If you have trouble distinguishing where you are in your QPP (APM or MVP, for example), you are not alone! The Merit-based Incentive Payment System (MIPS) has thrown us into what seems to be a continuously expanding acronym soup. It can feel like once you figure out where you are, a new program modification crops up and your knowledge is outdated.
The Past
It all began under the Tax Relief and Health Care Act of 2006 as the Physician Quality Reporting Initiative (PQRI), a voluntary program to report data on specific quality measures for Medicare Part B services and offering a potential 1.5% (of allowed charges) bonus. In 2011, the program was renamed as the Physician Quality Reporting System (PQRS) and became mandatory, offering not only incentives for participation but penalties for failure to do so. Penalties for non-reporting increased from 2015 forward and PQRS terminated as a standalone program in 2017 following passage of the Medicare Access and CHIP Reauthorization Act in 2015 (MACRA) and the introduction of the Merit-based Incentive Payment System (MIPS) in 2023.
The Present
As of 2026, diagnostic and interventional radiology groups (along with pathology and anesthesia) can now register to participate in MIPS Value Pathways (MVPs). Practices can also report both traditional MIPS and MVPs, and provider(s) will receive the higher of the two scores. MVPs remain voluntary in 2026, and new measures have been added to the prior list of MVPs. Then we also have the alternatives of MIPS versus an Alternative Payment Model (APM), beginning with the determination of whether or not your group is a Qualifying APM Participant (QP) as part of an Accountable Care Organization (ACO). The ACO consists of a group of healthcare providers—such as physicians, hospitals, and other clinicians—that voluntarily work together to coordinate care for a defined population of patients, typically Medicare beneficiaries, with the goal of improving quality while reducing overall healthcare costs. The ACO therefore constitutes the entity participating in an APM (an APM-E) and an Advanced APM is a higher standard APM that requires financial risk and allows clinicians to avoid MIPS if participation thresholds are met. Whew!
The Future
Traditional MIPS may sunset after 2027 as CMS continues the transition to MVPs, which will eventually be the only option. MSN’s QPP consultants predict radiologists are less likely to be invited to participate in APMs in the future, and they anticipate lower APM rewards as well (unless Congress takes action). In the future, the emphasis will shift to new specialist models with more difficult, mandatory measures and a greater emphasis on cost. Scoring will involve comparison only with peers, and there will be an equal number of winners and losers.
Does your head hurt yet? It’s all part of Medicare’s progression to Value-Based Care (VBC). All of this is made much simpler if you participate in MSN’s Qualified Clinical Data Registry (QCDR), under the guidance of our experts. And MSN will help QCDR clients register for an MVP.
