MIPS Series: part 2 of 3
This article is the second in a series of three and provides valuable insight regarding the Merit-based Incentive Payment System (MIPS) and its impact on radiology.
Be sure to review the rest of the articles in the series:
- Part 1: MIPS 2025: Where we are and where we’ve been
- Part 3: MSN QCDR Measures 2025
Composite Performance Score (CPS)
MIPS is all about a clinician’s Composite Performance Score (CPS). The CPS determines the applicable payment adjustment under the Medicare Physician Fee Schedule and is calculated from a clinician’s performance in each of four performance categories:
- Quality (30%)
- Cost (30%)
- Promoting Interoperability (25%)
- Improvement Activities (15%)
Groups and individual providers with any one of the defined special statuses is exempt from the Promoting Interoperability category (the EMR component of the program) and that category’s weighting of 25% is automatically reweighted to Quality. Special status categories include: Ambulatory Surgical Center (ASC)-based; Hospital-based; Non-patient facing; Small practice.
Radiology groups with Interventional Radiology procedures and Evaluation & Management visits (especially those with mid-level practitioners) will likely be impacted by Cost, which accounts for 30% of the CPS [1]. Exhibit A provides an illustration of how the performance categories are weighted.
Exhibit A: Performance Category Weightings
*A small practice is defined as 15 or fewer clinicians (identified by NPI) who have reassigned their billing rights to a single TIN.
Improvement Activities
Improvement Activities (IA) are reported through attestation and at least 50 percent of the group must perform the same activity for 90 consecutive days [2] to satisfy this category. The 2025 scoring has been simplified by removing the weighting of the activities as either high or medium. Clinicians and virtual groups that meet the definition of a “small practice,” are in rural or health professional shortage areas, and are non-patient-facing must attest to one improvement activity. All other clinicians must attest to two activities. The Patient Relationship Modifier Improvement Activity (X5: only as ordered by another clinician) remains in the program in 2025 and is unchanged.
Quality Scores
Quality is still the bulk of a radiologist’s score and 60 quality points must be earned to achieve a perfect score. Clinicians may submit an unlimited number of measures; however, CMS will only score six measures with the highest earned point values. The big news in 2025 is CMS is “backtracking” on the 7-point caps for measures #360, #364, #405, and #406 so these measures will have a maximum point value of 10.
The following assumes Promoting Interoperability (PI) is re-weighted to Quality and illustrates total points earned:
CMS calculates the quality score by adding points from the 6 measures with the highest scores. For example, assume the group is a large practice that is not eligible for PI and does not trigger cost measures—score is 85% quality; 15% Improvement Activities (IA). If the group’s top 6 measures include 2 measures scored at 10 points and 4 measures scored at 7 points, their quality points would equal 48 points. The total points of 48 is divided into 60 (maximum number of points allowed), equaling 0.80, which is multiplied by 85%*100, giving them 68 Quality Category Points. If they receive 15 points out of 15 for the Improvement Activities, their total CPS = 83 points; 8 points above the 2025 penalty threshold of 75 points. MIPS-eligible providers would receive a positive Medicare B payment adjustment in CY2027.
Incidental Measures
There are three incidental measures a diagnostic practice may choose to report. However, the documentation can be difficult as many radiologists are concerned about dictating “no additional imaging is needed” for liability reasons.
Cost Performance Category
The method for calculating the Cost benchmarks and assigning performance points has changed. The current methodology uses a decile range that is based on linear percentile distributions. The revised methodology is based on deciles according to how close eligible clinicians are to the national median. ECs will likely earn higher scores if their performance is close to the national median which is the middle of the 7th decile under the revised methodology (formerly the middle of the 5th decile). “Fun fact:” the decile where the median is placed is 10% of the penalty threshold (75 * .10 = 7.5).
Additional Interventional Radiology Reporting
3Practices that perform even limited Interventional Radiology procedures may also report:
#145: Exposure Dose Indices Reported for Procedures Using Fluoroscopy
#413: Door to Puncture Time for Endovascular Stroke Treatment
#420: Varicose Vein Treatment with Saphenous Ablation: Outcome Survey
#421: Appropriate Assessment of Retrievable Inferior Vena Cava (IVC) Filters for Removal (no published benchmark [3] – 3 points)
#465: Uterine Artery Embolization Technique: Documentation of Angiographic Endpoints and Interrogation of Ovarian Arteries (no published benchmark)
#487: Screening for Social Drivers of Health
#498: Connection to Community Service Provider
Evaluation and Management Visits Reporting
Practices that perform Evaluation & Management visits may report:
#24: Communication with the Physician or Other Clinician Managing On-Going Care Post-Fracture for Men and Women Aged 50 Years and Older (10 points)
#487: Screening for Social Drivers of Health (No published benchmark)
#493: Adult Immunization Status (No published benchmark)
#47: Advance Care Plan (7 points)
#130: Documentation of Current Medications in the Medical Record (7 points + 1 HP bonus point)
#226: Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention (10 points)
#317: Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented (10 points)
- Comment on reporting E&M measures: they do potentially expose the practice to patient attribution under the Cost Performance Category.
[1] Cost will likely not be attributed to Radiology groups that are primarily diagnostic with little to no interventional radiology.
[2] The consecutive 90-day period may vary by clinician.
[3] To establish a benchmark, a measure must be reported to CMS by practices with a minimum of 20 eligible encounters.
- Measures that are new to the program and are in their first year earn a minimum of 7 points if performance is >0%
- Measures that are in their second year of the program earn a minimum of 5 points. If performance is >0%.
- Small practices, defined as 15 or fewer clinicians, still may earn up to 6 quality bonus points. Another perk of small practice status is that measures are valued at a minimum of 3 points if performance is > 0%, even if the reporting rate is below 75%.
MIPS Article Series
This article is #2 of 3 in our MIPS series. Be sure to review the rest of the articles in the series:
- Part 1: MIPS 2025: Where we are and where we’ve been
- Part 3: MSN QCDR Measures 2025
Barbara Rubel
MBA, FRBMA
Senior Vice President, Marketing & Client Services
Barbara has been a leader with MSN Client Services since 1998. Her extensive background in strategic planning, market research, healthcare marketing and managed care negotiations provides a wealth of information to support MSN Clients.
Barbara has also been highly involved in industry organizations, serving as President of the Radiology Business Management Association (RBMA), the Georgia RBMA, and the Florida RBMA. In addition, she chaired the influential RBMA Federal Affairs Committee and the RBMA Technology Task force and was a member of the RBMA Data Committee. Her work on behalf of radiology has earned her the RBMA Special Recognition Award (2010), the RBMA Global Achievement Award (2013), and she is a Fellow of the RBMA.
Diana Stillwell
MHSA, CPHQ, CNMT
MSN Director, Quality Payment Programs & QCDR
Diana Stillwell, MHSA, CPHQ, CNMT, brings a wealth of experience to her position as MSN Director of Quality Payment Programs & QCDR. She worked on the clinical side of the business as a technologist and supervisor for more than 21 years and served nearly 7 years as a radiology practice director of quality improvement and risk management before joining MSN almost three years ago. She works closely with MSN senior leaders and client managers on the MIPS team to provide guidance and education to client practices with the goal of improving their reporting processes and optimizing performance in the MIPS program. In addition, she collaborates with MSN’s coding leaders to implement and/or edit workflow processes for new and modified measures.
