The Centers for Medicare and Medicaid Services (CMS) recently released the proposed CY 2027 Physician Fee Schedule (PFS), which includes updates to the Quality Payment Program (QPP) and the Merit-based Incentive Payment System (MIPS).
Several of the proposed changes could have significant impacts on radiology practices. The following detailed summary highlights the key updates we’re watching closely.
Quick Take:
- Despite a proposed reduction of the PFS conversion factor, CMS impact models predict an approximately +2% impact on reimbursement for diagnostic radiology and nuclear medicine, and an approximately +3% impact for interventional radiology and radiation oncology as a result of proposed increases in RVUs.
- Traditional MIPS is proposed to end after 2028, completing CMS’s shift to the MIPS MVP program.
- CMS proposes to add a new mammography follow-up eCQM.
- The introduction of a new MIPS Core Measure framework may provide greater reporting flexibility for radiology practices than the current outcome measure requirement.
- Extending topped-out benchmark methodology to the new MIPS Core Measures would help preserve scoring opportunities and provide additional flexibility for radiology groups.
Conversion Factor and Payment Adjustments
After increasing the conversion factor (CF) in 2026 for the first time in six years, CMS is lowering physician reimbursement again with a proposed decrease for 2027. As a reminder, there are now two different CF rates to be aware of, as CMS introduced a separate CF in 2026 for qualifying Alternative Payment Model (APM) participants. The proposed CF for qualifying APM participants is $33.1693, which is a 1.19% decrease from CY 2026. The proposed CF for non-qualifying physicians decreases 1.68% to $32.8409.
The 2027 rates reflect three key factors:
- The expiration of a temporary 2.5% update enacted for CY 2026
- A statutory increase in the Medicare Access and CHIP Reauthorization Act (MACRA) of 0.75% for qualifying APM participants and 0.25% for non-APM-qualifying physicians
- A 0.53% positive budget neutrality adjustment
Positive Payment Changes
Despite the conversion factor reduction, radiology reimbursement may represent a rare bright spot next year. For radiology, the CF decrease will be offset by proposed increases in RVUs.
First, CMS is proposing three major changes in 2027 to the way it calculates and allocates indirect practice expense (PE) RVUs:
- Reallocating indirect PE allocation to better align indirect costs with work RVUs and clinical labor inputs
- Phasing out the Indirect Practice Cost Index over a two-year transition because it relies on outdated specialty survey data
- Creating a new PE stabilizer adjustment that would mitigate short-term volatility by limiting annual increases or decreases in PE RVUs to +/-5 percent for most existing services
Additionally, based on reviews of 2026 claims data, CMS is proposing increases to several individual treatment delivery codes and select diagnostic studies. Although CMS is also proposing cuts to other radiology codes, the increases are expected to outweigh the decreases.
Net reimbursement impact for radiology: Overall, CMS impact tables show the proposed rule generating a positive impact of approximately +2% for diagnostic radiology and nuclear medicine, and approximately +3% for interventional radiology and radiation oncology.
Advanced APM Changes
Most radiology groups participate through MIPS rather than Advanced APMs, but CMS is proposing one notable APM policy change.
Currently, clinicians who achieve Qualifying Participant (QP) status generally carry that designation across all billing entities where they provide services. Under the proposal, QP status would instead be tied to the specific TIN/NPI combination participating in the APM. Benefits associated with QP status would only apply to services billed through that participating entity.
Radiologists billing under multiple TINs should monitor this proposal closely if they currently participate in Advanced APM arrangements.
Merit-based Incentive Payment System (MIPS)
Traditional MIPS Is Scheduled to End After 2028
CMS plans to sunset Traditional MIPS after the 2028 performance year. Beginning in 2029, clinicians required to participate in MIPS would be reporting through a MIPS Value Pathway (MVP). (Organizations already participating in eligible APMs would continue reporting through the appropriate APM reporting pathway.)
For radiology groups that have not yet evaluated MVP reporting options, the next two years may serve as the final transition period before Traditional MIPS reporting is no longer available.
New MVPs Continue CMS’s Expansion of Specialty Reporting
CMS is proposing three new MVPs for 2027:
- Diabetic Disease MVP
- Hypertension MVP
- Hospitalist MVP
While none of these MVPs are radiology-specific, the proposal reflects CMS’s continued commitment to expanding specialty-focused reporting pathways. CMS is also proposing to allow virtual groups to participate in MVP reporting beginning in 2029.
Quality Category Updates
CMS is proposing several significant updates within the Quality category:
- The addition of two new quality measures focused on prevention and chronic disease management
- Adoption of some existing QCDR measures into the MIPS CQM inventory
- Removal of 20 quality measures
- Substantive revisions to 43 existing quality measures
The most significant radiology-specific measure proposal is a new eCQM focused on breast cancer screening follow-up:
- Rate of Timely Follow-Up of Abnormal Screening Mammograms for Breast Cancer Detection
The measure evaluates female patients ages 40 to 75 who receive an abnormal screening mammogram and subsequently receive timely diagnostic resolution, either through follow-up imaging with appropriate findings or biopsy within 60 days. CMS has proposed a one-year delay before implementation.
This proposal is particularly important for mammography-focused imaging centers. Historically, many mammography-only facilities have had few, if any, applicable quality measures available. If finalized, this measure would create a meaningful quality reporting opportunity for those organizations. At the same time, it may also create new reporting obligations and operational expectations related to follow-up tracking and documentation.
Overall, all radiology groups should pay close attention to any measure specification updates affecting currently reported measures, as these changes may alter reporting requirements, benchmarks, or eligible patient populations.
A Major Win for Radiology: MIPS Core Measures Replace Outcome Measure Requirements
One of the most impactful proposals for radiology may be the replacement of the current outcome measure requirement.
Under current rules, participants must report at least one outcome measure. If no applicable outcome measure exists, a high-priority measure must be reported instead. This has historically created challenges for radiology. Many radiologists have had very limited outcome measure options available. In some cases, especially within MVP reporting, only a single outcome measure was available, significantly restricting selection flexibility.
CMS is proposing to replace the outcome/high-priority requirement with a new MIPS Core Measure framework.
Under the proposal:
- Approximately 78 measures would be designated as Core Measures.
- Participants would simply need to report one applicable Core Measure as part of their quality submission, within either Traditional MIPS or MVP.
- The Core Measure counts toward the overall measure requirement.
- Small practices would be exempt.
- Groups with no applicable Core Measures could submit an attestation and select an alternative measure instead.
The proposed radiology Core Measures are:
- Measure 145: Radiology: Exposure Dose Indices Reported for Procedures Using Fluoroscopy
- Measure 360: Optimizing Patient Exposure to Ionizing Radiation: Count of Potential High Dose Radiation Imaging Studies (CT and Cardiac Nuclear Medicine Studies
- Measure 405: Appropriate Follow-up Imaging for Incidental Abdominal Lesions
For radiology organizations that have struggled to meet the existing outcome measure requirements, this proposal could provide more flexibility.
Topped-Out Measure Changes May Benefit Radiology
Radiology has benefited from CMS’s defined topped-out benchmark methodology in recent years due to the specialty’s limited measure inventory. Measures commonly reported by radiology groups, including Measures 145, 360, 364, 405, and 406, have already received this special benchmark treatment.
The 2027 proposed rule would further strengthen this approach by allowing topped-out measures designated as MIPS Core Measures to continue using defined benchmarks without being subject to the traditional seven-point scoring cap. For radiology practices, this helps preserve scoring opportunities while providing additional flexibility under the proposed Core Measure framework.
Improvement Activities
CMS is proposing:
- 6 new Improvement Activities
- 5 modified Improvement Activities
- 11 removed Improvement Activities
Many of the proposed additions focus on prevention, wellness, nutrition, and chronic disease management.
Extreme and Uncontrollable Circumstances (EUC)
CMS is proposing to remove the requirement that automatic Extreme and Uncontrollable Circumstances (EUC) determinations rely specifically on PECOS data. This change would not affect the standard hardship application process but would provide CMS with greater flexibility when applying automatic EUC relief.
Performance Threshold Remains Unchanged
CMS is not proposing any changes to the MIPS performance threshold. The score required to avoid a negative payment adjustment remains 75 points, a threshold that has already been finalized through Performance Year 2028.
Looking Ahead
The 2027 Proposed Rule continues CMS’s shift toward specialty-focused reporting and MVP participation. For radiology practices, the proposed Core Measure framework, changes to QP status, and new mammography measure may represent some of the most meaningful changes in the rule. While the proposals are not final, now is an excellent time for radiology groups to begin assessing how future reporting requirements may evolve and identifying areas where workflow or reporting adjustments may be needed.
Stakeholders should also consider submitting comments on the proposed rule to share operational concerns, financial impact questions, and recommendations for implementation. The public comment period is open through September 14, 2026, with a final rule expected later this fall.
As always, the Ventra Health team will be monitoring the changes and planning for all issues that will impact our clients. Additional information and resources are available in our general overview of the CY 2027 Physician Fee Schedule Proposed Rule.
If you have questions about how these changes will impact your practice, please don’t hesitate to contact us.
