- 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.
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
MIPS Value Pathways (MVPs): Specialty alignment bridge
Ambulatory Specialty Model (ASM): Mandatory, condition-focused next step
- Heart failure cohort: ~3,400 clinicians (1,160 TINs)
- Low back pain cohort: ~5,200 clinicians (2,400 TINs)
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 |