The Centers for Medicare & Medicaid Services (CMS) have released the 2024 Merit-based Incentive Payment System (MIPS) performance feedback and final scores. The 2024 performance year was characterized by stability, consistency, and restrained adjustments.
Despite modest scoring variations, the 2024 feedback underscores CMS’ strategic redirection toward structured, specialty-aligned models — MIPS Value Pathways (MVPs), the Ambulatory Specialty Model (ASM), and broader CMMI-led innovation frameworks —to drive the next era of value-based reimbursement.
Performance outcomes at a glance
CMS reported that the mean final MIPS score for the 2024 performance year was 82.7, with a median of 84.0. That’s virtually unchanged from the 2023 cycle. The performance threshold remained at 75 points, consistent with prior years.
The maximum positive adjustment for 2026 payments is only +1.05%, marking the lowest incentive payout in program history. Negative adjustments remain capped at -9%, maintaining the full statutory penalty range.
|
Year |
Mean score |
Median score |
Max positive adjustment |
Max negative adjustment |
Neutral threshold |
|
2023 |
83.18 |
85.49 |
+2.15% |
-9% |
75 |
|
2024 |
82.7 |
84.0 |
+1.05% |
-9% |
75 |
CMS confirmed that the reduction in positive adjustment magnitude reflects budget neutrality pressures, as overall provider performance continues to cluster tightly above the neutral threshold. This consistent scoring distribution suggests strong program compliance but limited differentiation among performers.
|
MIPS final score (2024) |
2026 payment adjustment |
|
100 |
+1.05% |
|
90 |
+0.63% |
|
80 |
+0.21% |
|
75 |
0% (neutral) |
|
60 |
–1.73% |
|
50 |
–2.89% |
|
40 |
–4.04% |
|
30 |
–5.20% |
|
20 |
–6.36% |
|
10 or below |
–9.00% |
CMS’ scaling factor ensures total positive bonuses don’t exceed total penalties. This results in small upward adjustments despite high average performance across clinicians.
Category-level insights
|
Category |
Weight |
2024 score trend |
Key observations |
|
Quality |
30% |
Slight decline from 2023 |
CMS reports stagnant performance, largely due to half of quality measures lacking valid benchmarks and higher completeness thresholds (75%). |
|
Cost |
30% |
Minor improvement overall |
CMS implemented median-based cost scoring and 5 new episode-based cost measures, reducing volatility but narrowing standout performance potential. |
|
Promoting Interoperability (PI) |
25% |
Stable high participation (>94%) |
The category remains functionally “mature”. Nearly all large practices achieve max marks. |
|
Improvement Activities (IA) |
15% |
No change |
Most clinicians received full credit, continuing to yield minimal performance differentiation. |
These results reflect a “compliance plateau”: strong adherence with diminishing performance elasticity. Clinicians are reporting efficiently, but the incentivization gap between threshold and excellence has collapsed.
Program dynamics: A year of stability by design
CMS framed the 2024 MIPS year as one of “predictable performance”, emphasizing program stabilization while preparing for broader structural reform. The 2024 Physician Fee Schedule maintained 198 active MIPS quality measures, 5 new MVPs, and nearly identical category mechanics to 2023.
CMS’ Quality Measure Development Plan (MDP) also aligned with this steadiness by refining reporting standards, integrating the Universal Foundation of Measures, and embedding interoperability within more measures to prepare for MVP conversion.
The 2024 reporting environment was non-eventful on the surface but directional underneath. While payment dynamics flattened, the groundwork for the next MIPS iteration was clearly laid.
Evolving CMS focus: MVPs, ASM, and integration models
Beyond the calm of static metrics, CMS’ 2024 feedback cycle outlines an unmistakable strategic pivot toward integrated, specialty-specific accountability models:
- MIPS Value Pathways (MVPs): CMS will expand MVPs to 22 options by 2026, facilitating specialty-specific reporting with reduced measure overlap. Long-term, CMS expects MVPs to replace traditional MIPS by 2029, simplifying clinician reporting while emphasizing outcome-based metrics.
- ACO participation shifts: Organizations are working to align ACO participation with the incentivization strategies of CMS. As ACOs mature, more strategic participation in payment models is occurring.
- Ambulatory Specialty Model (ASM): Announced in the 2026 Proposed Rule, ASM introduces mandatory two-sided risk for outpatient specialties treating chronic conditions such as heart failure and low back pain. This marks CMS’ first structured move toward specialist accountability outside of voluntary APMs.
- CMMI Innovation Model Integration: CMS, through the Center for Medicare and Medicaid Innovation, continues to expand programmatic links with ACO, TEAM, and Flex models. Each emphasizes the transition from performance reporting toward continuous measurement embedded in care delivery.
This is a restructuring era in slow motion, a deliberate narrowing of performance variability now, to support more cohesive, risk-bearing structures later.
Small-practice realities and equity considerations
Despite stability in benchmarks, smaller practices continue to face disproportionate challenges. CMS’ hardship exemptions and reweighting policies remain in place, yet interoperability and cost measure gaps still amplify disparities for rural and low-volume providers.
Recommended provider actions
To align with feedback trends and policy evolution, we advise 4 specific near-term actions:
- Verify feedback accuracy: Submit targeted review requests by Nov. 14, 2025, for any scoring or attribution discrepancies.
- Realign quality portfolios: Decommission topped-out measures and adopt those tied to future MVP domains.
- Leverage predictive analytics: Model 2025–2026 cost and MVP scenarios with tools that use past and current data to predict optimal reporting strategies.
- Prepare for risk readiness: Begin testing workflows and data sufficiency for ASM participation in eligible specialties.
The calm before reconfiguration
The 2024 MIPS performance results represent a year of continuity: high compliance, low variation, and muted incentives. Yet CMS’ emphasis on MVP standardization, specialist accountability (ASM), and expanded integration across CMMI models makes clear that the quiet of 2024 is intentional. CMS has set the stage for more risk-bearing models, more digitally enabled reporting, and more focused comparisons.
2024 was stable by design. 2026 may not be.
CMS payment adjustment and performance feedback resources:
- 2026 MIPS Payment Year Payment Adjustment User Guide (PDF, 2 MB) : Reviews information about the calculation and application of MIPS payment adjustments, and answers frequently asked questions.
- 2024 MIPS Performance Feedback FAQs (PDF, 2 MB): Reviews the information available in performance feedback and how to access it. (Note: CMS is in the process of updating this resource with the Targeted Review deadline.)
- 2024 MIPS Performance Feedback Supplemental Reports Guide (PDF, 833 KB): Reviews the downloadable supplemental and patient-level reports for administrative claims, quality measures, and cost measures.
- 2024 Quality and Cost Benchmarks: Links to quality and cost measure benchmarks and supporting documentation. (Benchmarks determine measure scores.)
