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It’s early October, and the MIPS performance year has less than three months left. Whatever your EHR has captured by December 31 is what you’ll report, and CMS accepts no late submissions after the March 31, 2027 filing deadline.
Most practices think of MIPS as a March problem. It’s really a November problem, because that’s when you find out whether the data is any good.
The Short Version: For the 2026 performance year, submission is expected to run January 2, 2027 through March 31, 2027 at 8 p.m. ET, with no late filing. The deadline rarely sinks a practice. What does is discovering in March that the EHR data is incomplete or doesn’t match CMS measure logic. Validate in Q4, and bring in an EHR consultant if your reports don’t reconcile.
Key Takeaways
- The performance year runs January 1 to December 31. You submit by March 31 of the following year.
- The Improvement Activities (IA) start date has probably passed. One guide lists October 3, 2026 as the last day to start a 90-day IA period.
- Promoting Interoperability (PI) needs 180 continuous days of certified EHR data in 2026.
- The best use of a consultant is data validation before submission, not a last-week rescue.
The Dates That Matter
| Date | What happens |
|---|---|
| Apr 1 – Jun 30, 2026 | CAHPS for MIPS survey registration (closed) |
| Apr 1 – Nov 30, 2026 | MVP registration window (still open) |
| Oct 3, 2026 | Last day to start a 90-day IA period, per one vendor guide |
| Dec 31, 2026 | Performance year ends; some hardship exception deadlines fall here, per vendor summaries |
| Jan 2, 2027 | Submission window expected to open |
| Mar 31, 2027, 8 p.m. ET | Submission closes |
Sources: CMS’s QPP timeline and vendor summaries. One vendor lists the opening as January 4. Confirm the exact day on QPP before you plan around it.
Reality Check: Vendors warn that missing the window means a zero score and an adjustment of up to 9% on Medicare Part B. That framing comes from vendor guides. CMS applies adjustments under its final scoring methodology, so read your own payment-year notice instead of trusting a sales page’s worst case.
What You Need Out of the EHR
Pull these now, not in March:
- Quality measure data for the full year, built from encounters, diagnoses, orders, results, and medications.
- PI data from certified EHR technology covering at least 180 continuous days in 2026.
- IA documentation. A 90-day period applies in many cases.
- Patient volume and clinician attribution, with numerator and denominator support. Cross-check these against claims and registry exports.
- Specialty-specific measure fields. Vendors note that measure selection and benchmark alignment materially affect your final score.
Where Submissions Break
The ranking pages mostly cover dates. Here’s what they skip.
Exports that don’t match the spec. Your EHR’s quality report and the CMS measure specification are two different documents. Midyear template changes, new workflows, or revised codes can break the mapping without anyone noticing.
Denominator mismatches found late. If you validate in March, you have weeks to fix problems that took months to create.
The PI clock. The 180 days have to fit inside the calendar year. If your certified EHR changed or went live this year, check your dates today.
Mixing up two calendars. The performance year is calendar 2026. The submission window is 2027. Staff confuse them constantly.
Pro Tip: Run a full test export in November. Compare the denominators to your claims. A mismatch you see in November is a bug. In March it’s a crisis.
Does Your Region Change the Timing?
The research found no regional pattern. The deadline is federal, so a practice in Seattle and one in San Diego face the same clock. What differs is your EHR vendor, your specialty, and how your workflows are built. Each of those affects your measures.
If you want someone local, browse EHR consultants in Seattle or San Diego. For MIPS data work, though, a remote consultant who knows your EHR platform often beats a nearby generalist.
When a Consultant Earns Their Fee
Hire one if:
- Your exports don’t reconcile with claims.
- Your measure choices were never reviewed against your specialty.
- Your EHR was replaced or heavily reconfigured this year.
- Nobody on staff can explain how the PI numbers are calculated.
The useful scope is data cleanup, validation, and submission support. Vendor guidance is also shifting toward end-to-end services rather than one-time deadline help.
On cost, our field notes show wide variation. One listed consultant posts $150 for a one-hour consultation, and another says most engagements start at $5,000. Price an audit first, not a full engagement. See how much an EHR consultant costs and how to choose one. The complete guide to EHR consultants covers the rest.
By the Numbers
According to EHRIntel directory data (see industry statistics):
- Verified providers listed: 184
- States covered: 42
- Most providers: Texas (25), California (17), Florida (16)
- Average years in business, where published: 22.7
Practical Bottom Line
- This week: Confirm which MIPS reporting path you’re on and whether your IA period started in time.
- By November 30: Decide on an MVP if you’re considering one. Registration closes then.
- November: Run a test export and reconcile it against claims.
- December: Fix gaps and confirm your PI period covers 180 days.
- January 2027: Submit early. Don’t wait for March 31.
If step 3 turns up problems you can’t explain, that’s the moment to call an EHR consultant, not March.
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Nick built this directory to help medical groups find credentialed EHR consultants without wading through vendors who mostly want to sell software subscriptions — a conflict of interest he ran into when trying to help a family member’s practice navigate a painful EMR migration.
