CMS Opens Public Comment Period for Two Radiology MIPS Value Pathways

The Centers for Medicare and Medicaid Services (CMS) began transitioning participation in the traditional Merit-based Incentive Payment System (MIPS) to MIPS Value Pathways (MVPs) in 2023 to reduce the measure reporting burden (e.g., overall time spent toward activities related to clinical documentation, time spent in clinical review, administrative tasks) and streamline and simplify MIPS-eligible clinicians’ measure selection and reporting experience.

CMS said measures and activities included in MVPs must be linked by a condition or specialty topic so that care quality and associated costs may directly inform on value for patients and clinicians. Currently, radiologists participate in traditional MIPS because CMS has not finalized MVPs appropriate to the care they provide.

CMS shared a draft of the Diagnostic Radiology MVP earlier this year and met with American College of Radiology® (ACR®) measurement and economics leaders and staff. The College in response submitted a letter with feedback on the draft MVP, suggesting additional measures so that a wider range of MIPS-eligible radiologists could participate.

CMS released six candidate MVPs across multiple specialties Dec. 11, that it is considering for 2026 rulemaking, including Diagnostic Radiology and Interventional Radiology MVPs.

Parties interested in sharing MVP feedback must submit to PIMMSMVPSupport@gdit.com for consideration by 11:59 pm ET, Jan. 24. Emails should include:

• Subject Line: Draft 2026 MVP Candidate Feedback. 
• Email Body: Feedback for consideration and public posting. Indicate the MVP to which comments relate.

If you have any questions or would like to share your comments about the Diagnostic Radiology and Interventional Radiology MVPs with the College, contact Samantha Shugarman, ACR Director of Quality Programs.