Merit-based Incentive Payment System Value Pathways (MVPs) are a subset of measures and activities, established through rulemaking, that can be used to meet MIPS reporting requirements.
Those choosing to report MVPs will be able to report their data through AQI NACOR's Qualified Registry (MIPS measures only) or Qualified Clinical Data Registry (QCDR) options (MIPS and QCDR measures may be reported).
The MVP framework aims to align and connect measures and activities across the quality, cost, and improvement activities performance categories of MIPS for different specialties or conditions. In addition, the MVP framework incorporates a foundation that leverages Promoting Interoperability measures and a set of administrative claims-based quality measures that focus on population health in order to reduce reporting burden.
Performance Year 2026
CMS approved a revised "Patient Safety and Support of Positive Experiences with Anesthesia MVP" and introduced a new layout with clinical groupings of measures. MVP scoring and special status designations do not differ from Traditional MIPS policies. Those groups choosing to report the MVP in 2026 will only need to report four quality measures, one improvement activity and promoting interoperability measures (optional depending on your special status designation). CMS will calculate the Medicare Spending Per Beneficiary (MSPB) Clinician measure for the Cost Performance Category.
Eligible clinicians and their groups will need to choose four measures from this designated list:
Eligible clinicians and their groups also have a set of nine (9) improvement activities to choose:
Individuals and groups will need to register with CMS during the 2026 performance period to report an MVP. The registration period runs April 1 and November 30th of the performance year.
Even if you register to report an MVP, you can still choose to report traditional MIPS or the APM Performance Pathway (APP), if applicable.
Subgroup Reporting
CMS defines a subgroup as, “A subset of a group which contains at least one MIPS eligible clinicians and is identified by a combination of the group Taxpayer Identification Number (TIN), the subgroup identifier, and each eligible clinician’s National Provider Identifier (NPI).” Anesthesiologists who participate in MIPS with non-anesthesiologists may be able to report the anesthesia MVP. Please check with your group administrator or CMS for eligibility requirements.
What are the differences between Traditional MIPS and MVPs?
Anesthesiologists and their groups may report either Traditional MIPS or the Anesthesia MVP in 2026. The table below includes some considerations when choosing whether to report one or the other.
| Description | Traditional MIPS | MIPS Value Pathways |
| General | Available for 2026 performance year reporting. Multispecialty groups can report six measures from any specialty and receive credit for the entire group. |
Available for 2026 performance year reporting. Multispecialty groups, in the future, will be required to report on the MVP that applies to their subspecialty eligible clinicians. |
| Quality Measures | Qualified Registry Participants: Choose any MIPS measures. QCDR Participants: Choose any combination of MIPS and QCDR measures. Report six (6) quality measures on at least 75% of cases to which the measure applies. |
Qualified Registry Participants: Limited to MIPS 404, 430, 463, 477, and 487. QCDR participants must choose from MIPS 404, 430, 463, 477, AQI48, ePreop31, and ABG44. Report four (4) quality measures on at least 75% of cases to which the measure applies. |
| Improvement Activities | Choose any of the 100+ improvement activities available. For most anesthesiologists and groups. |
Choose from the designated list of nine (9) activities. Must attest to one improvement activity. |
| Cost | CMS calculates the cost performance category. | CMS calculates the cost performance category. |
| Promoting Interoperability | Special status designations apply. Most anesthesiologists and their groups will not need to report. | Special status designations apply. Most anesthesiologists and their groups will not need to report. |
| Population Health | CMS calculates if a population health measure applies to the individual or group. | CMS calculates if a population health measure applies to the individual or group. |
Performance Year 2025:
Eligible clinicians and their groups will need to choose four measures from this designated list:
Eligible clinicians and their groups also have a set of twelve (12) improvement activities to choose:
For more information, please contact ASA Department of Quality and Regulatory Affairs at qra@asahq.org.
Curated by: ASA Department of Quality and Regulatory Affairs
Date of last update: January 30, 2026