MIPS Public Reporting Changes for 2027: New CMS Updates

CMS removed the first-year public-reporting delay for new Improvement Activities (IA) and Promoting Interoperability (PI) measures reported through a MIPS Value Pathway (MVP). 

Under the CY 2027 Medicare Physician Fee Schedule final rule (CMS-1848-F), published November 9, 2026, eligible performance information for new MVP items can appear on Care Compare during the first year those items are included — if the data meets CMS’s ordinary public-reporting standards. 

The two-year delay for new Quality and Cost measures remains untouched. Here is what the rest of this article covers:

• Which MVP data lost its first-year reporting shield
• Why CMS said the old delay barely applied to anyone
• The safeguards still protecting your displayed information
• What CMS changed in the regulatory text (and what it left alone)
• What MVP participants should actually do before the next reporting cycle

Which MVP data lost the first-year delay?

The removed delay applied narrowly — and understanding the scope prevents overreaction. CMS eliminated the categorical one-year holdback for MVP-reported performance information tied to a new item in one of four categories:

• A new Improvement Activity
• A new Promoting Interoperability measure
• A new Promoting Interoperability objective
• A new Promoting Interoperability activity

The word “new” here refers to when the item first appears in a specific MVP, not when it first enters the MIPS program. A measure that existed in traditional MIPS for years but was added to an MVP for the first time counted as “new” under the old delay rule.

What the delay used to do

Before the 2027 final rule, paragraph (c)(2) of § 414.1395 told CMS to hold back the first year of performance data when one of those four item types appeared in an MVP for the first time. The idea was to give clinicians a transition period before their data went public.

In practice, CMS found the delay had almost no effect. During the 2025 performance period, only four individual clinicians had new IA data in MVPs that would have been withheld. 

No new PI measures appeared in MVPs for 2025. Since MVP reporting began with the 2023 performance period, fewer than 1% of MIPS-eligible clinicians reporting new IA and PI information were affected by the delay.

What the delay never covered

The two-year holdback for new Quality and Cost measures lives in a separate part of the regulation. CMS did not remove it. 

If a Quality or Cost measure enters the MIPS program for the first time, CMS generally waits two years before publicly reporting that data — and that policy survived the 2027 rule without changes.

The practical consequence is clear. New IA and PI items in an MVP lost their buffer. New Quality and Cost measures kept theirs.

What did CMS actually change in the regulation?

CMS removed paragraph (c)(2) from 42 CFR § 414.1395. One paragraph, one deletion — but it shifts the default for MVP data disclosure.

Element	Before the 2027 rule	After the 2027 rule
New IA or PI item in an MVP	First-year data categorically held back	First-year data eligible for public reporting if it meets CMS standards
New Quality or Cost measure	Two-year holdback before public reporting	No change — two-year policy remains
30-day clinician preview	Required before public release	Still required
Data validation	CMS monitors and validates data	Still applies
Public-reporting locations	Care Compare and Medicare Provider Data Catalog	No new destinations added

CMS proposed this removal in CMS-1848-P (July 2026) and finalized it as proposed in the November 2026 final rule. 

The effective date is January 1, 2027. CMS’s discussion uses the CY 2027 performance period and CY 2029 MIPS payment year as its illustrative timeline.

For most clinicians, the change alters when information can become visible — not whether it will be reported at all.

What safeguards still apply?

Removing the categorical delay does not mean every new MVP item automatically lands on Care Compare. CMS kept the public-reporting standards in § 414.1395(b), which require performance information to meet several conditions before display.

Data quality requirements

CMS’s standards require data to be:

• Accurate
• Statistically valid and reliable
• Above CMS’s reliability threshold
• Comparable across collection types

CMS also evaluates whether the information is appropriate for display on public-facing clinician profiles and whether it resonates with the people using the website (patients and caregivers).

The 30-day preview window

Before CMS publishes performance information, clinicians and groups receive a 30-day preview period. During that window, they can review what CMS intends to display and raise issues through the applicable process.

The preview is not new. It existed before this rule change, and CMS specifically confirmed it remains in place. For MVP participants, the preview becomes more important now — because the first year of data for a new IA or PI item no longer gets an automatic holding period.

In practice, the 30-day preview is the last scheduled checkpoint before data goes public. Treating it as optional is the kind of mistake that only becomes visible after the information is already on Care Compare.

Why did CMS remove the delay?

CMS offered two reasons, and both are worth reading carefully.

Transparency 

CMS cited annual consumer testing showing that patients and caregivers found new IA and PI information understandable and useful for healthcare decisions. From CMS’s perspective, holding back useful information without a strong justification runs against the program’s transparency goals.

Futility

The delay was supposed to encourage MVP adoption by protecting early participants from premature public scrutiny. CMS concluded it had not meaningfully encouraged MVP participation. Fewer than 1% of MIPS-eligible clinicians reporting new IA and PI information were affected since MVP reporting began in the 2023 performance period.

Some commenters pushed back. They argued the first year gives clinicians time to adapt and that earlier reporting could create technical or workflow risks. 

CMS acknowledged those concerns but finalized the change anyway, pointing to data quality protections and the preview period as sufficient safeguards.

One commenter suggested expanding the grace period to two years instead of removing it. CMS rejected that — stating it would further reduce transparency.

What about star ratings on Care Compare?

CMS included a separate Request for Information (RFI) in the proposed rule about an alternative method for assigning star-rating cutoffs to administrative-claims quality measure scores on clinician profiles. 

The approach involved a standard-deviation-based methodology.

In the final rule, CMS thanked commenters and said it may consider the feedback in future rulemaking. The star-rating methodology for 2027 did not change based on this RFI.

Keep these two topics separate. The MVP public-reporting delay removal is finalized policy. The star-rating method is an open question for potential future rulemaking — nothing more.

What should MVP participants do now?

The practical takeaway fits into a short checklist, but the thinking behind it deserves a sentence. 

MVP participants should assume that first-year IA and PI data may be publicly visible after the applicable reporting cycle — not that it will be, but that the categorical protection is gone.

The most underestimated risk here is not the rule itself — it is the assumption that “new” MVP items still have a quiet first year. That assumption is now wrong.

Your data is public whether you prepared for it or not

MIPS public reporting creates a direct connection between your billing accuracy, measure attestations, and what patients see on Care Compare. 

A single coding error or missed attestation can sit on your public profile for years. MedHeave operates inside your practice’s revenue cycle to catch problems before they compound.

• Denial management with documented 72-hour response windows
• Claim submission tracking with payer-specific billing accuracy checks
• Coding accuracy reviews by AAPC-certified coders (CPC, CRC, CPMA)
• Credentialing and enrollment management to prevent gaps that affect reporting
• Weekly and monthly reporting that surfaces billing issues before they reach CMS

Frequently asked questions

Here are some commonly asked questions on this topic: