2026 Compliance Checklist · MIPS + HEDIS + VBP
CMS Quality Measures Compliance Checklist 2026
For quality directors, MIPS coordinators, and compliance officers. Covers MIPS, MSSP ACO quality, HEDIS, and Hospital VBP - the four programs most US healthcare organizations manage simultaneously.
Completed: 0 / 18 items
MIPS - Quality Performance Category
Reporting
Confirm eligible clinician (EC) list for 2026 MIPS performance year - verify NPI-level eligibility in the QPP Participation Status tool. Q1 Priority
Select and lock your quality measure set - Confirm your 6 quality measures (or specialty measure set) are aligned to your specialty and reporting pathway.
Verify QCDR or QR submission pathway is contracted and the vendor is MIPS-qualified for 2026. Submission deadline is March 31, 2027 for 2026 performance year. Critical
Conduct a mid-year MIPS score estimate using Q1–Q2 data. The 2026 performance threshold is 82 points. Know your trajectory before August. Critical
Assess digital quality measure (dQM) readiness - Check EHR structured data completeness for your selected measures. dQM reporting requires clean, structured clinical data at the EHR level.
Review Improvement Activities (IA) category selections - Confirm at least 1 high-weighted or 2 medium-weighted activities are documented and attestable. Important
MSSP ACO Quality Requirements
ACO compliance
Enroll in ACO CAHPS patient experience survey - Now mandatory for all MSSP participating ACOs. Vendor engagement must be completed by early Q2 for calendar-year ACOs. Critical
Map your MSSP quality measures to the Universal Foundation set - CMS is harmonizing measures across programs; ensure your reporting aligns with the updated measure specifications.
Run a care gap analysis for your top 5 quality measures by attributed beneficiary panel - identify which patient cohorts are furthest from measure compliance before mid-year. Important
Review your MSSP benchmark expenditure and quality score trajectory together - quality performance directly affects your shared savings percentage (not just eligibility).
HEDIS - Commercial & Medicare Advantage
Plan quality
Pull HEDIS measure gap report from your health plan or PHM platform - identify your lowest-performing measures by denominator size and gap closure opportunity. Critical
Assign measure-specific owners - HEDIS performance improves when a specific care team member owns outreach for each measure (e.g., diabetic care measures → diabetes care coordinator).
Validate your HEDIS hybrid measures with a record review sample before the measurement year closes - hybrid measures (chart + claims) are where most organizations lose points to data errors.
Hospital Value-Based Purchasing (VBP)
Financial risk
Pull your current VBP Total Performance Score (TPS) projection from CMS Hospital Compare or your analytics platform and identify which domain is dragging your score. Critical
Review HCAHPS survey process - Patient experience is one of the highest-weight VBP domains. Survey distribution timing, staff scripting, and follow-up processes drive score more than clinical intervention.
Confirm HAC reduction program compliance - Hospital-Acquired Condition (HAC) reductions carry a 1% payment penalty for the bottom 25% of hospitals. Know your HAC score before Q4. Important
Model your 2026 VBP payment adjustment - Your 2028 DRG payment adjustment is set by 2026 performance. Model the financial impact now so leadership can prepare. Important
Designate an accountable quality reporting owner for each program (MIPS, MSSP, HEDIS, VBP) with defined reporting timelines - role clarity determines execution quality.