The MIPS submission deadline for a performance year is typically March 31 of the following year, at 8 p.m. ET, so 2026 performance data would be due by March 31, 2027 (confirm against the current CMS Quality Payment Program calendar at qpp.cms.gov). For wound care and podiatry practices, that date is a ceiling, not a starting line. Chronic-wound data depends on follow-up documentation, healing-status capture, and denominators that are built visit by visit across the year.
If you report through a Qualified Clinical Data Registry (QCDR), the effective deadline is usually earlier, because the registry needs time to clean, validate, and submit your data. This article separates the dates that get conflated, explains how QCDR reporting changes your timeline, and sets out what to do in the weeks that remain in 2026.
When Is the MIPS Submission Deadline for the 2026 Performance Year?
As of October 2026, the standard pattern holds: the performance year runs January 1 to December 31, the data submission window generally opens early in the following year, and it closes March 31 at 8 p.m. ET. Confirm the exact 2026 window on qpp.cms.gov, since CMS can adjust operational dates.
Four dates are routinely confused:
- End of the performance period: December 31, 2026. Care delivered after this date does not count toward 2026 scoring.
- Data submission deadline: generally March 31, 2027. This is when data must be in, not when care must be delivered.
- Targeted review window: the period after final scores are released, during which you can dispute a calculation.
- Payment adjustment year: 2026 performance affects Medicare Part B payments in 2028, a two-year lag.
Reporting periods also differ by category. Improvement Activities generally require a minimum continuous 90-day period within the performance year, Promoting Interoperability requires a minimum continuous 180-day period, and Quality is expected to cover the full year. These requirements are set in the CY2026 Physician Fee Schedule final rule, and details such as the number of required measures can change from year to year.
The practical implication of today’s date is straightforward. With roughly two months of the 2026 performance period left, you can no longer change much about what happens in the first ten months. You can still close documentation gaps on current patients, confirm that your Promoting Interoperability 180-day window (the last day to start one was July 5) and your Improvement Activities 90-day window (the last start date was October 3) are in place, and confirm who is submitting what. After December 31, the work shifts from improving the record to assembling it.
What Happens to the Deadline if You Report Through a QCDR?
A QCDR is a CMS-approved entity that collects clinical data from participating clinicians and submits it to CMS on their behalf. Unlike a standard qualified registry, a QCDR can also develop and propose its own measures, which lets a specialty report on outcomes that general MIPS measures do not capture.
The timing consequence is the part practices miss. Registries typically set an internal data-completion cutoff ahead of March 31, because they must reconcile records, resolve missing fields, and give clinicians a chance to review before submission. That cutoff is the deadline that matters for you. The date varies by registry, so ask yours for it in writing and put it on the calendar next to the CMS date.
Why specialty measures matter for chronic wounds
Wound care clinicians treat patients who are often in their sixties or older, with wounds that have persisted for months and several comorbidities such as diabetes, vascular disease, and obesity. General measures built for primary care or surgical populations can fit these patients poorly. A measure that ignores wound age, wound type, or comorbid burden may penalize a clinic for treating the hardest cases.
Risk adjustment addresses this by accounting for patient factors that influence outcomes, so a center treating sicker patients is compared more fairly. Specialty-specific QCDR measures can also reflect what wound clinicians actually do: assess healing status over time, document offloading or compression, and track closure.
US Wound & Podiatry Registries (USWR) is part of the Chronic Disease Registry, a CMS-recognized QCDR, and its wound care measures were developed in conjunction with the Alliance of Wound Care Stakeholders, the Undersea and Hyperbaric Medical Society, and the American Podiatric Medical Association. CMS has approved USWR’s wound care quality measures for 2026, including healing or closure measures for diabetic foot ulcers, venous leg ulcers, and pressure ulcers. QCDR measures are re-approved annually, so the list can change from year to year.
What Are the Four MIPS Performance Categories and How Do They Affect Submission?
MIPS scores clinicians in four categories, and they do not all require the same action from you. The common misconception is that everything must be submitted. Cost is the exception.
- Quality: submitted by you or your registry. Data comes from the EHR, registry capture, or claims, depending on the measure and collection type.
- Cost: calculated by CMS from Medicare claims. There is nothing to submit, but your claims coding and attribution drive the result.
- Improvement Activities: attested by you or your group, typically through the QPP portal or via a registry or other third party.
- Promoting Interoperability: attested by you, covering certified EHR technology use, with required measures and a security risk analysis.
For the 2026 performance year, category weights are 30% Quality, 30% Cost, 15% Improvement Activities, and 25% Promoting Interoperability. Those weights shift when categories are reweighted for an individual clinician.
Exceptions and reweighting
Clinicians who qualify can apply for a Promoting Interoperability hardship exception (for example, for decertified EHR technology or insufficient internet connectivity) or an extreme and uncontrollable circumstances exception, which can cover any category. If approved, that category’s weight is typically redistributed to others, often Quality. Both 2026 applications close December 31, 2026, at 8 p.m. ET, well before the March 31 submission deadline.
Status considerations for wound centers
Which categories apply depends on your status. Small practices (as defined by CMS, generally 15 or fewer clinicians) may receive special treatment such as reweighting or additional points. Hospital-based clinicians can sometimes qualify for Promoting Interoperability reweighting, and non-patient-facing status can also trigger it. A hospital outpatient wound center and an independent podiatry practice can therefore face different category structures, so confirm your status in the QPP participation lookup before planning.
What Does Missing the MIPS Submission Deadline Cost a Wound Care Practice?
If you are an eligible clinician and submit no data, you receive the maximum negative payment adjustment for the applicable payment year. By statute, that maximum negative adjustment is 9%, applied to 2028 Medicare payments for covered professional services.
Consider an illustration, not real data. Suppose a practice receives $1,000,000 in Medicare Part B payments for covered professional services in the relevant year. A 9% negative adjustment would reduce payments by $90,000. For a small podiatry group, that can exceed the cost of the registry, the staff time, and any documentation changes combined.
Submitting is not the same as avoiding a penalty. Your final score is compared with the performance threshold, which CMS sets annually. Scores below it produce a negative adjustment, a score exactly at it is neutral, and scores above it may earn a positive adjustment. For the 2026 performance year, the threshold is 75 points, and CMS has held it there through the 2028 performance year.
Once final scores and payment adjustment information are released, you can request a targeted review if you believe there was an error in data submission, eligibility determination, or score calculation. The window is limited: it opens when final scores are released and closes 30 days after payment adjustment information is released, roughly 60 days in total. A targeted review is far easier to win when you have your submission confirmation, your measure data, and your registry’s reports on file. Keep them.
How Can You Check Your Data Before the Deadline Instead of After It?
Work backward from the dates, starting now:
- Confirm eligibility. Use the QPP participation status lookup on qpp.cms.gov to see whether each clinician is required to report and under which status.
- Run a gap report. Ask your registry or EHR for measure performance to date, including denominators and missing fields.
- Close gaps before December 31. Documentation that should have been captured at a visit is much easier to fix for patients still under care.
- Meet the registry cutoff. Treat the registry’s date as the real deadline, then use the CMS window only as a backstop.
Wound care data tends to fail in predictable places. Denominators are incomplete when patients are seen across several sites or when eligible encounters are not flagged. Healing status at follow-up is missing when the note says “improving” but no structured field records closure, wound size, or status. Documentation is also scattered across the EHR, a wound photography tool, and billing, so no one system holds the full picture.
Double data entry is the objection most clinicians raise, and it is a fair one. Registry-EHR connectivity reduces it by pulling structured fields directly, leaving staff to resolve exceptions rather than retype notes. Ask any registry you evaluate exactly which fields it extracts and which require manual entry.
A clean submission checklist looks like this:
- Eligibility confirmed for every clinician
- Measures selected and matched to your patient mix
- Data complete, with denominators reconciled
- Improvement Activities and Promoting Interoperability attestations filed
- Submission confirmation received and saved
For roster-wide visibility across clinicians and sites, ask USWR what dashboards and reporting it provides for your participation year. Practices documenting in Intellicure can also use its wound care quality dashboard, which benchmarks each clinician’s measure performance against national averages.
Do Wound Care Practices Have Special Options for MIPS Reporting?
Practices choose how they report, and the choice affects both workload and scoring. The main options are:
- Individual: each clinician reports under their own NPI and TIN combination. It suits solo podiatrists or clinicians who want separate scores.
- Group: the practice reports as one TIN with an aggregated score. This is common for multi-clinician podiatry practices and for hospital outpatient wound centers whose clinicians bill under the same TIN.
- Virtual group: small practices combine for reporting without merging. It can help solo or small practices that lack the volume to score well alone, but it requires an election with its own deadline.
- APM Entity: for clinicians participating in an eligible Advanced Alternative Payment Model or MIPS APM. Few wound centers fall here, but check if your organization participates in one.
Reporting through a specialty QCDR can be strategically useful. Specialty measures are more likely to describe the care you deliver, risk adjustment accounts for patient complexity, and benchmarks can reflect a comparable population. That does not guarantee a higher score, and any benchmark you rely on should be checked against CMS’s current benchmark files.
Registry data has value beyond MIPS. Structured outcomes from real patients can support arguments to payers and policymakers in a field where trials often exclude the sickest patients. Hyperbaric medicine is one example: when the AMA RUC re-evaluated payment for hyperbaric chamber supervision, USWR registry data on patient comorbidities and supervision volume gave the specialty real-world evidence to bring to the table.
Treat March 31 as the Backstop, Not the Plan
The March 31 deadline is a ceiling. The work that determines your score happens during the performance year, in the documentation of each visit and the capture of each follow-up. Your registry’s cutoff will arrive sooner than the CMS date, so find it first.
Before the year ends, confirm your 2026 dates on qpp.cms.gov, get your QCDR’s data-completion cutoff in writing, and run a gap report while you can still correct the record. If you are not yet capturing structured wound data, start now so that 2027 begins with the process in place. To discuss starting data capture with a wound care and podiatry QCDR, learn more about our services.
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