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MIPS 2025: Essential Updates and Strategies for Pathologists and Radiologists

MIPS 2025: Essential Updates and Strategies for Pathologists and Radiologists

January 30, 2025

As the Medicare Physician Fee Schedule (PFS) Final Rule for 2025 takes effect, radiologists and pathologists must navigate key updates to the Merit-Based Incentive Payment System (MIPS). Understanding these changes and optimizing participation strategies is essential to avoiding the up to 9% negative payment adjustment on 2027 Medicare claims.

Under MIPS, there are three participation options:

  • Traditional MIPS – Established the first year of the program where your performance is measured across 4 areas: quality, improvement activities, promoting interoperability, and cost. The majority of pathologists and radiologists will participate in Traditional MIPS.
  • MIPS Alternative Payment Model (APM) Pathway – MIPS APMs are designed for clinicians in specific Alternative Payment Models (APMs), such as Accountable Care Organizations (ACOs).
  • MIPS Value Pathways (MVPs) – MIPS Value Pathways (MVPs) are the newest reporting option to fulfill MIPS reporting requirements. While CMS is introducing MIPS-VPs, none have been finalized for pathology or radiology as of the 2025 performance year. This limits their current adoption in these specialties.

Listed below are several key highlights and program updates impacting radiologists and pathologists.

Weighting

  • Preserved Category Weights – The MIPS category weights for the 2025 performance year will remain unchanged.
  • Maintained Reweighting – The previously established reweighting special status formulas associated with cost and promoting interoperability for non-patient-facing clinicians and small practices (15 or fewer physicians) will continue without modification.
MIPS Performance Category Category Weights Large Practice Non-Patient Facing Small Practice Non-Patient Facing
Quality 30% 85% 50%
Improvement Activity 15% 15% 50%
Cost 30%
Promoting Interoperability (PI) 25%

Quality

  • Removing the 7-Point Cap for Topped-Out Measures: CMS removed the 7-point cap for certain topped-out quality measures in specialty sets with limited measures, allowing these measures to be scored up to 10 points. This change benefits both radiologists and pathologists reporting such measures.
  • Maintaining the Performance Threshold and Data Completeness: CMS retained the performance threshold at 75 points for the 2025 performance period. The data completeness criteria also remain at 75% through the 2028 performance period, ensuring consistency in reporting requirements.
  • Added New Radiology Measure – QPP 494: Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography (CT) in Adults (Clinician Level) – This measure, initially finalized in the 2024 rule with a delay, is now active for 2025.
  • Removed Radiology Measure – QPP 436: Radiation Consideration for Adult CT: Utilization of Dose Lowering Techniques – Previously finalized for removal with a one-year delay, this measure is no longer available in 2025.
  • Revised Pathology Measure – QPP 249: Barrett’s Esophagus Pathology Reporting – The denominator exception now includes “Specimen site other than anatomic location of esophagus: G8797.”

Improvement Activities

  • Simplified Scoring for Improvement Activities: Scoring of the Improvement Activities category was simplified by eliminating the weights associated with activities. Previously, activities were identified as either high-weight or medium-weight. With this new change, all activities will be weighted equally.
  • Removed Activities: CMS streamlined the Improvement Activities inventory, removing several activities, including those frequently utilized by radiologists and pathologists:
    • ERP_4: Implementation of a Personal Protective Equipment (PPE) Plan – removed 2025
    • ERP_5: Implementation of a Laboratory Preparedness Plan – removed 2025
    • CC_1: Implementation of use of specialist reports back to referring clinician or group to close referral loop – scheduled for removal in 2026
    • CC_2: Implementation of improvements that contribute to more timely communication of test results – scheduled for removal in 2026

Cost and Promoting Interoperability

  • CMS finalized several new episode-based Cost measures unlikely to be attributed to pathology or radiology groups but may contain imaging in the cost calculations: Chronic Kidney Disease, End-Stage Renal Disease, Kidney Transplant Management, Prostate Cancer, and Rheumatoid Arthritis.
  • Clinicians with small practice and non-patient facing clinician special status will continue to receive automatic weighing of this category.

Cost and Promoting Interoperability

CMS is gradually transitioning clinicians toward MIPS Value Pathways (MVPs) as part of its long-term strategy to simplify and streamline the MIPS program. While participation in MVPs is not mandatory yet, CMS has made it clear that MVPs will eventually become the default framework for the MIPS program. While CMS is introducing MIPS-VPs, none have been finalized for pathology or radiology as of the 2025 performance year. This limits their current adoption in these specialties.

CMS introduced six new MVPs for the 2025 performance period, covering areas such as ophthalmology, dermatology, gastroenterology, pulmonology, urology, and surgical care. Additionally, two neurology-focused MVPs were consolidated into a single neurological MVP. While these MVPs may not directly impact radiologists and pathologists, they represent CMS’s ongoing efforts to refine and expand the MVP framework.

Optimize Scoring

Listed below are 5 ways to optimize your MIPS score

  1. Analyze Quality Measure – Understand the requirements impacting the number of points awarded for each quality measure including data completeness, minimum case requirements, benchmark and topped out. CMS will release the 2025 Quality Benchmarks on the Benchmarks page of the QPP website in late January 2025 which will display the points distribution per measure.
  2. Document Performance Met on Quality Measure – Coding a MIPS quality measure Performance Not Met because the documentation doesn’t support the measure will negatively impact the quality score. Therefore, pathologists and radiologists should include the required report documentation, defined by CMS, in the medical report to avoid coding Performance Not Met.
  3. Attest to Improvement Activities – Attest to performing improvement activities. At the end of the program, participants are required to “attest” to having performed an improvement activity for 90 continuous days. Clinicians with small practice and non-patient-facing special status must attest to one activity, while all other clinicians must attest to two activities.
  4. Submit Interoperability Requirements – For larger practices with over 15 physicians without the non-patient facing special status exemption, use an electronic health record (EHR) technology that meets the health IT certification criteria and submits the performance measures in each objective.
  5. Identify Special Status – Visit qpp.cms.gov to review your MIPS eligibility and determine which special status exemptions are applicable. This will help identify how your MIPS score will be calculated based on performance weighting.

Additional Resources:

 

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