February 26, 2025
Small Practice Radiologists and Those Reporting Individual Face Disadvantages in MIPS Scoring, Highlighting Need for Reform
New Harvey L. Neiman Health Policy Institute research found significant differences in performance across radiologists in the CMS Merit-Based Incentive Payment System (MIPS). The researchers examined a broad range of radiologist and practice characteristics and identified the set of factors that predicted whether a radiologist would score exceptionally, and thus receive the highest payment bonus, or would fail to meet this bar. The study, published in the Journal of the American College of Radiology (open access link), found that the strongest predictor of a radiologist’s lower performance was reporting as an individual clinician, rather than as part of a group of physicians or an Advanced Payment Model (APM) entity. Individual radiologists were 7.4 times more likely to fail to achieve “exceptional” status than group reporting radiologists, indicating potential disadvantage in the MIPS program.
MIPS is the largest component of the CMS Quality Payment Program; it incentivizes higher quality care by tying provider payments to performance through score-based bonuses and penalties. From the first MIPS performance year in 2017 until 2022, the highest bonus was awarded to those with an “exceptional” score, but the ability to achieve this performance level depends on the number of applicable measures and performance of other participants across all specialties. “Since its inception, the MIPS program has raised concerns about whether radiologists and other specialties who are not directly accountable for managing a patient’s overall care can meaningfully participate in the program,” said Dr. Lauren Nicola, MD, Chief Executive Officer, Triad Radiology Associates. “Yet, quality in imaging is critical for patient care. Radiologists save lives by diagnosing disease, guiding decisions about the most effective treatment, and administering targeted and minimally invasive therapy.”
The study of all 22,875 radiologists in 2019 MIPS aimed to understand the factors associated with their performance in the program. Results showed that radiologist’s participation type and practice size were the strongest predictors of performance. The score differential was substantial between the reporting categories. Compared to a majority of radiologists participating in MIPS via group reporting, individually reporting radiologists scored 32% lower, while APM radiologists scored 8% higher. “There also has been a rapid, large shift in MIPS participation type, with the proportion of individual reporting dropping from 16.6% to 4.3% from 2017 to 2019, suggesting that radiologists are seeking opportunities for higher scores and bonus potential,” stated Dr. YoonKyung Chung, PhD, Principal Economic and Health Services Researcher at the Neiman Institute.
Beyond participation type, practice size was the next strongest predictor of performance. Practices with 50 or more clinicians were the least likely to underperform in MIPS. Hospital-based radiologists were less than half as likely to underperform in MIPS. “Despite CMS’ efforts to support smaller practice MIPS success with bonus points and reduced reporting requirements, smaller practices remain disadvantaged. Yet, evidence does not support that smaller practices provide lower quality care” said Dr. Chung. Additional significant predictors of underperformance in MIPS were more rural practices, higher risk patients, and more years in practice (> 10 vs < 10).
The Neiman HPI researchers also looked specifically at which quality measures were reported most often by radiologists, and if these differed by reporting type. Of note, none of the measures reported by radiologists in APM reporting were radiology-relevant due to separate APM reporting requirements. “Our analysis found most radiologists did perform successfully, overall, in the MIPS program, but this success was not equally distributed across practice, physician and patient panel characteristics, and largely depended on whether a radiologist was limited to reporting radiology-specific measures” said Dr. Nicola. “Unfortunately, the imbalance in available MIPS radiology measures is worsening. None of the top 10 quality measures reported by individual and group participants in our analysis were still available for full score potential in 2024. It is unsurprising that radiologists reporting in groups or APMs take advantage of the opportunity to report measures of other medical specialties within their practice.”
The authors noted that one possible solution to improve success in radiology-relevant measures is participation via a CMS-approved MIPS qualified clinical data registries (QCDR) such as the ACR National Radiology Data Registry. There were 20 diagnostic radiology QCDR measures in PY 2024, of which 14 allow for maximum points. “Further evaluation of MIPS is needed for radiologists. This study provides important data to inform future program design that may reduce bias and better achieve the goal of incentivizing higher value care,” said Elizabeth Rula, PhD, Executive Director of the Neiman Institute.
To obtain a copy of the study or to arrange an interview with a spokesperson, contact Nichole Gonzalez at ngonzalez@neimanhpi.org.
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About the Harvey L. Neiman Health Policy Institute
The Harvey L. Neiman Health Policy Institute is one of the nation’s leading medical imaging socioeconomic research organizations. The Neiman Institute studies the role and value of radiology and radiologists in evolving health care delivery and payment systems and the impact of medical imaging on the cost, quality, safety and efficiency of health care. Visit us at www.neimanhpi.org and follow us on Twitter, LinkedIn and Facebook.