Part 1 – Merit-based Incentive Payment System (MIPS): Where we are and where we’ve been

Mid section of businesswoman looking at document through magnifying glass, MIPS


Where we are and where we've been

MIPS Series: part 1 of 4


  • Barbara Rubel, MBA, FRBMA, MSN Sr. VP, Marketing and Client Services
  • Claudia Murray, RCC, MSN Sr. VP, Regulatory Affairs and Corporate Compliance Officer

MIPS in 2021

Performance Year 2021 is the Merit-based Incentive Payment System’s (MIPS) fifth year and CMS’ “relaxing” of the program is coming to an end.  Radiologists have, by and large, embraced the MIPS program and their success rate in fulfilling the MIPS measures documentation requirements has been both positive and negative.

Positive side of MIPS

Positive in that not only have a majority of clinicians avoided penalties, but many have exceeded the exceptional performance threshold and received a portion of the $500 million allocated by Congress for exceptional performers.

Downside of MIPS

The downside to this success is many of the “national” [1] measures are “topping out” which has resulted in their being devalued and/or eliminated. 

Notably, most of the diagnostic measures are topped out and devalued in 2021 with measure #225, mammography reminder system, as the only measure still valued at 10 points.  Measure #146, BIRADS3, has been deleted.  

The remaining diagnostic radiology measures have all been devalued to seven points:

  • #145: Exposure Dose Indices or Exposure Time and Number of Images Reported for Procedures Using Fluoroscopy (+ 1 HP [2] bonus point)

  • #147: Correlation with Existing Imaging Studies for All Patients Undergoing Bone Scintigraphy (+ 1 HP bonus point)

  • #195: Stenosis Measurement in Carotid Imaging Reports

  • #360: Optimizing Patient Exposure to Ionizing Radiation: Count of Potential High Dose Radiation Imaging Studies: Computed Tomography (CT) and Cardiac Nuclear Medicine Studies (+ 1 HP bonus point)

  • #436: Radiation Consideration for Adult CT: Utilization of Dose Lowering Techniques

Why do we care?

Why do we care? Medicare Part B dollars are now seriously at risk.  The maximum payment adjustment in 2021, as legislated by Congress, is +/-9 percent and the Composite Performance Score to avoid a penalty is 60 percent.  Compare 60 percent to the modest three percent during the first year of MIPS (2017) and 45 percent in 2020. 

Furthermore, additional national (all numeric IDs) are not being developed by CMS since their plan is to shift to MIPS Value Pathways (MVPs).

Qualified Registries vs. Qualified Clinical Data Registries

The fact that national MIPS measures are topping out and being eliminated leads to a discussion about the differences between Qualified Registries and Qualified Clinical Data Registries. 

A Qualified Registry is limited to reporting national measures only.  A Qualified Clinical Data Registry (QCDR), however, can report both national measures and QCDR (non-national) measures.  

QCDR measures must be reviewed and approved by CMS annually and, to report a QCDR measure, a radiologist must be reporting through a QCDR.  QCDR measures that have been approved by CMS are specific to the QCDR submitting the measure for approval; however, it is possible for QCDRs to license measures from other QCDRs. 

[1] National measures are numeric IDs only, e.g. measure 225 is a national measure.

[2] HP stands for High Priority and bonus points are awarded for reporting these measures. Bonus points are capped at six points in total.

MIPS Article Series

This article is #1 of 4 in our MIPS series. Be sure to check out the rest of the articles in the series: 

Barbara Rubel MBA, FRBMA Senior Vice President, Marketing & Client Services

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 provide 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.

Claudia Murray, RCC Senior Vice President of Regulatory Affairs Executive,  Director of Quality Payment Programs

Claudia brings an extensive background in Medicare regulations, law and billing processes having spent more than 20 years with the Medicare program in various roles. Prior to joining MSN Healthcare Solutions as their full-time compliance officer, Claudia headed a small consulting firm specializing in radiology and other hospital-based specialties. She consulted with MSN for 15 years in designing, implementing and advising on their compliance programs.

Currently at MSN, Claudia is responsible for the myriad activities for HIPAA and corporate compliance as well as the Quality Payment Programs, bringing her full circle to CMS regulations and programs.

Claudia Murray RCC Senior Vice President of Regulatory Affairs Executive Director of Quality Payment Programs