Radiologists and other docs express growing frustration with Merit-based Incentive Payment System

Radiologists and other physicians are expressing growing frustration with a key Medicare program focused on improving the quality of care. 

Over 30 medical societies including the American College of Radiology recently wrote to CMS Administrator Mehmet C. Oz, MD, MBA, to voice their concerns. They highlighted the urgent need for the Merit-based Incentive Payment System (MIPS) to add additional quality measures into the program. 

Doing so would help equip patients with more usable quality information about providers while granting physicians a greater chance at being successful in the payment program. 

“There is a false belief among the administration, CMS and its contractors that decreasing the number of measures and [MIPS Value Pathways, or “MVPs”] will minimize burden,” ACR and others including the Medical Group Management Association and American Medical Association wrote Sept. 11. “However, it is not the number of measures or MVPs that cause physician burden, but rather the morass of reporting requirements and poorly designed programs.”

Doc groups are urging the agency to maintain a robust portfolio of quality measures that can help to “enable quality improvement in addition to promoting accountability.” In recent years, CMS has started to combine multiple measures into one, which has only increased complexity while adding additional burdens into reporting. ACR et al. are asking the agency to avoid adapting and selecting measures that are overly complex and duplicative in the future. 

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The physician groups also want the administration to revive and promote the Qualified Clinical Data Registry or QCDR option. Through previous legislation, Congress has acknowledged the importance of this, which allows for a seperate pathway for measure review outside of formal channels. However, CMS has started “outright rejecting” any QCDR measures for use in the payment program.

They gave the example of one instance last October, when the American College of Radiology advocated for the inclusion of more measures to “better reflect the practice of radiology.” ACR at the time had emphasized the need to reduce administrative burden, maintain flexibility for non-patient-facing physicians and ensure clear reporting guidance. 

“Despite these recommendations, CMS removed several key QCDR measures in the CY 2026 proposed rule—citing a desire to reduce the total number of QCDR measures,” the groups wrote, also highlighting the removal of a measure tied to excessive radiation dosing, with CMS claiming it was duplicative of others. “As a result of examples such as this one from ACR, the number of available QCDRs has greatly dwindled and more QCDRs will stop participating in the program, which is counter to the [Medicare Access and CHIP Reauthorization Act] statute,” they added later. 

Radiologists and other physicians are asking the administration to recognize and prioritize the value of specialty-led Qualified Clinical Data Registry measures and actively select them for the payment program. Doc groups said they remain committed to MIPS and MACRA but are questioning whether the agency feels the same. 

“To our dismay, it has often been a one-sided partnership,” they wrote.

Others signing the message included the societies representing dermatologists, family physicians, neurologists, emergency docs, anesthesiologists and pathologists. The Radiology Business Management Association also recently shared feedback about MIPS changes for 2026 in physician fee schedule comment letter submitted Sept. 5.

Radiology Business Marty Stempniak

Marty Stempniak has covered healthcare since 2012, with his byline appearing in the American Hospital Association's member magazine, Modern Healthcare and McKnight's. Prior to that, he wrote about village government and local business for his hometown newspaper in Oak Park, Illinois. He won a Peter Lisagor and Gold EXCEL awards in 2017 for his coverage of the opioid epidemic. 

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