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2026 MIPS Improvement Activities

The Improvement Activities (IA) category requires a pathologist or group to attest to completing a certain number of CMS-approved activities over the course of the year, with each activity taking place over at least 90 continuous days. This category will count for 15% of the overall MIPS final score for large practices and 50% of the overall MIPS final score for small practices.

For MIPS reporting, only an attestation is required to receive points for completing Improvement Activities. However, in the event of an audit, practices will need to ensure they have documentation confirming the completion of the activity.

Important 2026 Updates: CMS has removed two IAs applicable that were highly used by pathologists and three more that some practices reported

  • IA_CC_1: Implementation of Use of Specialist Reports Back to Referring Clinician or Group to Close Referral Loop
  • IA_CC_2: Implementation of Improvements that Contribute to More Timely Communication of Test Results
  • IA_AHE_8: Create and Implement an Anti-Racism Plan
  • IA_ERP_3: COVID-19 Clinical Trials
  • IA_PM_26: Vaccine Achievement for Practice Staff: COVID-19, Influenza, and Hepatitis B

CMS has removed the “Advancing Health Equity (AHE)” Improvement Activity subcategory for 2026. Some activities that were part of this subcategory, such as IA_AHE_6, Provide Education Opportunities for New Clinicians, are still available as part of a different subcategory. Other AHE activities, such as IA_AHE_8, Create and Implement an Anti-Racism Plan, have been eliminated.

CMS has introduced a new subcategory for 2026, Advancing Health and Wellness. However, there is only one IA in this category, IA_AHW_1, Chronic Care and Preventative Care Management for Empaneled Patients. This IA is not applicable to most pathology practices.

Available Activities

We have developed a resource to help pathologists participating in MIPS determine which Improvement Activities to attest to in 2026. To receive credit in this category, pathologists need to attest to Improvement Activities, which represent 15% of their final MIPS score if they are in a large practice and 50% of their final MIPS score if they are in a small practice.

Attesting and Submitting Activities

Participants in the Pathologists Quality Registry can attest to Improvement Activities using the MIPS Portal. Those who choose to submit using Medicare Part B claims or other registries can attest to Improvement Activities using the log in and attest submission method on the CMS website.

2026 Improvement Activities FAQs

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The Improvement Activities (IA) category is a performance category first introduced for the 2017 Merit-based Incentive Payment System (MIPS) performance year by the Centers for Medicare & Medicaid Services (CMS). The IA category is intended to reward clinicians for care focused on coordination, beneficiary engagement, and patient safety. Below are key questions to keep in mind and the list of pathology-specific Improvement Activities for the 2026 MIPS performance year. These Improvement Activities have been successfully reported to CMS through the Pathologists Quality Registry.

The IA category is intended to reward clinicians for care focused on coordination, beneficiary engagement, and patient safety. Activities include emergency preparedness, addressing health equity, and introducing formal methods of quality improvement.

The weight of the Improvement Activities category varies depending on practice size. For large pathology practices (16 clinicians or more), the IA category is 15% of the final MIPS score. The other 85% is the Quality category. For small pathology practices (15 or fewer clinicians), the IA category is 50% of the final MIPS score. The other 50% is the Quality category.

The maximum score for an individual or group is 40 points. CMS has removed the weighting system for Improvement Activities; all activities are now equally weighted. In order to satisfy the requirements of this category, individuals or groups must attest to one activity. 

  • Physicians must do the activity for a minimum of 90 continuous days and up to a full year.
  • At least 50% of the physicians in a practice must perform the same IA. Clinicians can work on different projects or initiatives within an Improvement Activity but must contribute to the same overall IA
    • Example: Pathology Practice, LLC has three pathologists. Pathologist A completes his OPPE activity between February and March 2024. Pathologist B chooses a different OPPE metric and completes hers between March and May 2024. This satisfies IA_PSPA_13 for this practice
  • Physicians must keep documentation for 10 years on how they participate in an Improvement Activity.

Many activities pathologists are already doing should qualify for Improvement Activities. Some of the top Improvement Activities utilized by pathologists include:

  • Participation in Joint Commission Evaluation Initiative
  • Implementation of use of specialist reports back to referring clinician or group to close referral loop

Please refer to the IA document that the CAP has developed for more guidance on which IA to attest.

Physicians must attest to completing the Improvement Activities by the end of the 2026 MIPS reporting period.

  • A simple "yes" is all that is required to attest to completing an improvement activity. However, in the event of an audit, practices will need to ensure they have documentation confirming the completion of the activity.
  • Most billing companies cannot provide attestation for Improvement Activities. Therefore, most pathologists will need to attest, such as through a qualified registry, for Improvement Activities.
  • For group reporting in 2026, 50% of clinicians in a tax identification number (TIN) entity must perform the same Improvement Activity for the TIN to receive credit.
  • Not everyone in the group or TIN has to perform the Improvement Activity at the same time, but they have to perform the same Improvement Activity. Clinicians can perform the activity during any continuous 90-day period during the performance year.
  • Clinicians can perform or participate in different initiatives and projects in order to satisfy the same Improvement Activity. The group must retain documentation to show that 50% of the clinicians in the group (TIN) have performed or participated in an initiative or project to support the Improvement Activity or Activities to which the group is attesting.
  • Please refer to the case studies the CAP has developed for examples on how a group can satisfy the Improvement Activities requirement in 2026.

Visit the CMS website for more information on Improvement Activities.

Members can login to see 2026 improvement activities Lock we have identified as applicable to pathologists.

CMS QPP Resources

Contact Information

We have a dedicated team to help you succeed in MIPS. Contact us to learn how we can optimize your MIPS performance.

Email: mips@cap.org

Phone: 800-323-4040, option 3

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