American College of Radiology ‘strongly disagrees’ with making CMS payment model mandatory

The American College of Radiology said Friday that it “strongly disagrees” with the possibility of making a Centers for Medicare & Medicaid Services payment model mandatory. 

CMS detailed the idea in the 2025 physician fee schedule, released in July. In collaboration with the CMS Innovation Center, the agency is exploring a new payment model design for specialists in ambulatory care. The feds see this as a way of increasing specialist engagement in value-based care and bolstering their collaboration with primary care and Medicare beneficiaries. 

CMS sent a request for information to solicit input on different parameters of the potential pay model, including making it mandatory. The focus is on fully implementing the Merit Based Incentive Payment System (MIPS) Value Pathways and sunsetting traditional MIPS. 

In comments submitted to the agency Sept. 6, ACR urged the feds to avoid making the model mandatory. 

“The ACR strongly disagrees with making participation mandatory, particularly within the short three- to five-year timeframe suggested and highly recommends that CMS conduct extensive testing,” CEO Dana Smetherman, MD, MBA, wrote Friday. “The ACR also believes that a significant on-ramp for the proposed model is warranted for the subset of initially implemented [MIPS Value Pathways] and for each additional MVP included over time.” 

Under the program, physician specialists would receive a payment adjustment based on their performance on a set of clinically relevant performance measures. Each individual’s performance would then be compared to other clinicians furnishing similar services, ACR noted in its summary of the bill. CMS believes this targeted approach could provide greater insight into the clinical decisions impacting patient outcomes. 

Smetherman and ACR commended the agency for its drive to address the “complexities and unviability” of the MIPS program. As outlined, the payment model would work to reward integration of specialty care across the patient’s journey. And the emphasis on improved coordination and collaboration between specialists and PCPs is “laudable,” the college noted. 

“The radiology profession prioritizes accurate imaging interpretation combined with concise evidence-based recommendations in radiology reports. Beyond the communication of diagnostic information, radiologist collaboration as part of the care team in the coordination of care, including ensuring the adherence to recommended care, is critical to the effective use of the imaging information to achieve the best patient outcomes,” Smetherman wrote. “These factors point to the critical role radiology plays in integrated primary-specialty care both episodically and longitudinally,” she added later. “As such, the ACR is supportive of the foundation and principles upon which the proposed Ambulatory Specialty Care model using an MVP framework is based.” 

In its request, CMS also asked if there are certain clinician characteristics that might warrant policy flexibilities or exemptions. Participation of certain non-patient-facing specialties such as diagnostic radiology would be dependent on the agency allowing alternative approaches. ACR said it is willing to work with the agency to help it navigate these concerns as it determines how to involve providers who do not interact directly with patients. 

The Medical Group Management Association also shared its own comments on the fee schedule Monday, similarly urging CMS to avoid making the model mandatory. 

“While we appreciate CMS examining ways to improve MVPs, we do not support instituting a new mandatory payment program for specialists in MVPs given the multitude of concerns we have outlined here and in previous comments about the need to reform the current system,” the association added.  “MGMA encourages CMS to develop specialty MVPs that are reflective of the coordination across multiple specialties in the treatment of patients with a particular condition, during an episode of care, or procedure. We also encourage the agency to prioritize alignment of the quality and cost measures to alleviate concerns with the existing MVP approach. Once again, we encourage the agency to work closely with physician specialty societies and medical groups when developing MVPs to improve the system.”

You can read the full comment letter from ACR here.