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How changes to Quality Payment Program rules will affect pathologists

In its final 2026 QPP regulations, the CMS will leave the performance threshold at 75 points for next year’s reporting. 

The impact: Maintaining the current threshold is better than an increase, which adds further burdens on pathologists.

The CMS is also maintaining the data completeness threshold at 75 points. And, no measures were added to or removed from the Pathology Specialty Measure Set and the Pathology QPP measures will remain worth a maximum of 10 points for practices who score 100%.

The CMS also continues to carry out MIPS Value Pathways (MVPs) including for the first time a Pathology.

  • The Pathology MVP includes MIPS Clinical Quality Measures (CQMs) and QCDR measures from the Pathologists Quality Registry as well as a commercial QCDR, MSN Healthcare.   
  • Several of the Improvement Activities (IAs) included in the MVP are not applicable to pathologists.
  • The MVP also includes other aspects of the MIPS program that do not apply to pathologists such as population health measures and Promoting Interoperability activities.
  • For information about reporting the MVP, contact mips@cap.org

What's next: The CAP continues to advocate for pathologists’ success in the MIPS program.

  • We encourage practices (and their billing companies) to review the scoring changes and contact CAP at mips@cap.org to understand the availability of higher-scoring measures and how to best report them. 

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