The American College of Radiology® (ACR®) submitted comments to the Centers for Medicare and Medicaid Services (CMS) Sept. 6 that address numerous issues and make specific recommendations related to the 2025 Medicare Physician Fee Schedule (MPFS) proposed rule.
CMS estimates — if the rule is implemented as proposed —an overall impact of the proposed changes to radiology, nuclear medicine and radiation oncology to be a neutral 0%, while interventional radiology would see an aggregate decrease of 2% if the provisions within the proposed rule are finalized. These impacts do not take into account the congressionally passed conversion factor updates for 2024 that expire Dec. 31.
ACR expressed strong support for CMS’ proposal to cover screening CT colonography for Medicare patients, something the College has advocated for over the past 15 years. The College did, however, express concern with the proposal to subject CT colonography to the Deficit Reduction Act (DRA) payment cap, which would result in a very low technical component payment rate for the procedure. ACR also asked CMS to fully cover any necessary follow-on colonoscopy without patient cost sharing as part of the complete screening process.
CMS included two requests for information (RFI) regarding transitioning from the traditional Merit-based Incentive Payment System (MIPS) as part of the proposed PFS Quality Payment Program updates, upon which ACR commented as summarized below.
The College’s comments regarding The Building Upon the MIPS Value Pathways (MVPs) Framework to Improve Ambulatory Specialty Care RFI highlight years of ACR’s efforts to cultivate cross-specialty relationships through joint work identifying tenets of high-value referral management and ensuring coordinated emergency department imaging-related communication and follow-up tracking for actionable and evidence-based incidental findings. ACR noted that along with the radiology community, the ACR prioritizes accurate imaging interpretation combined with concise, evidence-based recommendations in radiology reports and strives to collaborate within the care team in the coordination of care, including ensuring adherence to recommended care to achieve the best patient outcomes.
ACR’s comments about the Transforming the Quality Payment Program RFI addressed radiologists’ readiness to participate in a MIPS Value Pathway explained that, without flexibilities for non-patient-facing physicians, it is not possible to gauge radiology MIPS-eligible clinicians' capacity to adopt future radiology-focused MVPs. The College encouraged CMS to examine potential flexibilities for non-patient-facing physicians participating in a radiology-focused MVP.
The College expressed support for CMS’s proposal to remove the seven-point cap from certain topped-out quality measures identified as belonging to specialty sets with a limited selection of 10-point measures available. This would likely make several topped-out radiology measures once again eligible for 10 full achievement points, greatly improving radiologists’ ability to score well in MIPS. However, ACR did request clarification from CMS on how broadly this proposal would be implemented.
ACR also supported CMS’s proposal to simplify the Improvement Activities (IA) category by removing weight designations. Under this new proposal, most MIPS clinicians would be required to submit two IAs each year, while clinicians identified as non-patient-facing (which includes most radiologists) would only be required to submit one IA.
CMS will take comments received from all stakeholders into consideration and release its final rule in early November.
For questions about the 2025 MPFS proposed rule and ACR comments, contact Katie Keysor, ACR Senior Director, Economics and Health Policy.