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Purpose To optimize the flexibility and relevancy of its Merit-Based Incentive Payment System (MIPS), CMS exempts selected physicians and groups from participation and grants others relaxed reporting requirements. We assess the practical implications of such special status determinations. Methods For a random sample of 1,000 Medicare-participating radiologists, the CMS MIPS Participation Lookup Tool was manually searched. Individual radiologists' and associated groups' participation requirements and special statuses were assessed. Results Although only 55% of radiologists were required to participate in MIPS as individuals when considering only one associated taxpayer identification number (TIN), 83% were required to participate as individuals when considering all associated TINs. When using the group reporting option, 97% of radiology groups were required to participate. High participation requirements persisted across generalist and subspecialist radiologists, small and rural, and both academic and nonacademic practices. Non-patient-facing and hospital-based statuses were assigned to high fractions of individual radiologists (91% and 71%, respectively), but much lower fractions of group practices (72% and 25%). Rural and health professional shortage area statuses were assigned to higher percentages of groups (27% and 39%) than individuals (13% and 23%). Small practice status was assigned to 22% of individuals versus 16% of groups. Conclusion Although not apparent if only considering individual radiologist-TIN combinations, the overwhelming majority of radiologists will be required to participate in MIPS, at the individual or group level. Radiology groups are strongly encouraged to review their physicians' MIPS participation requirements and special statuses to ensure optimal performance scores and payment bonuses.

Radiology has historically been at the forefront of innovation and the advancement of technology for the benefit of patient care. However, challenges to early implementation prevented most radiologists from adopting and integrating certified electronic health record technology (CEHRT) into their daily workflow despite the early and potential advantages it offered. This circumstance places radiology at a disadvantage in the two payment pathways of the Medicare Access and CHIP Reauthorization Act of 2015: the Merit-Based Incentive Payment System (MIPS) and advanced alternative payment models (APMs). Specifically, not integrating CEHRT hampers radiology's ability to receive bonus points in the quality performance category of the MIPS and in parallel threatens certain threshold requirements for advanced APMs under the new Quality Payment Program. Radiology must expand the availability and use of CEHRT to satisfy existing performance measures while creating new performance measures that create value for the health care system. In addition, radiology IT vendors will need to ensure their products (eg, radiology information systems, PACS, and radiology reporting systems) are CEHRT compliant and approved. Such collective efforts will increase radiologists' quality of patient care, contribution to value driven activities, and overall health care relevance.

The Medicare Access and CHIP Reauthorization Act (MACRA) of 2015 describes alternative payment models (APMs) as new approaches to health care payment that incentivize higher quality and value. MACRA incentivizes increasing APM participation by all physician specialties over the coming years. Some APMs will be deemed Advanced APMs; clinicians who are a Qualifying Participant in an Advanced APM will receive substantial benefits under MACRA including an automatic 5% payment bonus, regardless of their performance and savings within the APM, and a larger payment rate increase beginning in 2026. Existing APMs are most relevant to primary care physicians, and opportunities for radiologists to participate in Advanced APMs fulfilling Qualified Participant requirements are limited. Physician-Focused Payment Models (PFPMs), as described in MACRA, are APMs that target physicians' Medicare payments based on quality and cost of physician services. PFPMs must address a new issue or specialty compared with existing APMs and will thus foster a more diverse range of APMs encompassing a wider range of specialties. The PFPM Technical Advisory Committee is a new independent agency that will review proposals for new PFPMs and provide recommendations to CMS regarding their approval. The PFPM Technical Advisory Committee comprises largely primary care physicians and health policy experts and is not required to consult clinical experts when reviewing new specialist-proposed PFPMs. As PFPMs provide a compelling opportunity for radiologists to demonstrate and be rewarded for their unique contributions toward patient care, radiologists should embrace this new model and actively partner with other stakeholders in developing radiology-relevant PFPMs.