From the Chair of the Commission on Economics

Historically, CMS releases its Medicare Physician Fee Schedule (MPFS) final rule late each year. Over the course of this document, which can be thousands of pages in length, are details on how Medicare providers, including radiologists, will be reimbursed in the coming year. The rule includes an impact table that indicates the effect of CMS’s policy changes on each specialty. This year is the 16th consecutive year without a positive update in the impact table for diagnostic radiology; interventional radiology (IR) will be cut 2%, again tied for the largest cut of all specialties. Outrageously, and compounding these challenges, the Medicare provider payment rate (known as the conversion factor), which CMS finalized for use in 2025, is lower than the rate used in 1994. Given these challenges, it is crucial that radiologists engage in advocacy. Of course, no organization is better suited than the ACR to lead this effort, with its Economics, Government Relations (GR) and Quality and Safety teams coming together to advocate for our specialty and its patients.

As a member of the ACR Commission on Economics and the Measurement Strategy Committee, I have a front row view of how ACR staff and volunteers advocate for our specialty and our patients and collaborate with outside organizations, including CMS. 

As Gregory N. Nicola, MD, FACR, chair of the ACR Commission on Economics, says, “Advocacy is explaining to policymakers what we as radiologists do to improve our patient’s health. While gratification is usually not immediate and often nuanced, advocacy is part of our duty to protect our specialty and its patients.”  

Each year, the GR team sends detailed letters to CMS describing the effects of the proposed policy changes. This work has paid off. In the 2025 MPFS final rule, CMS finally agreed to cover CT colonography as a screening test for colorectal cancer for Medicare patients. In this case gratification was certainly not immediate; instead, it took the better part of two decades of work led by the ACR that culminated in this coverage announcement.

Of course, no organization is better suited than the ACR to lead this effort, with its Economics, Government Relations (GR) and Quality and Safety teams coming together to advocate for our specialty and its patients.

The ACR also helps lead a multispecialty coalition advocating for sustainable reform of the MPFS. In May 2024, the Senate Finance Committee issued a white paper acknowledging concerns of the provider community and committing to working on a long-term solution to Medicare provider reimbursement. 

Going further, the ACR has been the leader in the development and maintenance of radiology performance measures. Such measures are important for a variety of reasons, including quality improvement. It is often said that you can’t improve what you don’t measure. But beyond quality improvement, major payers like CMS use such measures in determining reimbursement. An example relevant to many radiologists is the Merit-based Incentive Payment System (MIPS). The MIPS program is part of the Medicare Fee-For-Service payment system, with payment amounts partially based on providers’ performance on a series of MIPS measures. 

While MIPS was intended to incentivize high value care by rewarding those who perform well and penalizing those who do not, the reality has been quite different. Radiology practices are not just competing against other radiology groups; they are competing against groups in every specialty that participate in the MIPS program. Over time, radiologists have become increasingly disadvantaged in MIPS. For example, in the 2025 final rule, CMS approved only six freely available quality measures for diagnostic radiology, some of which are not accessible to many groups. For comparison, a family medicine practice has more than 60 freely available quality measures from which to choose.

To address this problem, the Measurement Strategy Committee has worked with CMS, with positive results. All but one of the measures the ACR presented for inclusion in 2025 were accepted, for a total of 23 measures. The measures are part of the ACR National Radiology Data Registry^®, a robust collection of measures that are available at a discounted rate for ACR members. These measures can be used for both quality improvement and MIPS.

Looking ahead, CMS has said that it intends to wind down the traditional MIPS program in favor of a new system, the MIPS Value Pathways (MVPs). MVPs are specialty-specific, use many of the MIPS measures, and should be less burdensome for practices. Since there is not yet a radiology MVP, members of the ACR Economics, Government Relations and Quality and Safety teams have collaborated both internally and with CMS. Hopefully, the result will be MVPs that radiology practices find useful for both quality improvement and reimbursement policies.

While substantial challenges remain, the advocacy successes of the ACR reflect a commitment to collaboration — collaboration between commissions within the ACR, between staff and members and collaboration with other organizations. To paraphrase the commission chair’s words, advocacy is not easy, and results usually take time, but the work being done by the ACR is having meaningful results for radiologists and, more importantly, for our patients.