MIPS for PT, OT, and SLP: 2026 Reporting and the MVP Sunset

Physical therapists, occupational therapists, and qualified speech-language pathologists are MIPS eligible clinician types, but eligibility is not the same as being required to report. A clinician is required to report for the 2026 performance year only if they bill more than $90,000 in Part B allowed charges, treat more than 200 Medicare Part B patients, and furnish more than 200 covered services, all three. Miss the reporting duty when it applies and the Medicare payment adjustment can reach negative 9 percent on Part B payments in 2028. Data for 2026 is submitted from January 4 to March 31, 2027.

A point that is easy to get wrong: the automatic Promoting Interoperability exemption by therapist clinician type ended after the 2023 performance year. What applies now is small-practice reweighting. The CY 2027 proposed rule would also phase out traditional MIPS beginning with the CY 2029 performance year / 2031 payment year. Sources are 42 CFR 414.1305 and the CMS 2026 Quick Start Guides and Small Practice Eligibility FAQ. Current as of October 2026.

Do physical therapists have to report MIPS in 2026?

It depends on the clinician’s own numbers. The CMS Small Practice Eligibility FAQ lists “Physical therapists”, “Occupational therapists”, and “Qualified speech-language pathologists” among the eligible clinician types for 2026, identified under 42 CFR 414.1305 by a unique billing TIN and NPI combination. Per the FAQ, you are required to report when you are an eligible type, enrolled in Medicare before January 1, 2026, not a Qualifying APM Participant (QP), and exceed the low-volume threshold as an individual.

PTAs, OTAs, and SLP assistants are not on the eligible list. In private practice, their services are billed on the supervising therapist’s claims, which matters in Example 3 below.

What is the MIPS low-volume threshold for 2026?

The threshold has three parts. The FAQ states that to exceed it for the 2026 performance year, you must meet all three:

The regulation is written from the other direction. Section 414.1305 sets the low-volume threshold at allowed charges of $90,000 or less, or 200 or fewer Medicare Part B-enrolled individuals, or 200 or fewer covered professional services. Falling at or under any one of the three puts a clinician under the threshold. And 414.1310(b)(1)(iii) excludes from the definition of MIPS eligible clinician anyone who does not exceed the threshold.

Which 12 months of billing count?

CMS evaluates eligibility over a 24-month determination period with two segments. Under 414.1305, a clinician identified as not exceeding the threshold in the first segment is identified that way for the payment year regardless of the second segment. A clinician whose TIN and NPI combination is first established during the second segment is assessed on that segment alone.

The FAQ adds that a practice that established a new TIN between October 1, 2025 and September 30, 2026 is evaluated on segment 2 only. The plain reading of the regulation and the FAQ: if segment 1 shows you below the threshold, you stay below it for 2026, and segment 2 can only add you if you are newly billing under that TIN and NPI. Check status with the QPP Participation Status Tool and a 10-digit NPI.

Does the practice or the individual get evaluated?

Both, for each TIN under which a clinician bills Part B, per the FAQ. A group is a single TIN with two or more eligible clinicians who have reassigned their billing rights to it.

That creates a middle case: a clinician who is eligible but not required to report because the practice exceeds the threshold even though the clinician does not. The FAQ says there is no requirement to report as a group just because you exceed the threshold at the practice level. If the practice does report as a group, that clinician receives a positive, negative, or neutral adjustment based on the group’s data.

The catch, per the FAQ: group reporting means submitting aggregated data for all clinicians billing under the TIN, including those not individually eligible, and group-eligible clinicians receive the group’s final score. Individually eligible clinicians receive it too unless they have a higher individual score. Clinicians eligible as individuals must report or face a negative adjustment.

Can a below-threshold therapist still participate?

Yes, in two ways, and they differ on money. Under 414.1310(b)(1)(iii)(A), an individual or group that exceeds at least one, but not all, of the three criteria can elect to participate and is then treated as a MIPS eligible clinician. Clinicians who are not MIPS eligible “have the option to voluntarily report,” per 414.1310(b)(2), but under 414.1310(d) no payment adjustment applies to them.

What is the penalty, and what score avoids it?

The performance threshold for the 2028 through 2030 payment years is 75 points (42 CFR 414.1405(b)(10)(ii)), consistent with the CY 2026 final rule. The maximum applicable percent is 9 percent (414.1405(c)). A score at or above 75 earns a zero or positive adjustment on a sliding scale. A score below it earns a negative one, and scores from 0 to one-fourth of the threshold (18.75) receive the full negative 9 percent. A required clinician who reports nothing scores 0, which is the full negative 9 percent. Positive adjustments may be scaled by “a scaling factor not to exceed 3.0” for budget neutrality.

The adjustment applies claim by claim, beginning January 1, 2028, per 414.1405(e) and the Small Practices Quick Start Guide.

When is the 2026 MIPS submission deadline?

The 2026 Quality Quick Start Guide states: “The data submission period will begin on January 4, 2027, and end on March 31, 2027.” That matches 42 CFR 414.1325(e), which sets March 31 following the performance period for direct, login and upload, login and attest, and Web Interface submissions. Part B claims must be processed within 60 days after the performance period closes.

Timeline, from the Small Practices guide and the other CMS documents cited here:

One trap: the Quality guide keeps data completeness at 75 percent for 2026 and says to start collecting on January 1, 2026, so completeness runs across the calendar year, not the submission window.

Are therapists exempt from Promoting Interoperability?

Not by clinician type, and not for the 2026 performance year.

42 CFR 414.1380(c)(2)(i)(A)(4)(i) reweights Promoting Interoperability for physical therapists, occupational therapists, qualified speech-language pathologists, and several other types, but only “for the 2021 through 2025 MIPS payment years.” The 2025 payment year corresponds to the 2023 performance year. For the 2026 performance year (2028 payment year), there is no automatic reweighting by therapist clinician type. The 2026 Promoting Interoperability Quick Start Guide lists the special statuses with automatic reweighting as Small Practices, Hospital-based, ASC-based, and Non-patient Facing, with no therapist entry.

What does apply is small-practice reweighting. Under 414.1380(c)(2)(i)(C)(9), beginning with the 2024 payment year a clinician in a small practice (15 or fewer) is reweighted. The Small Practices Quick Start Guide says small practices receive automatic reweighting to 0 percent whether they participate as an individual, group, or virtual group, and need no hardship application.

For a therapist in a practice with more than 15 clinicians, the route is a hardship exception application by December 31, 2026, which CMS must approve. The PI guide warns that a qualifying data submission voids a hardship exception and cancels automatic reweighting.

Per 414.1380(c)(2)(ii)(F), a non-small practice whose PI is reweighted scores Quality 55, Cost 30, and Improvement Activities 15.

What do traditional MIPS and an MVP require for quality?

Per the Quality Quick Start Guide, traditional MIPS means at least 6 quality measures (including 1 outcome or high priority measure) or one complete specialty measure set. An MVP means at least 4 measures from the chosen MVP, including 1 outcome or high priority measure. Medicare Part B claims measures are available only to small practices, and a small practice reporting by claims whose MVP offers fewer than 4 claims measures need not report more.

The 2026 PT/OT specialty set in traditional MIPS includes measures 182 and 217 through 222, per CMS’s measures data repository and the Explore Measures page. Measure 182 requires a standardized functional outcome assessment tool, and its 2026 specification says a pain-only VAS does not meet the criteria. For instruments, see patient intake forms for PT and chiropractic clinics.

What is the Rehabilitative Support MVP?

The Rehabilitative Support for Musculoskeletal Care MVP (ID M1370) lists Physical Therapy and Occupational Therapy among its most applicable specialties, along with Chiropractic Medicine, Physiatry, and others. The official listing is the Explore MVPs page; the 2026 contents below come from CMS’s measures data repository (mvp/2026/mvp.json, as of October 22, 2026). The MVP Implementation Guide says you must register between April 1 and November 30, 2026 (8 p.m. ET), and cannot report an MVP you did not register for.

The MVP lists 16 quality measures:

Only 128 and 134 have a Medicare Part B claims collection type, and every outcome measure here is registry-only. Per the Quality Quick Start Guide, a small practice reporting only by claims can meet the measure count with those two; a practice that wants outcome measures needs a registry or QCDR submission. The cost measure is COST_LBP_1 (low back pain episode-based), calculated by CMS from claims. Sixteen improvement activities are listed, and one is required in 2026.

Illustrative arithmetic: four worked examples

These are hypothetical numbers, not real clinics, applied to the rules above.

Example 1: solo PT, own TIN. Segment 1 shows $84,000 in Part B allowed charges, 160 Medicare Part B patients, and 2,100 covered services. Only the services criterion is exceeded.

Outcome: not required, but opt-in eligible (at least one but not all criteria exceeded). Opting in applies the adjustment up or down, voluntary reporting yields feedback only, and doing nothing means no adjustment. Because segment 1 shows below the threshold, segment 2 cannot make this clinician required for 2026.

Example 2: three-clinician group, one TIN.

If the group reports, all three receive the group score and 2028 adjustment, including PT-B and OT-C, because the threshold is applied at the group level for group reporting. If not, PT-A must report individually or take negative 9 percent in 2028, and PT-B and OT-C get no adjustment. As a small practice, PI is reweighted to 0, weights are 40/30/30, and claims measures are available. Reporting the Rehabilitative Support MVP requires registering by November 30, 2026.

Example 3: PTA-heavy clinic. Two PTs and four PTAs bill under one TIN. All PTA visits are billed under the two PTs’ NPIs with the CQ modifier.

Both PTs are individually required, and the PTAs never appear in MIPS. The CY 2019 final rule says PTAs and OTAs are not recognized separately in the statute to enroll as practitioners for independently billing Medicare. CMS does not spell out the accrual in so many words, but the plain reading of that statement together with the TIN and NPI determination in 414.1305 is that assistant-furnished visits accrue to the supervising therapist’s counts, and the adjustment applies to that NPI’s paid claims, including CQ lines. See the CQ and CO modifier guide and PTA and OTA supervision requirements. With two eligible clinicians (or six staff, under either count) billing under the TIN, well under 15, the practice is still a small practice.

Example 4: score math.

What does the proposed end of traditional MIPS mean for a therapy practice?

The CY 2027 proposed rule (CMS-1848-P, 91 FR 43842, published July 16, 2026; comments closed September 14, 2026) proposes to “phase out traditional MIPS reporting for MIPS eligible clinicians not participating in the APP beginning in the CY 2029 performance year/2031 MIPS payment year.” It also notes that traditional MIPS “will be available to clinicians through the CY 2028 performance period/2030 MIPS payment year.”

This is a proposal until finalized, but the direction is not new: CMS floated a sunset in the CY 2022 proposed rule and said in the CY 2023 final rule that MVPs would be the only pathway in the future (87 FR 70035). Other proposals:

• Rename. The Rehabilitative Support for Musculoskeletal Care MVP would become the Rehabilitative Support MVP “to better reflect the measures and activities it includes.” CMS also proposes modifications to all 27 previously finalized MVPs and three new MVPs (Diabetic Disease, Hypertension, Hospitalist).
• Core measures. Beginning with the CY 2027 performance period / 2029 payment year, the one-outcome-or-high-priority requirement would be replaced with reporting at least one MIPS core measure, or one non-core measure if no core measure applies. CMS proposes a minimum of three core measures per MVP, and an inventory of over 70 core quality measures.
• Small practices. CMS proposes that small practices be exempt from the core measure requirement, with no attestation needed if a core measure is unavailable.
• Inventory. For the CY 2027 performance period, CMS proposes 180 MIPS quality measures: 177 in traditional MIPS and three available only in MVPs.

The threshold stays at 75 through the 2030 payment year. For the proposed conversion factor and KX threshold, see the CY 2027 fee schedule post.

What to check when the CY 2027 final rule posts

As of October 22, 2026, the final rule has not been published; a Federal Register search for CMS-1848-F returns nothing. The CY 2026 final rule was published November 5, 2025 (90 FR 49266), so a final rule in early November 2026 would fit that pattern. When it posts, check:

1. Whether the CY 2029 performance year / 2031 payment year sunset is finalized, delayed, or dropped.
2. Whether the Rehabilitative Support MVP rename and measure list are finalized, and which measures are designated core measures for it (Appendix 3).
3. Whether the small-practice exemption from the core measure requirement survives.
4. Whether the 2027 KX threshold and conversion factor changed (see the CY 2027 fee schedule post).

Related reading: per-provider tracking is covered in outpatient rehab KPIs, and the documentation behind measure data in Medicare PT documentation requirements.

Reporting a functional outcome measure starts with capturing it in a structured way at evaluation and again at later visits, and the threshold math starts with knowing your Medicare patient and visit counts per provider. PrismEHR supports structured capture of functional outcome measures and per-provider reporting, plus condition-level analytics, for physical therapy practices. For the numbers to watch, see outpatient rehab KPIs and benchmarks.