August 18, 2021

ACR Prepares to Comment on 2022 QPP Proposed Rule

The 2022 Medicare Physician Fee Schedule Proposed Rule released July 13 by the Centers for Medicare and Medicaid Services (CMS) includes several changes to the Quality Payment Program (QPP) and the Merit-based Incentive Payment System (MIPS).


The American College of Radiology® (ACR®) is preparing a comment letter to CMS expressing support or opposition to various proposals in the proposed rule. These include:

  • Opposition to CMS’s proposal to remove MIPS quality measures #195: Stenosis Measurement in Carotid Imaging Reports and #225: Reminder System for Screening Mammograms. The pool of measures available to radiologists has been significantly reduced over the last few years of the MIPS program and the ACR intends to push back against the removal of additional radiology measures.
  • Support for CMS’s proposal to raise the score ceiling for new measures to five points from three points for the first two years of a measure’s existence. However, the ACR requests that CMS extend to at least three years. The ACR contends that it often takes longer than two years for a measure to reach a level of adoption that enables it to receive a MIPS benchmark.
  • Strong opposition to the proposal to remove quality measure bonus points from the MIPS program. CMS’s policy of awarding bonus points for additional high-priority measures has incentivized the adoption of many new, non-benchmarked measures. It also has provided radiologists with a pathway to improve their MIPS score despite measures being removed from the program or capped at seven points due to topped-out status.
  • Concern with CMS’s plan to raise the data completeness threshold for quality measures to 80%; the ACR believes this is too steep an increase and may prove difficult for small and rural practices. Instead, the ACR encourages CMS to raise this threshold gradually.

In addition to these issues, the ACR intends to comment or request clarification on several other issues, including the challenges radiology faces regarding cost measures, the difficulty of transitioning to digital quality measurement, and concerns about subgroup reporting for MIPS Value Pathways.


The ACR intends to submit comments to CMS in early September.


If you have questions or would like more information about the 2022 proposed rule, email Zach Smith.