3 mistakes that cost practices MIPS payment adjustments

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Medicare's Merit-Based Incentive Payment System (MIPS) ties your Medicare Part B reimbursements directly to how your practice performs and reports each year.

Score well, and you earn a positive payment adjustment. Score poorly (or skip participation entirely), and you take a financial hit. For 2026, that penalty reaches up to -9% for clinicians who scored below 18.75 points in the 2024 performance year.

MIPS penalties rarely come from carelessness. More often, they come from the same avoidable mistakes that trip up practices year after year. Here are three to watch out for.

1. Not tracking year-to-year MIPS requirement changes 

MIPS isn't static. CMS updates performance categories, measure specifications, data completeness requirements, and benchmarks annually through the Medicare Physician Fee Schedule final rule.

A change to how a category is weighted, or a shift in the performance threshold, can affect your final score even if you participate the same way as the year before.

Understanding what's required before the performance year begins is the first step to avoiding MIPS penalties.

If no one in your practice is actively monitoring CMS updates through the Quality Payment Program (QPP) portal, your specialty society, or the annual final rule, that's a gap worth closing. By the time most practices notice a requirement has changed, they've already reported to an outdated framework.

Preparing ahead of time is how you keep operations running smoothly. If you're not ready, you'll lose payment adjustments. Simple as that.

2. Leaving reporting until the last minute

Practices need to stay on top of MIPS requirements throughout the year, not just during the submission window.

MIPS performance data accumulates across 12 months. Most quality measures require you to meet data completeness thresholds across a substantial share of your eligible patient population, so a "just-in-time" approach creates real risk: documentation gaps, incomplete data, and lower scores that show up only when it's too late to fix them.

Internal audits should happen regularly. If staff let documentation standards slip, if your EHR isn't capturing the right data points, or if reporting to registries falls through the cracks mid-year, your final score will reflect it. By the time the submission window opens, you should already have a clear sense of where you stand.

Some EHR vendors like ModMed offer MIPS advisory services for their users. Be sure to check whether yours offers something similar.

3. Assuming last year's participation carries over

Participating in MIPS one year and avoiding MIPS penalties does not protect you the next. CMS requires annual participation, and your payment adjustment reflects your performance from two years prior.

As the intro suggests, your 2024 results determine your 2026 Medicare payments. That lag means inaction this year shows up on your bottom line in two.

Performance thresholds also shift. For the 2026 payment year, the neutral adjustment threshold is 75 points. What earned a neutral or positive result in a prior year may no longer clear that bar.

Your practice put considerable time and resources into meeting MIPS requirements. Annual submission, consistent documentation throughout the year, and early attention to each performance year's updated requirements are what keep MIPS penalties off the table. Don't let that effort go to waste.

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Samantha Williams

About the author…

Samantha Williams’ EHR expertise stems from three years of medical billing for a large physician practice in New York City. She trains new hires to use a medical billing and EHR system and writes appeals for denied neurosurgical procedures, resulting in additional insurance payment.

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Samantha Williams