2026 MIPS Changes for Pathology and Radiology: What Applies, What’s Changed, and How To Report
For the 2026 performance year, CMS has refined quality measures, expanded specialty-aligned reporting options, and continued its transition toward MIPS Value Pathways (MVPs). For pathology and radiology practices, the biggest challenge isn’t just understanding what changed; it’s understanding what applies to the practice, what doesn’t, and which reporting options make sense for diagnostic care.
Reporting Structure Continues to Shift Toward MVPs
CMS continues to steer clinicians away from Traditional MIPS and toward MIPS Value Pathways, which bundle quality, improvement activities, and cost measures around a clinical theme.
- Pathology now has a finalized Pathology MVP designed to align with diagnostic reporting, cancer protocols, and laboratory workflows.
- Radiology continues to report through specialty-aligned pathways and registry-based measures, with MVPs providing a more structured alternative to traditional reporting.
Traditional MIPS remains available, but CMS has been clear that MVPs represent the long-term direction of the program.
MIPS Value Pathways do not change how clinicians are scored or paid. Instead, they change how measures are selected and organized—shifting from flexible, clinician-chosen reporting under Traditional MIPS to more structured and narrowly-focused reporting designed to reflect real clinical workflows for a subset of measures and activities.
Performance Weighting and Scoring Continue to Tighten
For the 2026 performance year, the overall MIPS performance category weights and scoring thresholds remain unchanged. The performance threshold stays at 75 points. For many pathology and radiology practices, Cost and Promoting Interoperability are reweighted, leaving Quality and Improvement Activities as the primary drivers of MIPS performance.
MIPS Value Pathways use the same performance category weighting as Traditional MIPS, including standard reweighting rules.
Payment adjustments also remain unchanged, with final MIPS scores continuing to determine a budget-neutral adjustment of up to ±9% applied to Medicare Part B payments two years later, meaning even small scoring gaps can still translate into meaningful financial impact.
Quality Measure Changes Impact Pathology More Than Radiology
Pathology experienced the most visible measure changes for 2026, including the removal of 3 long-standing measures:
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- CAP 22 – Biopsy Reporting Time to Clinician
- CAP 38 – Prostate Cancer Reporting: Complete Analysis
- CAP 41 – Basal Cell Skin Cancer: Complete Reporting
Radiology did not experience the removal or addition of widely recognized long-standing quality measures, unlike pathology.
For both pathology and radiology, performance expectations and scoring rigor continue to increase, leaving less room for reporting gaps or workflow inconsistency.
Cost Reporting Remains Informational for Diagnostic Practices
Cost measurement continues to be challenging for pathology and radiology due to attribution limitations and indirect control over downstream care.
For 2026, cost reporting under MIPS remains largely informational:
- New cost measures introduced through MVPs provide feedback without immediate scoring impact.
- Practices are not materially affected financially by cost performance today.
That said, CMS is clearly using this period to prepare practices for broader cost accountability in future years. Reviewing cost feedback now allows diagnostic organizations to understand attribution and operational drivers before cost begins to influence reimbursement.
Promoting Interoperability Remains Largely Unchanged
There were no material changes to Promoting Interoperability (PI) requirements for pathology or radiology in 2026. Diagnostic clinicians generally remain exempt, with the PI performance category continuing to be reweighted to zero due to limited control over certified EHR technology (CEHRT) workflows.
However, CMS finalized several technical and compliance updates worth noting:
- Expanded Security Risk Analysis attestation requirements
- Mandatory use of the 2025 SAFER Guides for High Priority Practices
- A new optional TEFCA public health reporting bonus measure
- Formal adoption of a measure suppression policy for future operational disruptions
While PI remains reweighted, maintaining current documentation, cybersecurity, and compliance processes remains important for audit readiness and to support broader interoperability and data-exchange initiatives.
Improvement Activities Are Stable but More Structured
For the 2026 MIPS performance year, CMS removed 8 Improvement Activities, added 3 and modified 7. Notable changes include:
- Removal of IA_CC_1: Implementation of Use of Specialist Reports Back to Referring Clinician or Group to Close Referral Loop
- Removal of IA_CC_2: Implementation of Improvements that Contribute to More Timely Communication of Test Results
- Addition of IA_PSPA_34: Patient Safety in the Use of Artificial Intelligence
A Separate Reimbursement Change Will Affect 2026 Payments
Outside of MIPS scoring, CMS has finalized an efficiency adjustment that reduces work RVUs and intraservice time by 2.5% for most non-time-based services. This change:
- Stems from budget-neutrality and statutory efficiency requirements
- Will directly affect 2026 reimbursement under the Physician Fee Schedule
- Will disproportionately impact imaging-heavy specialties and some pathology services
Practices should model how this adjustment interacts with changes to the 2026 PFS conversion factor, technical component adjustments, and volume mix.
What Diagnostics Organizations Should Do Now
Here are practical next steps for labs, pathology practices, and radiology groups:
- Confirm your 2026 MIPS strategy: Decide whether to remain in Traditional MIPS or transition to a specialty-aligned MVP such as Diagnostic Radiology or Pathology.
- Review your measure set: Identify which Quality measures and IAs are new, changed, or removed.
- Tighten PI compliance: Validate security risk documentation, confirm use of 2025 SAFER Guides, and evaluate TEFCA participation for bonus points and interoperability alignment.
- Monitor cost feedback: Even though cost measures are stable now, use the forthcoming two-year feedback windows to monitor performance on any future measures before they carry financial weight.
- Model reimbursement impact: Include both the MIPS implications and the broader CY 2026 PFS updates, including the 2.5% efficiency adjustment.
- Educate stakeholders on MVP reporting: Understand the structural differences between Traditional MIPS and MVPs. MIPS Value Pathways do not change how clinicians are scored or paid, nor do they change the available reporting mechanisms; instead, they change how measures are selected and organized—shifting from flexible, clinician-chosen reporting under Traditional MIPS to reporting on a smaller, more cohesive subset of measures and activities.