As the Centers for Medicare & Medicaid Services (CMS) moves toward finalizing the proposed 2026 Medicare physician payment rule, the AMA is highlighting this opportunity to make necessary changes to the Merit-based Incentive Payment System (MIPS).
MIPS has failed to live up to its goals to deliver better health outcomes for Americans and lower avoidable costs in the system; meanwhile, physician practices face high costs to stay compliant with the program, with small and rural practices disproportionally impacted.
In January, President Donald Trump issued an executive order titled, “Unleashing Prosperity through Deregulation,” with the aim of promoting “prudent financial management and alleviate unnecessary regulatory burden,” AMA CEO and Executive Vice President John J. Whyte, MD, MPH, wrote to CMS Administrator Mehmet C. Oz, MD. “There is no better way to fulfill this directive than by reducing the morass of complicated rules and requirements that define the ineffective MIPS program.”
The comprehensive comments letter (PDF) is in response to the nearly 2,000-page proposed 2026 Medicare physician payment rule that CMS unveiled earlier this year.
In the comments, the AMA said it is appreciative that CMS has been responsive and the physician organization offers a number of proposed improvements, including keeping the performance threshold at 75 points for the next three performance periods to provide continuity and stability to physicians. It also commends CMS for adopting the AMA’s recommendations on an alternative framework for structuring MIPS Value Pathways (MVP) by proposing “Clinical Groupings” within MVPs, as a nice first step for refining MVPs.
The comment letter also tells CMS that the AMA is “disappointed” that the proposed 2026 Medicare physician payment schedule doesn’t address MIPS data-access issues that result in physicians not receiving timely data about their performances. It can take six to 18 months after a physician has treated a Medicare patient to get quality and cost measures data.
“Without this information at any point during the actual performance year, physicians have no way to understand gaps in care and identify opportunities to improve health outcomes, reduce variations in care delivery, or eliminate avoidable services—all steps that can improve quality and lower costs for patients and the Medicare program,” Dr. Whyte wrote.
Reforming Medicare pay is important because since 2001, Medicare physician pay has remained virtually flat while the cost of running a medical practice catapulted 59%. When adjusted for inflation, physician pay declined 33% between 2001 and 2025, an AMA analysis shows.
The AMA is leading the charge to reform the Medicare payment system.
Nine pieces of red tape to cut
The AMA tells CMS that there are several positive changes in the proposed 2026 Medicare physician payment schedule, but that “there is more red tape to be cut.”
Here are nine key recommendations that Dr. Whyte outlined in the AMA comments:
- MVP clinical grouping must prioritize alignment of quality and cost measures and be clinically relevant, there should be no one-size-fits-all approach to MVPs.
- Incentivize the reporting of MVPs instead of mandating it; do not support sunsetting of traditional MIPS.
- Maintain a robust portfolio of MVPs and quality measures, including accepting new measures. Measurement burden increases when there are too few measures in the program and physicians are forced to report for the sake of reporting and compliance.
- At a minimum, establish a maximum number of MVPs for multi-specialty groups and develop guidelines for choosing MVPs for multi-specialty groups, such as MVPs based on the highest volume of service and/or largest number of clinicians. Requiring group practices to form multiple subgroups to report MVPs will significantly add to compliance burdens.
- Provide an option to apply facility-based scoring to MVP participants that otherwise qualify for this scoring option in traditional MIPS to encourage alignment of quality improvement efforts between physicians and facilities where they provide care.
- Realize that many MVPs now available to physicians don’t reflect physicians’ input. For example, the Surgical Care MVP lumps unrelated surgical specialties together— general, colorectal, neurological and thoracic surgeons. This doesn’t help to better inform patients where to seek care.
- Reduce the unnecessary quality measure reporting burden and eliminate arbitrary scoring rules.
- Remove total per capita cost from MIPS, or at a minimum, from any MVP that also includes an episode-based cost measure.
- Maximize electronic health record use and other emerging technologies, while minimizing wasteful “check the box reporting exercises.” The AMA supports CMS efforts to transition to digital quality measurements.
The AMA has developed a detailed summary of proposed 2026 Medicare Physician Fee Schedule (PDF) and is highlighting the problematic efficiency-adjustment and practice-expense payment proposals (PDF) in the CMS rule.
