This blog provides a detailed, visual, and measure-level comparison of 3 key CMS programs under the Quality Payment Program (QPP) framework — traditional MIPS, MIPS Value Pathways (MVPs), and the new Ambulatory Specialty Model (ASM) finalized in the 2026 Physician Fee Schedule Final Rule (CMS-1832-F).
- Traditional MIPS (2017–present): Broad, clinician-driven program allowing flexibility in measure selection but limited comparability across specialties.
- MIPS Value Pathways (MVPs, 2023–2026): Transitional structure to align measures by specialty or condition, improving comparability and interoperability.
- Ambulatory Specialty Model (ASM, launching 2027): Mandatory, condition-specific model targeting heart failure and low back pain specialists in select CBSAs.
This comparison highlights how CMS is evolving from flexible reporting (MIPS) to aligned reporting (MVPs) to accountable, outcome-based measurement (ASM), with increasing use of digital quality measures (DQMs), FHIR data exchange, and data validation via DQMs.
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Measures and reporting structure
|
Dimension |
Traditional MIPS |
MIPS Value Pathways (MVPs) |
Ambulatory Specialty Model (ASM) |
|
Measure framework |
Flexible — clinicians self-select from >200 measures across >40 specialties. |
Curated measure sets aligned to clinical themes or specialties (typically 6–9 quality measures per MVP). |
Fixed, CMS-defined sets tied to targeted chronic conditions (heart failure, low back pain). |
|
Quality category |
Choose 6 quality measures (including ≥1 outcome or high-priority measure). May report via registry, EHR, claims, or CMS Web Interface (phased out). |
CMS pre-selects a smaller, focused set of measures relevant to the MVP’s theme. Includes 1–2 patient-reported outcome measures (PROMs). |
CMS specifies condition-based quality measures, including clinical outcomes and PROMs (e.g., functional status, symptom improvement). No clinician choice. |
|
Examples of quality measures |
• MIPS 236: Controlling High Blood Pressure • MIPS 130: Documentation of Current Medications • MIPS 226: Tobacco Use Screening |
Cardiology MVP • MIPS 438: Statin Therapy for ASCVD• MIPS 438 (Outcome) + PROM: Kansas City Cardiomyopathy Questionnaire (KCCQ) • MIPS 438 equivalents via FHIR dQMs |
Heart Failure ASM • 30-Day Readmission Rate (claims-based)• Beta-Blocker or ACE/ARB/ARNI Therapy Use • PROM: KCCQ improvement ≥5 points. Low Back Pain ASM • Pain Interference PROMIS 29 Domain T-score improvement• Avoidance of early imaging for acute back pain • Physical Function improvement PROM |
|
Cost category |
Automatically scored via CMS claims-based episode-based cost measures (EBCMs) and Total Per Capita Cost (TPCC). |
Aligned to MVP theme: uses targeted EBCMs (e.g., Heart Failure, Low Back Pain, Diabetes, or Procedural Episodes). |
Uses identical EBCMs for the 2 chronic conditions but applied as the central scoring driver (heavier weight, model-level comparison). |
|
Improvement Activities (IA) category |
Choose up to 4 from >100 IAs. Clinician discretion to fit practice priorities. |
CMS defines a limited, pre-selected list (4–6) per MVP focused on care coordination, population health, and interoperability. |
CMS mandates specific care-coordination and patient engagement activities, e.g.: • Routine primary-care linkage for specialty patients. • Use of patient risk-screening tools. • Upstream chronic-care management workflows. |
|
Promoting Interoperability (PI) category |
Standard CEHRT-based EHR objectives: e-prescribing, HIE, public-health reporting, patient access. |
Same CEHRT requirements; MVP reporting aligns timing and submission formats with MIPS. |
Same CEHRT requirements but interoperability measures are integrated with ASM scoring (e.g., electronic exchange of care-plans, summary-of-care documents). |
|
Measure selection flexibility |
High — clinician or group selects which measures to report. |
Moderate — fixed MVP sets; some optional specialty-aligned measures can be added. |
None — CMS defines all measures; participants cannot add or substitute. |
|
Measure submission method |
Multiple (EHR, registry, claims, QCDR). |
EHR, Registry, or QCDR via FHIR or QRDA III; CMS encouraging digital transition. |
Must use certified electronic reporting (FHIR-based or registry with CMS alignment); no claims submission option. |
|
Benchmarking method |
National benchmark across all MIPS reporters for each measure. |
Specialty-specific benchmarking within MVP cohort. |
Condition-specific benchmarking — clinicians are compared only to peers managing the same chronic condition in selected CBSAs. |
|
Patient-Reported Outcome measures (PROMs) |
Optional; may substitute for outcome measure. |
Required component of each MVP; at least one PROM per MVP. |
Core requirement; patient-reported outcomes drive part of payment adjustment (KCCQ, PROMIS, etc.). |
|
Weighting of categories (2026) |
Quality 30% Cost 30% IA 15% PI 25% |
Same overall weighting, but internal scoring adjusted to MVP structure. |
Quality 35% Cost 35% IA 15% PI 15% (higher focus on outcomes and cost, lower PI burden). |
|
Measure evolution path |
Many topped-out measures; CMS phasing to digital quality measures (DQMs). |
All MVPs transitioning to FHIR-based DQMs by 2028. |
Fully digital/FHIR data validation through DQMS once operational; early pilot for DQM readiness. |
Narrative summary
Traditional MIPS: Choose your own adventure
Clinicians enjoy maximum flexibility, but the resulting self-selection dilutes comparability. For example, a cardiologist could report general preventive measures (like flu vaccination) unrelated to specialty outcomes.
CMS has consistently found this weakens quality-to-cost correlation.
MIPS Value Pathways (MVPs): Specialty alignment bridge
MVPs tighten measure alignment. Clinicians now report within a defined clinical theme (e.g., heart disease, diabetes, musculoskeletal care). Measures integrate claims, EHR, and patient-reported data, encouraging cross-domain interoperability.
MVPs also introduce subgroup reporting for multi-specialty groups, ensuring fairer comparisons.
Ambulatory Specialty Model (ASM): Mandatory, condition-focused next step
ASM moves beyond voluntary alignment to mandated participation in randomly selected CBSAs (≈25%).
For 2027:
- Heart failure cohort: ~3,400 clinicians (1,160 TINs)
- Low back pain cohort: ~5,200 clinicians (2,400 TINs)
Each specialist is measured by the same fixed measure set, integrating quality, cost, and patient experience. Patient-reported outcomes directly affect payment. Unlike MIPS or MVPs, there’s no opt-out. Scoring ranges are also wider (truly -9% to +9% or more).
CMS intends ASM to serve as a proof-of-concept for future specialty models where validated, condition-specific measures (via DQMs) replace MIPS entirely.
Key takeaway
|
Program |
Measure philosophy |
Clinician flexibility |
Comparability |
Policy intent |
|
Traditional MIPS |
Broad, elective |
High |
Low |
Foundational, but diffuse |
|
MVPs |
Specialty-aligned |
Moderate |
Moderate-High |
Transitional standardization |
|
ASM |
Condition-mandated, outcome-centric |
None |
High (like-to-like) |
Next-generation value-based specialty model |
Conclusion: The future of quality reporting
CMS’ 2026 Final Rule marks a pivotal turning point for clinicians and healthcare organizations engaged in quality reporting. As traditional MIPS gives way to MVPs and ultimately to the Ambulatory Specialty Model, the agency is driving toward a unified, outcomes-based, and digitally enabled ecosystem.
For clinicians, this evolution means fewer choices but clearer expectations. Success will depend on delivering measurable improvements in cost, coordination, and patient outcomes. For health systems, it’s an opportunity to embrace interoperability, leverage FHIR-based automation, and align internal data strategies with CMS’ vision for data integrity through DQMs.
Ultimately, MIPS to MVPs to ASM represents more than a reporting shift. It’s CMS’ blueprint for a smarter, fairer, and more patient-centered performance landscape, where quality isn’t just measured, it’s proven.
