New MIPS Value Pathways for Subspecialty Physicians

In the 2026 Medicare Physician Fee Schedule Final Rule, CMS added two new Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs) as reporting options for MIPS-eligible radiologists.

MVPs, much like traditional MIPS, comprise four performance categories: Quality, Improvement Activities, Cost and Promoting Interoperability.

An MVP, however, supplies a more curated list of available measures and activities, offering more relevant options to subspecialty physicians. The two new MVPs in 2026 are related to diagnostic radiology and interventional radiology.

MVP performance categories are scored and weighted in the same way as traditional MIPS:

• Quality represents 25%
• Improvement Activities are 15%
• Cost is 30%
• Promoting Interoperability is 25%

The same reweighting policies apply. Participants traditionally exempt from the Cost and/or Promoting Interoperability categories will likely still see those reweighted to Quality.

Notably, MVPs only require the submission of four Quality measures rather than the six required in traditional MIPS. However, an Outcome measure is still required. In the Diagnostic Radiology MVP, the available measures are:

• CQM 145: Radiology: Exposure Dose Indices Reported for Procedures Using Fluoroscopy
• CQM 360: Optimizing Patient Exposure to Ionizing Radiation: Count of Potential High-Dose Radiation Imaging Studies: Computed Tomography (CT) and Cardiac Nuclear Medicine Studies
• CQM 364: Optimizing Patient Exposure to Ionizing Radiation: Appropriateness: Follow-up CT Imaging for Incidentally Detected Pulmonary Nodules According to Recommended Guidelines
• CQM 405: Appropriate Follow-up Imaging for Incidental Abdominal Lesions
• CQM 406: Appropriate Follow-up Imaging for Incidental Thyroid Nodules
• eCQM 494: Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults (Clinician Level)
• QMM17: Appropriate Follow-up Recommendations for Ovarian-Adnexal Lesions Using the Ovarian-Adnexal Reporting and Data System (O-RADS™)
• QMM18: Use of Breast Cancer Risk Score on Mammography
• QMM26: Screening Abdominal Aortic Aneurysm Reporting With Recommendations

Please be aware that the only Outcome measure currently available in the Diagnostic Radiology MVP measure set is eCQM 494. Participants who choose not to report an Outcome measure might be unable to achieve a full score in the Quality category.

Groups choosing to participate in an MVP have between April 1 and Dec. 1 to submit an application to CMS. Groups must elect to participate in an MVP within this window, or the option will not be available to them for the 2026 performance year.

For more information about MVPs, read this ACR helpdesk article.