MIPS Registry Reporting: Workflow, Benefits & Accuracy

MIPS Registry reporting submits performance data to the Centers for Medicare & Medicaid Services (CMS)through a Qualified Registry. It is a CMS-approved third-party vendor that collects, validates, and transmits MIPS data on behalf of clinicians and groups. Registry is the most commonly used Merit-Based Incentive Payment System (MIPS) reporting method because it supports all four MIPS performance categories and works across specialties.

This guide covers the end-to-end Registry submission workflow, the group-reporting benefits that make Registries the default for TIN-level submission. It will also discuss five acceptance conditions that achieve 100 percent data acceptance for the 2026 performance year.

What Is a Qualified Registry?

A Qualified Registry is a third-party vendor approved annually by the Centers for Medicare & Medicaid Services (CMS)to collect, validate, and submit MIPS performance data on behalf of eligible clinicians. The Qualified Registry is one of the five MIPS reporting methods under the Quality Payment Program (QPP).

Qualified Registries operate as a data submission channel between the practice’s EHR or measure-tracking system and the CMS Quality Payment Program (QPP) submission infrastructure. The Registry aggregates measure data, validates completeness against CMS thresholds, and transmits the final submission in the QRDA III XML file format.

Most Qualified Registries provide additional value during the performance year. Common services include real-time benchmark gap reporting, measure-selection guidance, audit-prep documentation, and data-completeness audits.

The current CMS designation is Qualified Registry. Older CMS documentation occasionally references the legacy term Data Submission Vendor (DSV). That term has been superseded and no longer applies.

The three sections below cover the QCDR distinction, the annual approved list, and the approved vendor count.

How Is a Qualified Registry Different From a QCDR?

Qualified Registries and Qualified Clinical Data Registries (QCDRs) both submit MIPS data to CMS through the same Self-Nomination and annual approval process. QCDRs hold an additional authority that Registries lack: submitting non-MIPS specialty measures.

Here is how the two differ:

Qualified Registry:

• Submits standard MIPS measures only.
• Cross-specialty applicability — one Registry can serve cardiology, ophthalmology, primary care, and others.
• Typically, a lower annual subscription cost.

QCDR:

• Submits standard MIPS measures plus non-MIPS specialty measures approved annually by CMS.
• Narrower specialty focus.
• Often higher subscription cost. Specialty-society membership may be required.

Practices needing specialty-specific measures that the standard MIPS inventory does not cover should evaluate the QCDR specialty submission option alongside Registry.

Does CMS Publish an Annual List of Approved Qualified Registries?

Yes. CMS publishes the Registry Qualified Posting annually before each MIPS performance year, listing every Qualified Registry approved to submit data for that year. The list is published on the CMS Quality Payment Program (QPP) Resource Library. The list is updated only when an approved Registry has its certification revoked or amended mid-year. Vendors must reapply through CMS Self-Nomination each year to remain on the list. Approval does not roll over automatically.

How Many Qualified Registries Does CMS Approve for 2026?

CMS approves approximately 60 to 80 Qualified Registries each MIPS performance year. The exact number is published in the annual Registry Qualified Posting.

The exact count varies year to year. Some vendors do not reapply. New entrants are approved. A small number of mid-year revocations occur. Recent years have seen approximately 70 approved Qualified Registries.

A single Qualified Registry can serve clinicians across all specialties. The standard MIPS measure inventory covers cross-specialty Quality, Promoting Interoperability, and Improvement Activities categories.

Practices typically evaluate Registry options by measure-set fit, integration with the practice’s EHR, real-time benchmark gap reporting quality, and subscription cost. Raw vendor count is not a useful selection filter.

How Does Data Submission via Registry Work?

Data submission via a Qualified Registry follows a three-step workflow. The three steps are Collection, Validation, and Transmission of the final QRDA III XML file to CMS during the official submission window. Practices also rely on EHR direct submission as an alternative workflow for certain collection scenarios.

The three steps run sequentially but overlap in practice. Collection happens throughout the year. Validation happens continuously as data arrives. Transmission concentrates in January through March of the year following the performance period.

The sections below develop each workflow step under its own heading. Additional sections cover whether Registry reporting works without an EHR integration, when the 2026 submission window opens and closes, and which MIPS performance categories the Registry submits.

Collection

Step 1 of the Registry workflow is collection. Collection moves MIPS measure data from the practice’s EHR or measure-tracking system into the Qualified Registry. This process runs continuously throughout the MIPS performance year.

Qualified Registries accept measure data through three primary channels:

• API-based EHR integration, the most common configuration for CEHRT-equipped practices.
• Scheduled file exports, including daily, weekly, or monthly CSV or QRDA-formatted files from the EHR.
• Manual portal entries are used by practices without integrated EHRs.

API-based EHR integration is the most efficient configuration. The EHR exports measure data on a schedule using the Registry’s API or the FHIR-based bulk data export specification. The EHR pushes encounters, diagnoses, procedures, and quality-action documentation directly into the Registry without manual export.

Continuous collection during the performance year is a key advantage. Collecting throughout the year gives the Registry time to flag data-completeness gaps, case-minimum shortfalls, and specification mismatches early. This is the foundation for the 100 percent data acceptance discipline covered in the Accuracy section below.

Practices without integrated EHRs use Registry portal entry or CSV uploads. That path is covered in the no-EHR Boolean section below.

Validation

Step 2 of the Registry workflow is validation. The Qualified Registry runs every submitted record through a series of checks before the data is packaged into the QRDA III XML submission file.

Continuous validation begins as soon as data arrives during Step 1 (collection). Validation continues until the submission file is sealed in Step 3 (transmission). Registries do not validate only at year-end. Registries flag issues continuously so practices can correct workflow gaps mid-year.

Each measure record is validated against the five CMS acceptance conditions. Those are data completeness against the 75 percent rule, case minimums (20 cases per Quality measure), measure-specification version match, denominator and exclusion logic accuracy, and QRDA III encoding integrity. The Accuracy section below covers each condition as its own section.

The corrective-feedback loop works as follows. Records flagged at validation are returned to the practice with a measure-level issue summary. The summary identifies missing denominator data, incomplete exclusion documentation, and measure-version mismatches. The practice corrects the records or updates EHR documentation. The data then re-enters validation.

Registry validation is the validation safety net that claims-based reporting lacks. Claims-based submissions are evaluated directly by CMS without a pre-submission Registry layer to catch errors before transmission.

Transmission

Step 3of the Registry workflow is transmission. The Qualified Registry packages validate measure data into the QRDA III XML submission file and transmit the file to the CMS Quality Payment Program (QPP) submission API during the official submission window.

CMS requires Registry submissions in the QRDA III XML format. QRDA III stands for Quality Reporting Document Architecture, Category III. This standard is published by HL7 and adopted by CMS for MIPS Quality, PI, and IA category data. The Registry compiles all validated records for the TIN or NPI into a single QRDA III file.

Registries transmit the QRDA III file to the CMS QPP submission API. This is an authenticated machine-to-machine transmission channel that CMS uses for all third-party submission vendors. The transmission carries authentication credentials tied to the Registry’s annual CMS approval.

Transmission concentrates in January through March of the year following the performance year. For PY2026, the window runs January 2 through March 31, 2027. Registries typically transmit in early January and resubmit corrected records throughout the window until the March 31 close at 8 p.m. Eastern Time.

CMS returns a per-measure confirmation or measure-level rejection within hours of transmission. Confirmation completes the workflow. Rejections re-enter Step 2 validation for correction and resubmission.

Can a Registry Submit MIPS Data Without an EHR Integration?

Yes, Qualified Registries accept measure data through multiple channels beyond API-based EHR integration. Practices without integrated CEHRT EHRs can submit data via Registry portal manual entry, scheduled CSV uploads, or batch file imports formatted to the Registry’s specification. The trade-off is operational.

Manual entry and file uploads add data-entry overhead during the performance year and increase the validation work the Registry performs before transmission. Most groups with an integrated CEHRT EHR prefer API integration. Small practices and specialty practices without modern EHRs commonly use portal entry.

What Is the Submission Window for Registry Reporting in 2026?

The MIPS submission window for the 2026 performance year (PY2026) opens January 2, 2027, and closes March 31, 2027. This is the same three-month window CMS has used since the program’s inception.

Qualified Registries must transmit completed submissions to the CMS QPP submission API before 8 p.m. Eastern Time on March 31, 2027. Submissions accepted after that timestamp are not counted toward PY2026 scoring.

Most Registries finalize data validation and clinician sign-off during November and December 2026. Registries then begin transmitting submissions in January 2027 to leave buffer time for partial-rejection resubmission before the March 31 deadline.

CMS releases preliminary feedback in spring 2027 and the final PY2026 MIPS Final Score in summer 2027. Payment adjustments apply to 2028 Medicare Part B reimbursement.

Which MIPS Categories Can Be Reported via Registry?

A Qualified Registry can submit data for all four MIPS performance categories, which are Quality, Cost, Promoting Interoperability (PI), and Improvement Activities (IA) — though the mechanism differs by category.

• Quality: Submitted directly through the Registry. Practices select from the standard MIPS Quality measure inventory or a specialty measure set. Many Registries offer real-time benchmark gap reporting to guide measure selection. For further details, see quality via registry.
• Cost: CMS calculates Cost performance from Medicare Part B claims directly. The Registry does not submit Cost data. Registry feedback often includes Cost score projections sourced from historical Medicare claims.
• Promoting Interoperability (PI): Submitted via the Registry by exporting CEHRT-generated PI measure data. PI submission requires 2015 Edition Cures Update CEHRT regardless of submission method.
• Improvement Activities (IA): Attested through the Registry portal. The Registry transmits attestations to CMS during the submission window.

Practices submitting an MIPS Value Pathway (MVP) still rely on one of the five reporting methods underneath. Qualified Registry is the most common pathway for MVP submission.

What Are the Benefits of Registry Reporting for Groups?

Qualified Registries offer four core benefits that make them the default MIPS reporting method for groups. TIN-level aggregation, broader measure availability than claims-based or direct EHR submission, real-time benchmark gap reporting during the performance year, and a validation safety net that catches data issues.

Here is what each benefit means in practice:

1. TIN-level Aggregation: A Registry aggregates all clinicians billing under one Tax Identification Number (TIN) into a single group submission. This simplifies coordination and standardizes measure selection across the practice.
2. Broader Measure Choice: Registries can submit any standard MIPS Quality measure. This includes measures with low Medicare Part B claim volume that claims-based reporting cannot capture.
3. Real-time Benchmark Gap Reporting: Most Qualified Registries display measure-level performance against current CMS decile benchmarks throughout the performance year. The practice can adjust workflows mid-year.
4. Validation Safety Net: Registry validation catches data-completeness gaps, case-minimum shortfalls, and measure-specification mismatches before the CMS submission deadline.

The three sections below cover the measure-set advantage, whether Registry suits solo clinicians, and how Registry reporting affects MIPS Final Score.

What Measure-Set Advantages Do Registries Offer Over EHR Direct Submission?

Qualified Registries can submit the full standard MIPS Quality measure inventory. This includes measures specified as the MIPS CQM (Clinical Quality Measure) collection type. EHR direct submission is limited to measures specified as eCQM (electronic Clinical Quality Measure) collection type.

MIPS Quality measures have one or more approved collection types. Those types are MIPS CQM (Registry), eCQM (EHR), claims, and QCDR. Some measures exist as MIPS CQM only. Others exist as eCQM only. Some exist as both. Registry submission accesses the broader set.

CMS publishes specialty-specific measure sets covering cardiology, gastroenterology, orthopedic surgery, and other specialties. Registries can submit these sets as a unit. They often match specialty workflows better than ad hoc measure selection.

EHR direct submission remains the natural fit for the Promoting Interoperability category. It also suits practices with mature CEHRT integration where the eCQM measure set covers the practice’s reporting needs.

Does Registry Reporting Suit Solo Clinicians?

Yes, Qualified Registries support NPI-level (individual) reporting in addition to TIN-level (group) reporting. This makes them a workable option for solo clinicians. The trade-off for a solo clinician is cost. Registry subscriptions typically carry an annual fee per clinician or per group.

Medicare Part B claims-based reporting is available to small practices (TIN with 15 or fewer eligible clinicians)at no per-year vendor cost. Solo clinicians weigh Registry’s broader measure access and real-time benchmark gap reporting against claims-based reporting’s zero subscription cost.

How Does Registry Reporting Affect MIPS Final Score?

Choosing Registry as the submission method does not change the maximum achievable MIPS Final Score on the 0-to-100 scale. However, the Registry affects three score-determining factors that influence the actual score outcome.

1. Measure Availability: Registry can submit the full standard MIPS Quality inventory, plus specialty measure sets. This gives more selection optionality and access to higher-benchmarked measures.
2. Data-Completeness Ceiling: Registries can validate 100 percent data completeness across the calendar year and resubmit on partial rejection. This often achieves fuller completeness than claims-based reporting can match.
3. Benchmark Match: Each Quality measure has separate decile benchmarks for each collection type. Registry submissions are scored against the MIPS CQM benchmark. That benchmark sometimes scores differently from the eCQM benchmark for the same measure.

For most groups, the practical effect is that Registry submission produces a higher Quality category score than claims-based. Registry is comparable to EHR direct submission when the measure inventory overlaps. Registry scores lower than QCDR submission only when specialty non-MIPS measures would have scored higher than the standard MIPS equivalents.

How Do You Ensure 100% Data Acceptance?

100 percent data acceptance means every submitted measure record is accepted by CMS without rejection. This depends on five conditions that a Qualified Registry validates before transmitting the QRDA III XML file to the CMS Quality Payment Program (QPP) submission API.

The five acceptance conditions are Data Completeness (the 75 percent rule), Case Minimum (20 cases per quality measure), and Measure-Specification Version Match against the current CMS-published specifications. They also include Denominator and Exclusion Logic Accuracy according to each measure’s definition and QRDA III Encoding Integrity based on the CMS QRDA III Implementation Guide.

All five conditions apply simultaneously. A submission meeting four conditions but missing the fifth will be rejected by CMS at the measure level. Registries validate continuously during the Validation step of the workflow to catch any condition failure before transmission.

The sections below cover each of the five acceptance conditions in its own section — Data Completeness, Case Minimum, Measure-Specification Version Match, Denominator and Exclusion Logic Accuracy, and QRDA III Encoding Integrity — plus what happens if CMS still rejects part of a submission after all five conditions are met.

Data Completeness (75% Rule)

Condition 1is the 75 percent data-completeness rule. CMS requires Registry submissions to include measure data on at least 75 percent of the eligible patient encounters during the performance year for each Quality measure to qualify for full decile benchmark scoring.

A measure submitted with data on 75 percent or more of eligible encounters scores against the current CMS decile benchmark for the measure. Submissions below 75 percent face reduced scoring. In some cases, the measure defaults to the minimum measure achievement score rather than the standard benchmark.

Here is a worked example. A practice with 500 eligible encounters for a Quality measure must submit data on at least 375 encounters (500 multiplied by 0.75 equals 375) for the measure to score against the standard benchmark.

For most Quality measures, the 75 percent rule applies to all-payer eligible encounters, not Medicare-only. This broadens the data submission requirement beyond Medicare Part B claims.

Qualified Registries track measure-level data completeness during the performance year. The Registry alerts the practice when a measure approaches the 75 percent threshold. This gives time to capture missing documentation before year-end.

Case Minimum (20 Cases per Quality Measure)

Condition 2 is the 20-case minimum. Each MIPS Quality measure must include at least 20 eligible cases in the Registry submission for full decile benchmark scoring.

A case is one eligible patient encounter that meets the measure’s denominator inclusion criteria during the performance year. Encounters excluded by the measure’s exception or exclusion logic are not counted toward the 20-case minimum.

A measure submitted with 19 cases or fewer is still accepted by CMS. The submission is not rejected. However, the measure scores against an alternative low-volume benchmark rather than the standard decile benchmark. The alternative benchmark typically caps the measure’s achievable score lower than the standard benchmark allows.

The 20-case minimum functions as a measure-selection filter. Practices choose six Quality measures (or a specialty measure set) for MIPS submission. Measures that the practice expects to perform fewer than 20 times in a year should be deprioritized even if they are clinically relevant.

Qualified Registries display per-measure case counts during the performance year. Registries flag measures approaching the 20-case threshold so the practice can substitute a different measure if needed.

Measure-Specification Version Match

Condition 3 is a measure-specification version match. The data submitted for each Quality measure must conform to the current MIPS measure specification version published by CMS for the performance year being reported.

CMS updates measure specifications annually. Revisions cover denominator inclusion criteria, exception logic, numerator definitions, code value sets, and reporting frequency. A practice using PY2025 specifications to submit PY2026 data will see measure-level rejection.

CMS publishes the upcoming performance year’s measure specifications in late fall through the QPP Resource Library. The CY 2026 Final Rule was published on November 5, 2025. EHR vendors and Qualified Registries refresh their measure logic against the new specifications before the performance year begins.

Qualified Registries align internal measure logic to the current performance-year specifications. The Registry validates that the submitted encounter data uses the correct denominator, exclusion, and numerator definitions for that year. Mid-year specification corrections from CMS are propagated to the Registry’s validation rules when issued.

Practices submitting via Registry rarely need to track specification versions directly. The Registry abstracts the version match. Practices submitting via direct EHR must independently ensure the EHR’s measure logic matches the current performance-year specifications.

Denominator and Exclusion Logic Accuracy

Condition 4is the denominator inclusion criteria accuracy. Every encounter record submitted for a Quality measure must match the measure’s denominator inclusion criteria. Any approved exclusions or exceptions used to remove an encounter from the denominator must be documented per the measure specification.

A Quality measure’s denominator defines the population of encounters the measure evaluates. Inclusion criteria cover patient age range, diagnosis codes, procedure codes, encounter setting, and other factors. An encounter included in the denominator that does not meet these criteria is a denominator-accuracy failure.

Measure specifications allow encounters to be removed from the denominator through exclusions (for example, a patient in hospice) or exceptions (for example, a documented medical reason for not meeting the measure). Each exclusion or exception has a specific code or documentation requirement that the Registry validates.

Qualified Registries cross-check submitted encounter data against the measure’s denominator inclusion criteria. The Registry validates diagnosis codes, procedure codes, encounter type, and patient demographics against the specification. The Registry also validates that any exclusions or exceptions have the supporting documentation code present in the encounter record.

Denominator and exclusion errors are among the most common reasons for measure-level rejection. These errors are typically caused by EHR documentation gaps where the clinical action was performed but not coded with the specification-required code value.

QRDA III Encoding Integrity

Condition 5is QRDA III encoding integrity. The Qualified Registry compiles validated measure data into a single QRDA III XML file and validates the file against the CMS QRDA III Implementation Guide schema for the performance year before transmitting to CMS.

QRDA III stands for Quality Reporting Document Architecture, Category III. This standard is published by HL7 and adopted by CMS for MIPS Quality, PI, and IA category data. The Category III standard packages aggregate performance measures, including the numerator, denominator, exclusions, and exceptions, into a single XML document for transmission.

CMS publishes an annual QRDA III Implementation guide that defines the XML schema, required and optional elements, value-set bindings, and validation rules for the performance year. Registries must align their QRDA III output to the current Implementation Guide.

Before transmission, the Qualified Registry runs the compiled QRDA III file through schema validation. The Registry checks element structure, required attributes, code-value-set conformance, and cross-element consistency. Files with encoding errors are corrected before transmission to the CMS QPP submission API.

A QRDA III file that fails schema validation at CMS is rejected at the file level, not the measure level. The entire submission may fail rather than just individual measures. Encoding integrity is the gate condition before measure-level scoring even begins.

What Happens if CMS Rejects Part of a Registry Submission?

Even with all five acceptance conditions validated before transmission, CMS can still flag measure-level issues at submission. Rejections are returned at the measure level with specific error codes. This allows the Qualified Registry to resubmit the affected measures before the submission window closes.

Each measure record submitted through the QRDA III XML file is validated independently by the CMS QPP submission API. Records that fail validation are returned with measure-level error codes such as missing denominator, invalid exclusion code, and measure-version mismatch.

The Registry corrects rejected records, resubmits the affected measures, and may iterate multiple times until the submission window closes on March 31. This is why Registries advise practices to transmit in early January rather than late March.

Records still rejected after the submission window closes are excluded from MIPS Final Score calculation. Practices who believe their final score does not reflect their actual performance can file a Targeted Review with CMS within 60 days of feedback release.

What Does It Cost to Use a Qualified Registry?

Most Qualified Registries charge an annual subscription fee, billed per clinician (NPI) or per group (TIN), covering the data-collection portal, validation processing, real-time benchmark gap reporting, and CMS submission.

Annual Registry subscription pricing typically ranges from approximately 250 to 600 USD per clinician for standard MIPS submission. Volume discounts apply for larger groups. Setup fees of 500 to 2,500 USD may apply in the first year. Pricing varies based on EHR integration scope, real-time analytics features, and audit-support inclusion.

Smaller groups under 10 clinicians typically see per-clinician billing. Larger groups of 15 or more clinicians often negotiate flat group-level pricing.

The two sections below cover pricing by practice size and whether free Registry options exist for small practices.

What Does Typical Qualified Registry Pricing Look Like by Practice Size?

Qualified Registry pricing scales with practice size and EHR-integration complexity.

Practice Size	Typical Pricing Model	Approximate Annual Cost
Solo or Small (1 to 5 clinicians)	Per-clinician	250 to 500 USD per clinician
Medium (6 to 25 clinicians)	Per-clinician with volume discount	200 to 400 USD per clinician (often 30 to 40 percent below solo pricing)
Large (26 or more clinicians)	Group-level flat fee plus setup	5,000 to 25,000 USD annual (variable by integration scope)

Practices should request itemized pricing covering subscription, setup, EHR integration, real-time analytics, and audit-support modules. Some Registries quote a single bundled price while others itemize.

Are There Free Qualified Registry Options for Small Practices?

Yes, a small number of Qualified Registries operate at no cost to clinicians, typically as a member benefit from a specialty-society membership or as a CMS-funded option for specific clinician populations. Free Registry availability is narrow. Free options usually require specialty society membership or eligibility for a specific CMS-supported initiative.

The free tier may exclude certain value-added features like real-time benchmark gap reporting. Practices considering a free Registry should confirm the Registry remains CMS-approved each year through the annual Registry Qualified Posting.

How Is a Qualified Registry Approved by CMS?

A vendor becomes a CMS-approved Qualified Registry by completing the annual Registry Self-Nomination process. This is a formal CMS evaluation that assesses data-collection capability, measures validation rigor, security posture, and operational readiness.

CMS opens the Registry Self-Nomination window in late spring each year, typically May or June, for the following performance year. Vendors complete the Self-Nomination Form, document data-collection methods and supported MIPS measures, demonstrate validation processes, and undergo a security and operational-readiness review.

CMS reviews each application against published Qualified Registry criteria. The criteria cover measure coverage, data validation processes, HIPAA-aligned security controls, technical capability to transmit QRDA III XML to the CMS QPP submission API, and the ability to support clinicians from data collection through CMS submission.

Approved Registries are listed on the annual Registry Qualified Posting, published on the QPP Resource Library before the next performance year begins. Approval does not carry over. Vendors must reapply each year.

CMS retains the authority to revoke approval mid-year if a Registry fails to meet ongoing operational or compliance requirements. Revocations are documented on the Qualified Posting.

How Does Registry Reporting Compare to EHR and QCDR?

Qualified Registry is one of three closely related MIPS reporting methods, alongside EHR direct submission and QCDR specialty submission. The three differ in submission unit, measure scope, typical cost, and best-fit practice profile.

Method	Measure Scope	Typical Cost	Best-Fit Practice Profile
Qualified Registry	Standard MIPS measures (full inventory)	250 to 600 USD per clinician annually	Multi-specialty groups, mid to large practices, and practices new to MIPS
EHR direct submission (CEHRT)	eCQM subset of MIPS Quality plus PI and IA	Bundled in EHR vendor cost (no separate Registry fee)	CEHRT-mature practices with in-house IT and stable workflows
QCDR specialty submission	Standard MIPS plus non-MIPS specialty measures	400 to 1,200 USD per clinician annual; specialty-society membership may be required	Single-specialty groups whose specialty has an active QCDR (cardiology, ophthalmology, GI, ortho, anesthesia)

Practices choosing a method weigh measure-set fit against cost and operational complexity. See EHR direct submission and QCDR specialty submission for detailed coverage of the two sibling methods.

How Does Macralytics Handle MIPS Registry Submission?

Macralytics submits MIPS data through a CMS-approved Qualified Registry on behalf of partner practices. The team applies a four-step workflow that maps to the collection, validation, and transmission steps described above.

1. Measure planning: The Macralytics team reviews the practice’s specialty, patient mix, and historical MIPS data. The team identifies the highest-scoring measure mix from the standard MIPS Quality inventory and specialty measure sets.
2. Data extraction and validation: Data is exported from the practice’s EHR via API where available, or entered through the Macralytics submission portal. The team validates data completeness against the 75 percent rule, case minimums, and measure-specification accuracy throughout the performance year.
3. CMS submission: The final QRDA III XML file is transmitted to the CMS QPP submission API in January 2027 for PY2026. This leaves buffer time for partial-rejection resubmission before the March 31 deadline.
4. Feedback review and Targeted Review filing: After CMS releases the annual MIPS feedback report, the team reviews attribution accuracy. The team files Targeted Reviews on the practice’s behalf within the 60-day window if discrepancies appear.

To learn more about how Macralytics manages the end-to-end process, visit our registry submission.

Can a Practice Switch Qualified Registries Mid-Year?

Yes, a practice can switch from one Qualified Registry to another within a MIPS performance year. The condition is that the final submission must contain complete data covering the full reporting period for every submitted measure.

CMS does not constrain mid-year Registry changes directly. The constraint is operational. Data submitted to CMS for a Quality measure must cover the full performance year without gaps. Practices switching Registries must transfer or rebuild the year-to-date measure data in the receiving Registry before the submission window closes.

Practical switching costs are not trivial. EHR reintegration, measure mapping, data re-validation, and a fresh familiarity curve with the receiving Registry’s portal all add up. Most practices that switch do so between performance years rather than mid-year.

If CMS revokes a Qualified Registry’s approval mid-year, CMS publishes guidance to affected practices on transitioning to a different approved Registry to complete submission for that performance year. Mid-year revocations are rare but documented.

FAQ

What is a Qualified Registry in MIPS?

A Qualified Registry is a CMS-approved third-party vendor that collects, validates, and transmits MIPS performance data on behalf of eligible clinicians and groups. CMS approves Qualified Registries annually through the Registry Self-Nomination process.

How does the MIPS Registry Submission Workflow Work?

The Registry submission workflow follows three steps. Collection (measure data moves from the EHR into the Registry during the year), Validation (the Registry checks each record against CMS rules), and Transmission (the validated QRDA III XML file is sent to CMS during the submission window).

What is the 2026 MIPS Submission Window?

For PY2026, the submission window opens January 2, 2027, and closes March 31, 2027, at 8 p.m. Eastern Time. Qualified Registries must transmit completed QRDA III files to the CMS QPP submission API before that deadline.

What is the 75 Percent Data-Completeness Rule?

CMS requires Registry submissions to include measure data on at least 75 percent of eligible patient encounters for each Quality measure during the performance year. Measures below this threshold face reduced scoring or default to the minimum measure achievement score.

What is the 20-case Minimum for MIPS Quality Measures?

Each MIPS Quality measure must include at least 20 eligible cases in the Registry submission for full decile benchmark scoring. Measures submitted with 19 or fewer cases are scored against a low-volume benchmark rather than the standard benchmark.

What are the Five MIPS Data Acceptance Conditions?

The five acceptance conditions are: Data Completeness (75 percent rule), Case Minimum (20 cases per Quality measure), Measure-Specification Version Match, Denominator and Exclusion Logic Accuracy, and QRDA III Encoding Integrity. All five must be met simultaneously to achieve full data acceptance.

How is a Qualified Registry Different from a QCDR?

A Qualified Registry submits only standard MIPS measures. A Qualified Clinical Data Registry (QCDR) can also submit non-MIPS specialty measures approved annually by CMS. QCDRs typically serve a narrower specialty focus and carry a higher subscription cost.

How many Qualified Registries does CMS Approve Each Year?

CMS approves approximately 60 to 80 Qualified Registries each performance year. The exact count is published in the annual Registry Qualified Posting on the QPP Resource Library.

Can A Practice Report MIPS via Registry Without an EHR Integration?

Yes, Qualified Registries accept data through Registry portal manual entry, scheduled CSV uploads, and batch file imports. API-based EHR integration is the most efficient option but is not required.

Does Registry Reporting Suit Solo Clinicians?

Yes. Qualified Registries support NPI-level (individual) reporting. Solo clinicians should weigh the annual subscription cost against claims-based reporting, which is available to small practices (TIN with 15 or fewer clinicians) at no vendor cost.

How does Registry Reporting Affect MIPS Final Score?

Registry does not change the maximum possible Final Score (0 to 100). Registry influences the actual score through measure availability, data-completeness ceiling, and the MIPS CQM benchmark used for Quality category scoring.

What is QRDA III?

QRDA III stands for Quality Reporting Document Architecture, Category III. It is the XML file format published by HL7 and required by CMS for Registry-based MIPS submissions. The file packages aggregate measure performance data including numerator, denominator, exclusions, and exceptions.

How Does CMS Approve a Qualified Registry?

Vendors apply through the annual Registry Self-Nomination process, typically open in May or June. CMS evaluates data-collection capability, measure validation processes, security posture, and operational readiness. Approved vendors are listed on the Registry Qualified Posting. Approval does not carry over year to year.

Can A Practice Switch Qualified Registries Mid-Year?

Yes, provided the final submission contains complete data covering the full reporting period for every submitted measure. Most practices switch between performance years rather than mid-year due to the operational cost of re-integration and data migration.

What Happens if CMS Rejects Part of a Registry Submission?

CMS returns rejections at the measure level with specific error codes. The Registry corrects the rejected records and resubmits before the March 31 window closes. Practices with unresolved discrepancies after the window can file a Targeted Review with CMS within 60 days of feedback release.