CMS Proposes Mandatory MVP Reporting for Ophthalmology Practices Starting 2029

What Is the Mandatory MVP Proposal for Ophthalmology?

As of September 2026, the CMS CY 2027 Physician Fee Schedule proposed rule (CMS-1848-P) includes a provision to officially sunset traditional MIPS and require all ophthalmology practices to report through a MIPS Value Pathway beginning with the 2029 performance year and the 2031 payment year. For ophthalmologists, the designated pathway is the Complete Ophthalmologic Care MVP, which focuses on cataract, glaucoma, retinal detachment, and general ocular care outcomes.

Mandatory, not optional: CMS has proposed converting MVP reporting from voluntary to mandatory, which would eliminate the traditional MIPS reporting pathway ophthalmology practices have relied on since MACRA took effect.

Comment deadline: The 60-day public comment period closes September 14, 2026. Ophthalmology practices and specialty societies can still submit feedback to CMS through regulations.gov before the final rule is expected in November 2026.

Preparation window: Even though mandatory reporting would not begin until the 2029 performance year, CMS and the American Academy of Ophthalmology both recommend that practices begin voluntary MVP reporting now to identify workflow gaps before the transition becomes required.

What Changed in the CMS 2027 Proposed Rule

On July 14, 2026, CMS released the CY 2027 Physician Fee Schedule proposed rule with several provisions affecting ophthalmology. Alongside the widely discussed 2027 Medicare payment changes for ophthalmology, the proposed rule includes a structural shift in how CMS measures quality performance. For the first time, CMS has formally proposed sunsetting traditional MIPS and making MVP reporting the sole pathway for all eligible clinicians.

The timeline CMS laid out is the 2029 performance year, with payment adjustments based on MVP scores beginning in 2031. CMS has signaled this direction in prior rulemaking cycles, but past proposals stopped short of setting a concrete sunset date. The 2027 proposed rule goes further by naming the performance year, establishing the framework, and modifying existing MVPs to prepare for mandatory adoption.

The proposed rule also introduces a new core measure requirement for MVP reporting. Beginning in 2027, at least one of the four required quality measures submitted through an MVP must be a designated core measure. If none of the core measures apply to a specific clinician’s scope, CMS would allow an attestation to that effect. Small practices would be exempt from the core measure requirement. This is a meaningful addition that changes how ophthalmology practices select and report their quality measures going forward.

Who Does the Mandatory MVP Apply To?

The mandatory MVP transition would apply to every MIPS-eligible clinician who is not already reporting through the APM Performance Pathway. In ophthalmology, that covers the majority of practicing ophthalmologists and optometrists billing Medicare Part B above the low-volume threshold. As of September 2026, the MIPS low-volume threshold excludes clinicians who bill $90,000 or less in Medicare Part B allowed charges, see 200 or fewer Medicare Part B patients, or provide 200 or fewer covered professional services to Medicare Part B patients during the determination period.

Practices that currently report through traditional MIPS by selecting from the full measure inventory would lose that option once the sunset takes effect. The only remaining pathways would be the relevant specialty MVP or the APM Performance Pathway for clinicians participating in a qualifying advanced alternative payment model.

In our experience matching providers with billing partners, one of the most common gaps we see is practices that have been on autopilot with traditional MIPS for years. They report the same six measures, hit the performance threshold, and move on. The mandatory MVP changes that equation because the measure set narrows, the measures themselves are more clinically specific, and the reporting structure ties quality to cost and improvement activities in a tighter bundle than traditional MIPS ever required.

What Is the Complete Ophthalmologic Care MVP?

The Complete Ophthalmologic Care MVP is the MIPS Value Pathway designated for ophthalmology and optometry. CMS finalized it for voluntary reporting beginning with the 2025 performance year. The MVP focuses on what CMS describes as meaningful outcomes in cataract, glaucoma, retinal detachment, and broadly applicable ocular care.

Under the 2027 proposed rule, CMS is modifying the ophthalmology MVP by removing certain measures and adding core measure designations. Specifically, CMS proposes removing the Diabetic Macular Edema Loss of Visual Acuity measure (IRIS13) from the MVP. Quality measures retained or added include primary open-angle glaucoma optic nerve evaluation, cataract surgery with intraocular lens power calculation, and several broadly applicable patient safety and care coordination measures. The exact final measure set will be confirmed when the final rule publishes, expected by November 2026.

The MVP structure requires clinicians to report across four MIPS categories in a more focused way than traditional MIPS allows. Quality measures come from a curated list rather than the full inventory. Cost measures are linked to ophthalmology-relevant episode groups. Improvement activities are drawn from a subset relevant to eye care. And promoting interoperability requirements remain largely the same but are reported within the MVP framework.

One question we hear constantly from practice managers is whether the MVP requires different EHR configurations or registry setups. The answer depends on how the practice currently reports. Practices using the IRIS Registry, which the American Academy of Ophthalmology designed specifically for ophthalmology MIPS reporting, may have a smoother transition because the registry already maps to several MVP-eligible measures. Practices reporting through claims or a non-specialty registry will likely need to evaluate whether their current reporting method supports the narrower MVP measure set.

How Does This Differ From Traditional MIPS?

The structural differences between traditional MIPS and the Complete Ophthalmologic Care MVP affect how practices select measures, which measures count, and how the final score is weighted. The table below summarizes the key differences as of September 2026.

Feature	Traditional MIPS	Complete Ophthalmologic Care MVP
Quality measures required	6 from full inventory	4 from curated ophthalmology list
Core measure requirement	One outcome or high-priority measure	One designated core measure (proposed 2027)
Cost measures	Assigned automatically by CMS	Linked to ophthalmology episode groups
Improvement activities	Choose from 100+ activities	Choose from subset relevant to eye care
Measure flexibility	Broad selection across specialties	Narrowed to cataract, glaucoma, retina, ocular care
Reporting pathway status	Proposed sunset after 2028 performance year	Mandatory starting 2029 performance year (proposed)
Registry alignment	Any qualified registry or claims	IRIS Registry or compatible MVP-eligible registry

The narrower measure set is the most operationally significant change. Under traditional MIPS, a practice could select from a broad pool and often gravitate toward measures that were easiest to document rather than most clinically relevant. The MVP removes that option. Practices will need to report on measures tied directly to ophthalmology outcomes, which means documentation habits, coding accuracy, and clinical workflows all need to align with the specific measure specifications CMS has designated.

What Happens if Your Practice Does Not Prepare?

MIPS payment adjustments are not optional. Eligible clinicians who fail to report or score below the performance threshold face a negative payment adjustment applied to all Medicare Part B claims for the corresponding payment year. For the 2029 performance year, that adjustment would hit in 2031.

The maximum negative adjustment under MIPS is currently 9% of Medicare Part B payments. For a mid-size ophthalmology practice billing $1.5 million annually in Medicare, a 9% penalty represents $135,000 in lost revenue over a single payment year. Even a smaller shortfall that drops a practice below the performance threshold results in a negative adjustment that compounds when layered on top of the conversion factor reductions already affecting ophthalmology. The broader 2027 fee schedule changes are already tightening margins.

Across the billing companies we vet, a recurring pattern is practices that treat MIPS as a back-office checkbox rather than a revenue protection strategy. The MVP transition raises the stakes because the pathway is more structured, the measures are more clinically specific, and the scoring methodology ties quality to cost more tightly. A practice that has been coasting on traditional MIPS with generic measures will likely find that its existing workflows do not map cleanly to the MVP without deliberate adjustments.

Steps to Prepare for Mandatory MVP Reporting

Ophthalmology practices do not need to wait until 2029 to act. CMS and the AAO both recommend voluntary MVP reporting now to surface gaps before the pathway becomes required. Here is what to prioritize, in order.

1. Check your MIPS eligibility for the current performance year. Use the CMS QPP Participation Status Tool to confirm whether each provider in your practice meets the low-volume threshold. Eligibility can change year to year based on billing volume and patient count.

2. Review the Complete Ophthalmologic Care MVP measure set. Identify which quality measures your practice can report on today and which would require documentation or workflow changes. Pay close attention to the proposed core measure requirement.

3. Evaluate your registry or reporting method. Determine whether your current reporting tool supports MVP-eligible measures. The IRIS Registry is purpose-built for ophthalmology MIPS reporting. If you use a different registry or report via claims, confirm MVP compatibility.

4. Align clinical documentation with measure specifications. Each quality measure has specific data elements and documentation requirements. Cataract surgery outcomes, glaucoma optic nerve evaluations, and patient safety measures all require structured documentation that may differ from what your templates currently capture.

5. Run a voluntary MVP submission alongside your traditional MIPS report. CMS allows dual reporting. Submitting through the MVP voluntarily will not negatively affect your MIPS payment adjustment as long as you also report traditional MIPS. This is the safest way to test your readiness.

6. Model the financial exposure. Calculate what a negative payment adjustment would cost your practice in the 2031 payment year. Compare that against the cost of aligning your workflows and reporting now. For most practices, the math favors early preparation.

7. Submit a public comment to CMS before September 14, 2026. If the mandatory MVP timeline or the proposed measure changes affect your practice, the comment period is the mechanism to influence the final rule. Comments can be submitted through regulations.gov under docket CMS-1848-P.

Common Misreadings of the MVP Transition

Several misunderstandings are already circulating about what the mandatory MVP means. Clarifying them now prevents costly mistakes later.

The most common misreading is that mandatory MVP reporting starts in 2027. It does not. The 2027 proposed rule proposes that mandatory reporting begin with the 2029 performance year, which means the 2031 payment year. The 2027 performance year will still offer both traditional MIPS and voluntary MVP reporting.

Another frequent error is assuming that the MVP requires entirely new measures that a practice has never reported. In reality, several measures in the Complete Ophthalmologic Care MVP overlap with measures available in traditional MIPS. The difference is that the MVP limits the selection to a curated list, so a practice cannot substitute an unrelated measure just because it is easier to document.

A third misreading involves the interaction between the MVP transition and other proposed rule changes. The proposed modifier 25 same-day payment reduction, the G2211 modifier transition, and the conversion factor decrease are all separate provisions in the same proposed rule. They affect revenue differently than the MVP transition affects quality reporting. Treating them as one combined threat leads to the wrong response. The revenue provisions require financial modeling. The MVP transition requires workflow and documentation changes. Providers often come to us after conflating these issues and not knowing where to start, and the first thing a strong billing partner does is separate the action items by category.

Frequently Asked Questions

Next Steps

If your practice has not reviewed the Complete Ophthalmologic Care MVP measure set, start there. The AAO maintains current documentation on the MVP through its IRIS Registry and advocacy pages.

For practices already managing the complexity of ophthalmology billing and coding changes, aligning quality reporting with a billing partner who understands both revenue cycle and MIPS requirements is the most efficient path forward.

The comment period for the CMS 2027 proposed rule closes September 14, 2026. If the mandatory MVP timeline or the proposed measure changes affect how your practice operates, submit your comment through regulations.gov before that deadline.