April 14, 2026
CMS MIPS Quality Measures are “Topped Out” when Over 90% of Eligible Physicians Have Never Reported their Performance
New Neiman Institute research finding raises questions about CMS cap-and-removal policy that limits financial upsides for nearly half of quality measures
New research from the Harvey L. Neiman Health Policy Institute found that most Merit-Based Incentive Payment System (MIPS) quality measures designated as “topped out” by the Centers for Medicare & Medicaid Services (CMS) were reported by only a small fraction of eligible physicians, suggesting these measures may not reflect consistently high performance across clinicians. Topped out measures are capped at 7 points, which reduces the financial upside for reporting high quality. CMS designates measures as “topped out” with the rationale that meaningful improvement is no longer possible.
The study, published today in Health Affairs Scholar, included 643,558 physicians across 37 specialties who reported 275 MIPS quality measures from 2017 through 2023. Of these measures, 137 (49%), or nearly half, were designated as topped out. More than half of topped-out measures were reported by fewer than 5 percent of physicians in relevant specialties (i.e., eligible physicians) at the time of their topped-out designation, and only 11 topped-out measures were reported by a majority of physicians. The median reporting rate across all topped-out measures was 7.1 percent.
“Our findings show that many MIPS quality measures were deemed topped out based on performance reported by a relatively small subset of eligible physicians,” said YoonKyung Chung, PhD, Principal Economic and Health Services Researcher at the Neiman Institute. “This raises concerns about whether topped-out designations accurately reflect quality performance across the broader clinician population.”
The study also found substantial variation across specialties in reporting rates, the availability of quality measures and the proportion designated as topped out. Median specialty-specific reporting rates ranged from 0.6 percent in geriatric medicine to 40.4 percent in pathology. In more than 70 percent of specialties, over half of available specialty-relevant measures were topped out by 2023, leaving clinicians with limited options to achieve maximum quality scores using measures relevant to their practice. Additionally, several specialties, including diagnostic radiology, radiation oncology, anesthesiology, and surgery, had very few specialty-relevant measures remaining that were eligible for full scoring.
Measure capping and removal also have broader implications for the MIPS program. CMS and specialty organizations have invested substantial resources in developing quality measures. The premature removal of measures with low reporting rates may limit opportunities for quality improvement among clinicians who have not previously reported them, discourage maintenance of quality among reporting clinicians, and incur unnecessary cost to developing replacement measures.
“MIPS is intended to reward clinicians for delivering high-quality care to Medicare beneficiaries and to promote continuous improvement,” said Elizabeth Rula, PhD, Executive Director of the Neiman Institute. “Nineteen additional measures were topped out in 2026. This study highlights opportunities to refine CMS policies in ways that better align incentives with meaningful and ongoing quality improvement.”
“When few full-score, specialty-relevant measures are available, it undermines the ability of MIPS to meaningfully compare performance and incentivize improvement in areas most relevant to patient care,” said Lauren P. Nicola, MD, Chief Executive Officer of Triad Radiology Associates and a co-author of the study. “Alternative approaches—such as applying topped-out and cap-and-removal policies at the clinician or entity level rather than universally—could preserve incentives for continued quality improvement while maintaining flexibility within the program.”