MIPS 2026 for radiation oncology: the 75-point threshold, no radiation oncology MVP, and the topped-out pain measures

Medical Billing Blog·

The 2026 MIPS performance year ends on December 31, 2026, and what a practice reports between January 4 and March 31, 2027 sets its Medicare Part B payment adjustment for all of 2028. The MIPS radiation oncology 2026 rules, taken from the CMS Quality Payment Program fact sheet and scoring guide, are these: the performance threshold stays at 75 points, the maximum penalty is 9 percent, the specialty measure set has four process measures, the two pain measures most radiation oncologists report are scored on a topped-out benchmark, and there is still no radiation oncology MIPS Value Pathway.

None of that is new policy for 2026, so it is easy to put off until February. This is a one-page summary for the person responsible for the submission.

The key numbers

Item 2026 performance year
Payment year affected 2028
Performance threshold 75.00 points, held through the 2028 performance year (2030 payment year)
Final score 0.00 to 18.75 Negative 9 percent adjustment
Final score 18.76 to 74.99 Negative adjustment between 9 percent and 0
Final score 75.00 Neutral
Final score 75.01 to 100.00 Positive adjustment, scaled for budget neutrality
Category weights Quality 30 percent, Cost 30 percent, Improvement Activities 15 percent, Promoting Interoperability 25 percent
Data completeness 75 percent of eligible cases, all payers, held through 2028
Small practice (15 or fewer clinicians) Promoting Interoperability reweighted to 0; Quality 40, Cost 30, Improvement Activities 30; 6 bonus points in Quality
Submission window January 4 to March 31, 2027

The 9 percent maximum penalty is statutory (MACRA) and applies to every payment year from 2022 on. The 75-point threshold was held rather than raised; CMS’s fact sheet gives continuity and stability for participants as the reason.

The radiation oncology measure set

CMS’s 2026 measure inventory lists four quality measures in the radiation oncology specialty set. All four are process measures.

Quality ID Title High priority 2026 collection types
102 Prostate Cancer: Avoidance of Overuse of Bone Scan for Staging Low Risk Prostate Cancer Patients Yes eCQM, MIPS CQM
143 Oncology: Medical and Radiation - Pain Intensity Quantified Yes eCQM, MIPS CQM
144 Oncology: Medical and Radiation - Plan of Care for Pain Yes MIPS CQM
226 Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention No Medicare Part B claims, eCQM, MIPS CQM

Full participation in Quality normally means six measures including one outcome or high-priority measure. CMS also treats a complete specialty measure set, every measure in the set even when the set has fewer than six, as full participation, as long as each measure meets data completeness. A practice that reports all four of these meets the requirement, though with four measures each one carries more weight. Measure 264 (sentinel lymph node biopsy for invasive breast cancer) was removed for 2026; it was in the oncology set, not this one.

Topped out: what the pain measures can earn

Measures that CMS identifies as topped out are normally capped at 7 points. For 2026, CMS finalized 19 measures that instead receive a “defined topped out measure benchmark,” an alternative scale for specialty sets with limited measure choice and a high proportion of topped-out measures. Both 143 and 144 are on the list of 19, along with 250 (radical prostatectomy pathology reporting). Most of the points require a rate above 95 percent:

Performance rate Points available
84 to 85.9 percent 1 to 1.9
90 to 91.9 percent 4 to 4.9
94 to 95.9 percent 6 to 6.9
96 to 97.9 percent 7 to 7.9
98 to 98.9 percent 8 to 8.9
99 to 99.99 percent 9 to 9.9
100 percent 10

So 143 and 144 are not capped at 7, but a practice at 97 percent on pain intensity earns roughly what a capped measure would. In the 2026 Quality Benchmarks file these measures are flagged in Column W with “Measure Not Subject to 7 Pt Scoring Cap; Topped-Out Benchmark Applied.”

Measure 143 has a detail that matters to a biller. Its radiation therapy denominator is built from the treatment management codes 77427, 77431, 77432 and 77435, and it excludes encounters conducted via telehealth (code M1426). The radiation stratum is marked not telehealth eligible; the chemotherapy stratum is. Because 77427 is billed once per five fractions on a date that may not be the visit date, the specification allows a seven-day lookback from the billing date to find the face-to-face encounter where pain was assessed. If your 77427 units are off, your 143 denominator is off.

No radiation oncology MVP

CMS finalized six new MIPS Value Pathways for 2026 (Diagnostic Radiology, Interventional Radiology, Neuropsychology, Pathology, Podiatry and Vascular Surgery), bringing the total to 27. None is for radiation oncology. The closest is Advancing Cancer Care (M0001), which has a Radiation Oncology clinical grouping containing 102, 143 and 144 plus a QCDR measure (PIMSH17, prophylactic G-CSF in low-risk chemotherapy, an inverse measure) and the cost measures Total Per Capita Cost and Prostate Cancer. For 2026 CMS removed one quality measure and three improvement activities from that MVP.

One registration rule changed for 2026. Multispecialty groups can no longer register to report an MVP as a group; they report at the subgroup, individual or APM Entity level, except that multispecialty groups with small-practice status (15 or fewer clinicians) may still register as a group. Groups attest to their own specialty composition. Traditional MIPS remains available, and for most radiation oncology practices it is still the practical option.

A scoring example

A four-clinician group reports 102, 143, 144 and 226 as MIPS CQMs through a registry. Suppose 143 and 144 come in at 100 percent (10 points each on the topped-out benchmark), 102 scores 8 and 226 scores 6. Quality is 34 of 40 points, or 85 percent, worth 25.5 of the 30-point category. If Cost scores 60 percent (18 points), Improvement Activities is complete (15) and Promoting Interoperability scores 80 percent (20), the final score is 78.5: above the threshold, but only because the pain measures were perfect. At 97 percent on 143 and 144 the same practice scores about 74 and receives a penalty. The figures are illustrative, but they show that these two measures decide whether the practice meets the threshold.

What a radiation oncology practice should do before March 31, 2027

  • Confirm who is MIPS eligible for 2026 at the individual and group level, and whether any clinician has QP status under an advanced APM, which removes them from MIPS.
  • Confirm the registry still supports 102, 143, 144 and 226 as MIPS CQMs for 2026 and ask how it handles the telehealth exclusion (M1426) on 143.
  • Pull a 143 and 144 performance report now, not in January. On the topped-out scale the difference between 97 and 100 percent is about three points per measure.
  • Reconcile 77427 units against fractions before the performance year closes, since the measure denominators are built from the management codes. Iridium Suite can create 77427 and 77336 automatically from the fraction count and attach a billing note, which keeps the management units tied to the fractions actually delivered; see the claim scrubber.
  • Check data completeness (75 percent of all eligible patients, all payers) for each measure; a measure that misses it scores zero unless you are a small practice.
  • Decide on a complete specialty set versus six measures. Four radiation oncology measures count as full participation; adding two more only helps if they score higher than the ones they would replace.
  • Review Cost feedback from the 2025 performance feedback report. Cost is 30 percent and calculated from claims; there is nothing to submit, but the feedback report is still worth reviewing.
  • Calendar the window: January 4 to March 31, 2027.

Further reading

radiation oncologyMIPSQuality Payment Program2026