 2026 performance year, a practice is excluded from MIPS only if it falls below all three of these limits: $90,000 or less in Medicare Part B allowed charges, 200 or fewer Medicare Part B patients, and 200 or fewer covered professional services furnished to Medicare Part B patients.
If a podiatry practice exceeds even one of those thresholds while remaining below the others, it is still excluded. All three must be exceeded for the reporting requirement to apply. Solo practitioners and small groups should verify their status through the QPP Participation Status Tool on the CMS website. In our experience matching providers with billing partners, practices that assume they are exempt without checking frequently discover they crossed the threshold during a busy quarter and now owe a reporting obligation they were not tracking.
Practices with qualifying circumstances beyond their control, such as natural disasters, public health emergencies, or cyberattacks, can apply for a MIPS exception through CMS. Exception applications for the 2026 performance year are currently being accepted. Small practices that do meet the threshold receive automatic flexibilities, including Promoting Interoperability category reweighting and a reduced improvement activity requirement.
Why CMS Created a Podiatry MVP
CMS introduced MIPS Value Pathways in 2023 as an alternative to traditional MIPS reporting. The stated goal is to simplify the program, reduce reporting burden, and make quality data more meaningful for both clinicians and patients. Each MVP bundles quality, cost, improvement activity, and promoting interoperability measures into a single specialty-aligned set rather than requiring practices to assemble their own mix from a massive inventory.
For podiatry, the traditional MIPS framework created a persistent problem. Many of the available quality measures focused on primary care workflows, chronic disease management patterns, or surgical outcomes that did not reflect the day-to-day reality of a foot and ankle practice. Podiatrists were often forced to choose measures that poorly fit their patient population, resulting in lower scores despite delivering high-quality care. The dedicated podiatry MVP addresses this by curating measures relevant to podiatric practice patterns, including wound care documentation, diabetic foot exam completion, and patient-reported outcomes tied to lower extremity function. Staying current on these developments is one reason why attending podiatry conferences remains valuable for practice managers and billing teams.
CMS has not set a firm sunset date for traditional MIPS, but the direction is clear. In the CY 2025 proposed rule, CMS requested feedback on the possibility of making MVPs mandatory as early as 2029. Practices that begin reporting through the podiatry MVP now will be better positioned when that transition occurs.
How Does the Podiatry MVP Differ From Traditional MIPS?
The podiatry MVP and traditional MIPS share the same four performance categories, the same 75-point threshold, and the same penalty and bonus range. The difference is how you select and report your measures. Under traditional MIPS, a practice picks six quality measures from the full CMS inventory, chooses improvement activities from a long list, and reports cost and promoting interoperability data separately. Under the MVP, CMS pre-selects a focused set of measures tied to podiatry, and the practice reports from that curated list.
| Feature | Traditional MIPS | Podiatry MVP |
|---|---|---|
| Quality Measures | Choose 6 from full inventory (200+ measures) | Select from curated podiatry-relevant set |
| Cost Measures | Assigned based on billing patterns; may include irrelevant measures | Excludes problematic Non-Pressure Ulcer cost measure |
| Improvement Activities | Choose from full IA inventory | Pre-selected activities aligned with podiatric care |
| Registration Required | No separate registration | Yes, via QPP portal by November 30, 2026 |
| Performance Threshold | 75 points | 75 points |
| Maximum Penalty | 9% of Medicare Part B | 9% of Medicare Part B |
One question we hear constantly from practice managers is whether they should switch to the MVP or stay with traditional MIPS. The answer depends on measure alignment. If a practice’s current traditional MIPS measures already score well and the team is comfortable with the workflow, there is no penalty for staying on the traditional track in 2026. However, practices that consistently struggle to find relevant quality measures or that score poorly on cost measures they cannot control will likely perform better under the MVP framework. The curated measure set eliminates the guesswork and reduces the risk of being scored on irrelevant care episodes.
How to Register and Report the Podiatry MVP
Registering for and reporting the podiatry MVP requires a specific sequence of steps. Missing any one of them can result in defaulting to traditional MIPS or failing to submit data entirely, both of which put 2028 revenue at risk.
- 1. Verify your MIPS eligibility status using the QPP Participation Status Tool on the CMS website. Confirm whether your practice exceeds all three low-volume threshold elements for the 2026 determination period.
- 2. Log into the QPP portal and complete the formal MVP registration before November 30, 2026. Solo practitioners register at the individual level. Groups attest to their specialty composition during registration.
- 3. Select your quality measures from the podiatry MVP’s curated list. Choose measures that align with your highest patient volume and strongest documentation workflows.
- 4. Build measure capture into daily charting. Retroactively pulling MIPS data from paper notes or disconnected systems creates errors. Use EHR templates that prompt the documentation elements each measure requires.
- 5. Track your scores monthly. Practices that treat MIPS as a fourth-quarter scramble consistently underperform practices that monitor data completeness and measure benchmarks throughout the year.
- 6. Submit your performance data through a qualified registry, qualified clinical data registry, or the CMS web interface by March 31, 2027. Confirm submission receipt and review the preliminary feedback report when CMS publishes it.
Providers often come to us after realizing they are halfway through a performance year with no tracking system in place. At that point, the options narrow. The earlier a practice establishes its reporting framework, the more time it has to course-correct if data completeness or measure scores fall short.
Need help navigating MIPS reporting for your podiatry practice?
Our billing partners specialize in quality measure tracking, MVP registration, and penalty avoidance so you can focus on patient care.
Common MIPS Mistakes in Podiatry
Nearly half of solo clinicians receive a MIPS penalty, according to industry reporting on a bipartisan reform bill introduced in Congress in 2026. Many of those penalties trace back to the same avoidable errors. The most common issue we see providers run into is not reporting at all. A practice that exceeds the low-volume threshold but submits zero MIPS data receives the full 9% penalty automatically. There is no warning or grace period.
Choosing measures that do not match the practice’s patient population is another frequent problem. Under traditional MIPS, a podiatry practice might select a diabetes management measure thinking it aligns with their diabetic foot care volume, only to discover the measure attributes care episodes to the managing physician, not the podiatrist. The podiatry MVP reduces this risk by limiting measure choices to those validated for foot and ankle care patterns.
Data completeness failures also drive penalties. CMS requires a minimum case threshold for each quality measure. If a practice selects a measure but does not meet the minimum number of eligible cases, that measure scores at a 3-point floor rather than a benchmark-based score. Stacking multiple low-volume measures can push the total score below the 75-point threshold even when the quality of care is strong. Reviewing your billing data against each measure’s denominator criteria before selecting it prevents this outcome. Practices that reference their podiatry billing and coding cheat sheet during measure selection can more quickly identify which CPT codes trigger which quality measure denominators.
In-House Tracking vs. Outsourced Compliance
Some podiatry practices manage MIPS reporting internally by assigning a staff member to track measures and submit data through a registry. This works when the practice has a dedicated compliance or billing lead with the time to monitor scores throughout the year, stay current on measure specifications, and manage the submission process. For solo practitioners or small groups without that capacity, the administrative load of MIPS tracking competes directly with patient care time.
Across the billing companies we vet, a recurring pattern is that practices performing well on MIPS tend to have either a strong internal compliance function or a billing partner that builds MIPS into the revenue cycle workflow. The billing partner monitors data completeness weekly, flags missing documentation before it becomes a year-end problem, and handles the registry submission. For practices focused on strategies for maximizing revenue in podiatry, protecting 9% of Medicare Part B revenue from an avoidable penalty is one of the highest-return compliance activities available.
The decision often comes down to volume. A practice billing $500,000 annually in Medicare Part B faces a potential $45,000 penalty. A practice billing $2 million faces $180,000. At those dollar amounts, the cost of outsourced MIPS compliance is a fraction of the downside risk. CMS also runs MIPS on a budget-neutral, tournament-style model, meaning penalties collected from low scorers fund the bonus pool for high scorers. Practices that report well not only avoid the penalty but may receive a positive adjustment.
Frequently Asked Questions
No. The podiatry MVP is a voluntary alternative to traditional MIPS reporting for the 2026 performance year. Practices can choose either pathway. However, CMS has signaled that MVPs may become mandatory as early as 2029, and practices that begin reporting through the MVP now will have an easier transition when that shift occurs.
Practices that exceed all three low-volume threshold elements and submit no MIPS data receive the maximum 9% negative payment adjustment. This penalty applies to every Medicare Part B claim processed during the 2028 calendar year. There is no waiver or appeal for non-reporting unless the practice qualifies for an approved exception.
MVP registration through the CMS Quality Payment Program portal closes November 30, 2026. Solo practitioners register at the individual level. Groups must attest to their specialty composition during registration. Practices that miss the registration window default to traditional MIPS reporting for the 2026 performance year.
For 2026, multispecialty groups can no longer register to report an MVP at the group level unless they hold small practice status. Individual podiatrists within a multispecialty group may still report the podiatry MVP at the individual level if they meet the eligibility requirements.
Practices scoring below 75 points receive a negative payment adjustment on a linear sliding scale. The penalty reaches the maximum of 9% for scores at or below 18.75 points. Practices scoring at or above 75 points receive a neutral or positive adjustment. The threshold of 75 points is confirmed through the 2028 performance year.
The podiatry MVP excludes the Non-Pressure Ulcer Episode-Based Cost Measure that had previously been a concern for podiatrists under traditional MIPS. This exclusion was a direct result of APMA advocacy. The cost measures included in the podiatry MVP are designed to attribute costs only to care episodes appropriately connected to podiatric practice patterns.
Next Steps
- Check your MIPS eligibility status on the CMS QPP portal this week. If you exceed the low-volume threshold, decide whether the podiatry MVP or traditional MIPS is the better fit for your practice and begin tracking measure data now.
- For more on the coding and documentation workflows that underpin MIPS quality measures, review our podiatry billing and coding cheat sheet. Practices looking for a broader view of how billing strategy protects revenue should also review our guide to strategies for maximizing revenue in podiatry.
- If you need a billing partner who handles MIPS tracking alongside your claims, we can connect you with companies that specialize in podiatry revenue cycle management and quality reporting.
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