A new study from the Harvey L. Neiman Health Policy Institute highlights disparities in performance scores among radiologists participating in the Centers for Medicare & Medicaid Services (CMS) Merit-Based Incentive Payment System (MIPS). The research, published in the Journal of the American College of Radiology, found that radiologists reporting as individuals were significantly less likely to achieve high scores compared to those reporting as part of a group or an Advanced Payment Model (APM) entity.

The study analyzed data from all 22,875 radiologists participating in the 2019 MIPS program. It found that those reporting individually were 7.4 times more likely to miss the “exceptional” performance threshold, which determines eligibility for the highest payment bonuses. On average, individually reporting radiologists scored 32% lower than those in group reporting, while APM participants scored 8% higher.

MIPS, the largest component of the CMS Quality Payment Program, ties provider payments to performance through a scoring system that determines bonuses and penalties. Since its launch in 2017, the program has faced criticism from specialists like radiologists, who are not directly responsible for managing a patient’s overall care. “Since its inception, the MIPS program has raised concerns about whether radiologists and other specialties who are not directly accountable for managing a patient’s overall care can meaningfully participate in the program,” said Dr. Lauren Nicola, CEO of Triad Radiology Associates.
Beyond participation type, practice size was another major predictor of performance. Radiologists in practices with 50 or more clinicians were least likely to underperform, while those in smaller or rural practices, as well as those with more than 10 years in practice, faced greater challenges. “Despite CMS’ efforts to support smaller practice MIPS success with bonus points and reduced reporting requirements, smaller practices remain disadvantaged. Yet, evidence does not support that smaller practices provide lower quality care,” said Dr. YoonKyung Chung, principal economic and health services researcher at the Neiman Institute.

The study also examined which quality measures radiologists reported most frequently and found that APM participants often reported measures unrelated to radiology due to different reporting requirements. “None of the top 10 quality measures reported by individual and group participants in our analysis were still available for full score potential in 2024,” said Dr. Nicola.

To address these challenges, the researchers suggested that radiologists consider participating through CMS-approved MIPS qualified clinical data registries, such as the ACR National Radiology Data Registry, which offers 20 diagnostic radiology-specific measures in 2024. “Further evaluation of MIPS is needed for radiologists. This study provides important data to inform future program design that may reduce bias and better achieve the goal of incentivizing higher-value care,” said Dr. Elizabeth Rula, executive director of the Neiman Institute.

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