CY 2027 MPFS Proposed Rule: Key MIPS and Quality Reporting changes for occupational therapy

On July 14, 2026, the Centers for Medicare & Medicaid Services (CMS) released the proposed Calendar Year (CY) 2027 Medicare Physician Fee Schedule (MPFS), which outlines changes to Medicare Part B payment policies affecting occupational therapy (OT) and other outpatient services. In addition to payment and coverage policies, the MPFS proposed rule includes several important updates to the Quality Payment Program (QPP) and the Merit-based Incentive Payment System (MIPS), which continue to shape quality reporting requirements and payment adjustments for eligible OT practitioners. This article summarizes the proposed MIPS and QPP changes most relevant to occupational therapy, including CMS's continued transition to MIPS Value Pathways (MVPs), updates to quality measures and improvement activities, and other reporting policy changes that may affect OT participation in Medicare quality programs. For further information on technical and payment proposals, please read AOTA’s article From Payment to Practice: What OT Practitioners Need to Know About the 2027 Medicare Physician Fee Schedule Proposed Rule.

A focus on transition to MVPs

As the Quality Payment Program enters its tenth year, CMS is proposing a significant shift in MIPS participation by continuing its transition away from traditional MIPS reporting and toward MIPS Value Pathways (MVPs). CMS proposes to sunset traditional MIPS reporting beginning with the CY 2029 performance period/2031 MIPS payment year, after which clinicians participating in MIPS (and not reporting through the APM Performance Pathway) would be required to report through an MVP.

For occupational therapy, the proposed transition raises important concerns. While OT practitioners currently have access to the Rehabilitative Support MVP, it remains the only MVP specifically available to the profession, and its quality measures do not fully reflect the breadth of OT practice across settings, populations, and specialty areas. As CMS moves toward MVP-only reporting, AOTA is concerned that occupational therapy practitioners may face limited opportunities to select measures that accurately represent the outcomes and value of OT services. Continued development of additional OT-relevant measures and MVP options will be critical to ensuring meaningful participation in MIPS and avoiding situations in which practitioners are required to report on measures that are not reflective of their practice.

CMS is also proposing three new MVPs focused on Diabetic Disease, Hypertension, and Hospitalist Care and would rename the current Rehabilitative Support for Musculoskeletal Care MVP to the broader Rehabilitative Support MVP.

Proposed changes to MIPS Performance Categories

In addition to its broader proposals related to MVPs and the transition away from traditional MIPS reporting, CMS is proposing several updates to the individual MIPS performance categories. These changes would affect the measures, activities, and reporting requirements used to assess clinician performance and determine MIPS scores. The proposals include updates to the Quality Performance Category, new Improvement Activities focused on prevention and wellness, operational changes within the Cost Performance Category, and revisions to the Promoting Interoperability requirements. Together, these changes reflect CMS's continued emphasis on outcomes, prevention, health promotion, and streamlined reporting, while also presenting new opportunities and challenges for occupational therapy practitioners.

Quality Performance Category

CMS is proposing several changes to the MIPS Quality Performance Category. Most notably, CMS would establish a new MIPS Core Measure designation and require clinicians to report at least one applicable core measure rather than the current requirement to report an outcome measure or high-priority measure when an outcome measure is unavailable. CMS would also eliminate the high-priority measure designation and related reporting requirements. Several measures commonly used by rehabilitation providers are proposed as MIPS Core Measures, increasing their importance for future reporting under traditional MIPS and MVPs.

CMS also proposes to add new functional outcome measures for patients with neck, upper extremity, back, lower extremity, and knee impairments that use broader, nonproprietary assessment tools (including PROMIS measures). These measures would replace similar existing measures and be incorporated into the Rehabilitative Support MVP.

Additional OT-relevant measure updates include modifications to:

• Documentation of Current Medications in the Medical Record
• Screening for Depression and Follow-Up Plan
• Dementia: Education and Support of Caregivers
• Assessment of Cognitive Impairment/Dysfunction for Patients with Parkinson's Disease
• Preventive Care and Screening: High Blood Pressure and Follow-Up Documented

AOTA will further review these updates to assess the impact of the modifications and provide additional details if advocacy is needed.

Improvement Activities Category

CMS is proposing several new Improvement Activities that reflect the agency's growing emphasis on prevention, nutrition, wellness, and healthy lifestyle interventions. The proposed activities include systematic screening and intervention for nutrition and other health-related social needs, advance care planning conversations, and lifestyle approaches to diabetes management. CMS is also proposing a new Advancing Health and Wellness subcategory to highlight these types of activities within MIPS.

Cost Performance Category

CMS is not proposing to add or remove any cost measures for the CY 2027 performance period/2029 MIPS payment year. The agency is proposing only operational updates to the existing cost measure inventory. While the proposal does not make substantive changes to the Cost Performance Category, cost measurement remains a challenge for OT practitioners, as they currently have only one cost measure for which they are the attributed clinicians, resulting in limited opportunities to participate meaningfully. As CMS continues its transition toward MVPs and eventually sunsets traditional MIPS reporting, ensuring that cost measures appropriately reflect OT services and accountability remains an ongoing concern for the profession. As in previous years, AOTA will continue to advocate for the development of cost measures that more accurately reflect the value and impact of OT.

Promoting Interoperability (PI) Category

CMS is proposing several changes to the Promoting Interoperability category, including updates to the definition of Certified Electronic Health Record Technology (CEHRT), as well as other burden-reducing proposals. CMS would remove several EHR certification requirements that are no longer considered necessary, reducing administrative burden for health IT developers. If finalized, the streamlined CEHRT requirements may reduce the administrative burden on rehabilitation EHR vendors and make it easier for specialty EHR products to maintain certification while continuing to support the Promoting Interoperability reporting requirements. AOTA will continue to monitor these changes and their potential impact on rehabilitation technology vendors and therapy providers.

Take Action: Protect Occupational Therapy's Inclusion in MIPS

The CY 2027 proposed rule includes significant changes to MIPS that could affect how occupational therapy practitioners participate in quality reporting. AOTA encourages OT practitioners and organizations that participate in MIPS to share their perspectives with CMS, particularly regarding measure availability, MVP options, and the ability of current reporting programs to accurately reflect the full scope and value of occupational therapy services.

Visit AOTA's Legislative Action Center to access our advocacy resources and submit comments to CMS by 5:00 p.m. ET on September 14, 2026. Be sure to reference CMS-1848-P in your submission. Your feedback can help ensure that future MIPS policies support meaningful participation by occupational therapy practitioners and appropriately recognize the outcomes and quality of OT services.