Sept. 10, 2025

Within the CY2026 HOPPS/ASC proposed rule, CMS has proposed to indefinitely maintain the voluntary status of the electronic clinical quality measure (eCQM) titled Excessive Radiation Dose or Inadequate Image Quality for Diagnostic CT in Adults. Initially finalized in 2024 for voluntary reporting beginning in 2025, the measure was expected to become mandatory by 2027 under the Hospital Outpatient Quality Reporting Program. However, CMS has reconsidered its timeline following substantial public feedback and concerns about infrastructure and resource limitations at hospitals and imaging facilities. The measure intends to monitor CT imaging practices by identifying exams that exceed size-adjusted dose or global noise thresholds. Though CMS states that hospitals and clinicians may use any compliant software to report the measure and are not restricted to specific vendors like Alara Imaging, there remain financial and workflow burdens on hospital radiology departments with outpatient practices and standalone imaging facilities.

ACR’s Position and Commitment to Radiation Safety

ACR  supports continuing voluntary reporting for this measure, recognizing the technical and operational challenges it presents. At the same time, ACR remains deeply committed to radiation dose safety and monitoring, as demonstrated through longstanding initiatives such as Image Wisely, Image Gently, and the Dose Index Registry.

While ACR suggests that facilities engage with the measure if feasible, it also acknowledges that implementation may not be practical for all institutions. 

Facilities with concerns about the measure are encouraged to submit comments to CMS to ensure their perspectives are considered in future rulemaking. Email comments to CMS staff.  

For more information, contact Samantha Shugarman, ACR Director of Quality Programs.

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