Radiology groups urge CMS to retool the flawed Merit-based Incentive Payment System

Radiology groups are urging the federal government to retool the Merit-based Incentive Payment System, or MIPS, amid concerns that it’s too difficult for the specialty to participate.

Both the American College of Radiology and Radiology Business Management Association encouraged CMS to make changes to the quality-reporting program in comments submitted this month. As one point of contention, ACR highlighted the agency’s plan to raise the “performance threshold” from 75 to 82 points next year. Providers falling below this level would be automatically penalized.

However, radiologists already are struggling to participate in MIPS, given several barriers. Those include the specialty’s ineligibility to earn maximum incentive adjustments, despite perfect performance in the program.

“The ACR strongly opposes CMS’s proposal to raise the performance threshold to 82 points until the effects of topped out quality measures on non-patient facing clinicians and the barrier for introducing new measures is addressed,” CEO William T. Thorwarth Jr., MD, wrote to the agency on Sept. 8. “It is important to acknowledge that due to declining measure availability and an increased fraction of topped out measures for some specialties, such as radiology, as well as the removal of bonus points, there is not equivalency between past and present years,” he added later. “As a result, past performance is not reflective of the current challenges. We thus strongly urge CMS to use the flexibility provided in the statute to maintain the threshold until these issues are successfully addressed.”

CMS also has indicated that it plans to sunset the MIPS program in favor of alternatives, though no timeline has been set. The college asked the agency to hold off on such a change for now.

“The ACR acknowledges that the MIPS program is burdensome and imperfect at effectively measuring clinician performance,” Thorwarth wrote. “However, we encourage CMS to commit to not sunsetting MIPS until there is an option available which is viable to all specialties.”

The Radiology Business Management Association also voiced opposition to certain aspects of MIPS, as spelled out in the 2024 fee schedule. RBMA is “extremely concerned” about the impact on radiology practices after reimplementing cost measures for the 2022 performance period. The association believes there are no meaningful opportunities for clinicians to impact performance, and CMS has not provided cost data since 2019, RBMA noted. There also is no interim reporting during the performance period, leaving clinicians unable to understand how they are performing.

“It defies logic to expect clinicians to impact costs for patients who cannot be readily identified, for unknown services with unknown costs, ordered and rendered by unknown providers and suppliers for unknown reasons,” RBMA Executive Director Bob Still wrote Sept. 11. “Given the fact that the meager data is not provided until after the end of the reporting period, no one can expect it to impact program costs. Many radiology practices have reported being scored on the Medicare Spending per Beneficiary measure. They express frustration with this, since radiologists rarely admit patients to the hospital, and even more rarely manage post-discharge care.”

Radiologist Richard Heller, MD, MBA, also recently editorialized on the inherent flaws in MIPS. He urged Congress to consider quashing the program, as the Medicare Payment Advisory Commission recommended five years ago.

“Eliminating the MIPS program, or at least hitting pause while an alternative approach is developed, would not only reduce the burden on providers and stop the costly gamesmanship of managing a broken system, but it would also clear the way for meaningful reform,” Heller, who is associate chief medical officer for health policy and communication at Radiology Partners, wrote Sept. 9 in a MedPage opinion piece. “Let's hope Congress takes the easy win.”