Medicare Quality Payment Program changes affecting radiology practices for 2025

Radiology practices often participate in the Medicare Quality Payment Program (QPP) through the Merit-based Incentive Payment System (MIPS). Many aspects of the MIPS rules remain unchanged for 2025, including the following:

• The MIPS Performance Threshold will remain at 75 points.
• The completeness criteria remain at 75%.
• For practices where performance categories are not reweighted, the category weights remain at:
• *Quality – 30%
• *Improvement Activities – 15%
• *Cost – 30%
• *Promoting Interoperability – 25%
• For practices where Promoting Interoperability and Cost are not a factor, the standard reweighting will be 85% Quality and 15% Improvement Activities (or 50% each for Small Practices).
• The Small Practice Quality Category bonus will be retained at 6 points.

The MIPS Quality performance category scoring has been modified for 2025, which could have a positive effect for radiology practices. Under MIPS rules for 2024, there was a cap of 7 points on any Quality category measure that is part of a specialty, such as radiology, with a limited number of measures available for use. For 2025, The U.S. Centers for Medicare and Medicaid Services (CMS) has made a change to remove that cap, which means that such measures will receive the full 10 points. Radiology measures moving back up to a possible 10-point score include the following:

• Measure 360: Optimizing Patient Exposure to Ionizing Radiation: Count of Potential High Dose Radiation Imaging Studies: Computed Tomography (CT) and Cardiac Nuclear Medicine Studies
• Measure 364: Optimizing Patient Exposure to Ionizing Radiation: Appropriateness: Follow-up CT Imaging for Incidentally Detected Pulmonary Nodules According to Recommended Guidelines
• Measure 405: Appropriate Follow-up Imaging for Incidental Abdominal Lesions
• Measure 406: Appropriate Follow-up Imaging for Incidental Thyroid Nodules in Patients

Another change that could help radiologists is in the Improvement Activities (IA) category. Previously, IA had two levels of measures: medium-weight and high-weight. The goal was to reach 40 points by submitting from 2 to 4 activities. For 2025, the CMS has simplified the weighting system, as follows:

• Small practices, non-patient facing, and rural/health professional shortage practices need to attest to only one activity. This would include many diagnostic radiologists.
• All other practices will attest to two activities.
• Practices reporting under MIPS Value Pathways (MVP) will attest to one activity.  MVP reporting is not common among radiology practices due to a lack of applicable measure sets.

Quality Performance Measure #436, Radiation Consideration for Adult CT – Utilization of Dose Lowering Techniques, has been eliminated and replaced by Measure #494, Excessive Radiation Dose or Inadequate Image Quality for Diagnostic CT in Adults. This new measure provides a standardized method for monitoring the performance of diagnostic CT to discourage unnecessarily high radiation doses, a risk factor for cancer, while preserving image quality. It is expressed as a percentage of CT exams that are out-of-range based on having either excessive radiation dose or inadequate image quality, relative to evidence-based thresholds based on the clinical indication for the exam. All diagnostic CT exams of specified anatomic sites performed in inpatient, outpatient, and ambulatory care settings are eligible.

Measure #494 is an Electronic Clinical Quality Measure (eCQM) that requires the use of additional software to access primary data elements stored within radiology electronic health records and translate them into data elements that can be ingested by the eCQM. Accordingly, Measure #494 may not be very useful to practices due to the need for such additional software that will enable them to gather and report the required data.

Practices utilizing the Qualified Clinical Data Registry (QCDR) offered by the American College of Radiology (ACR) will have five new measures available for reporting in 2025. The new measures are as follows:

• ACRad 43: DXA – Improving Reporting of True Change in Bone Mineral Density
• QMM 23: Low Dose Cancer Screening Recommendation for CT of Chest with Diagnosis of Emphysema
• QMM 24: Acute Rib Fracture Numbering on ED Trauma Patients
• QMM 27: Appropriate Classification and Follow-up Imaging for Incidental Pancreatic Cysts
• QMM 28: Reporting Breast Arterial Calcification (BAC) on Screening Mammography

In its summary of the QPP for 2025, the CMS indicates that, “We’re revising our cost measure scoring methodology to assess clinician cost of care more appropriately.” While many radiology practices are not scored in the Cost category, those that do receive a score could benefit from the revised methodology. In the QPP Fact Sheet examples (page 24), a physician with a cost per episode of $1,126.34-1,062.93 would have received between 2 and 2.9 points, whereas under the new table the same cost per episode would earn from 6 to 6.9 points.

Conclusion

With the Medicare Physician Fee Schedule constantly under the threat of annual reductions or small increases that do not keep up with inflation, maximizing the practice’s participation under the Quality Payment Program is essential. Practices must annually review the changes to the program and take advantage of any opportunity to improve their score.

Erin Stephens is senior client manager, education for Healthcare Administrative Partners.

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