MIPS in 2026: A conversation with MIPS expert Holly Black

Holly Black has been in ophthalmology practice management for more than 35 years, long enough to have survived meaningful use, the Physician Quality Reporting System and every iteration of Medicare's quality reporting apparatus since.

These days, as product manager for regulatory affairs and compliance at Sightview Software, she spends most of her time helping practices navigate the Merit-based Incentive Payment System, or MIPS — a program she describes with equal parts expertise and affection. She’s been called a "MIPS geek guru."

Medical Economics sat down with Black to go through what's actually new in 2026, how MIPS Value Pathways (MVPs) are playing out in real practices and what physicians and administrators can realistically do right now to protect their Medicare revenue.

The biggest change for large practices this year is the removal of the 3-point scoring floor in the quality category. Previously, practices of 16 or more physicians could count on a minimum of 3 points per measure even if they didn't meet the 75% data completeness threshold. That floor is gone for 2026. Small practices still have it, but larger groups need to pay closer attention to completeness and benchmark performance than they may have in the past.

In the Promoting Interoperability category, the security risk analysis requirement has tightened. A simple yes-or-no attestation is no longer sufficient. Practices must now have a documented plan of action for any vulnerabilities identified in their electronic health record (EHR) security assessment. Black also flagged the SAFER Guides update — practices still using the 2016 version need to switch to the 2025 version.

On MVPs, Black's message was measured. The Centers for Medicare & Medicaid Services (CMS) is positioning them as the future of the program, potentially mandatory as early as 2029, and practices can now opt in and have their higher score — traditional MIPS or MVP — applied to their payment adjustment.

Based on what she's seen in practice so far, most practices are scoring about the same under both. "If we are seeing that in ophthalmology, hopefully you will see that across other specialties as well," she said.

The practical upside is that MVPs require reporting on four quality measures instead of six, and those measures are specialty-specific — which simplifies the process for most, though subspecialties can still find themselves without a clean fit.

The mistakes she keeps seeing after nearly a decade of the program: missed mapping deadlines with registries, ignored data validation, EHR transitions handled too late in the year and practices that leave everything to one administrator who isn't in the clinical workflow and can't catch documentation errors at the source.

Her fix is consistent: build a MIPS team. "It takes a village to raise a child," she said. "I tell my clients it takes a village to do well in MIPS."

For practices with limited bandwidth, Black's framework is straightforward. Run reports quarterly at a minimum, preferably monthly. Know your key deadlines — registry mapping typically closes Sept. 30. Focus on quality and cost, which together account for 60% of the composite score. Use structured EHR fields rather than free text wherever possible, and don't assume that a measure that worked last year works the same way this year. The documentation requirements for improvement activities, in particular, shift quietly from one year to the next.

Her bottom line for any practice trying to get ahead of year-end stress: "A quick meeting over lunch or at the end of the day to say, 'We are not doing well on this measure; here is what we need to do to improve it,' goes a long way. It only takes a few hours a month."