The Centers for Medicare and Medicaid Services (CMS) recently released the final rule for the 2025 Quality Payment Program (QPP). This rule outlines the participation of eligible clinicians and groups in the Merit-based Incentive Payment System (MIPS), Alternative Payment Models, and other QPP features during the 2025 performance year with a 2027 payment year.
We are excited to report that CMS finalized changes this year that will make it significantly easier for Radiology groups to be successful with MIPS reporting. These are the key updates and announcements you must know for 2025.
MIPS Thresholds and Category Weighting
- The MIPS performance threshold will remain at 75 points through CY 2027.
- The data completeness threshold remains at 75% for the MIPS Quality Performance Category through the CY 2028 performance period, possibly rising to 80% in CY 2029.
- There were no overall changes to the 2025 weighting of the four reporting categories: Quality, Improvement Activities, Cost, and Promoting Interoperability. However, qualifying for Special Status (small, non-patient facing, etc.) will continue to affect the weighting of categories for individuals or groups. Check your Special Status when it becomes available in December 2025 to see what may be re-weighted.
Category Updates
Quality
CMS is now applying an alternative benchmarking methodology in the Quality category, removing the 7-point cap on measures from specialty sets with a limited number of measures available.
Each quality measure is scored based on performance within the measure. Deciles are assigned a points score, and highly topped-out measures were previously limited to a 7-point maximum. Removing the cap has the potential to dramatically increase scores for these specific measures. While CMS will re-evaluate the list of included measures annually, the 2025 list includes all the topped-out Diagnostic Radiology measures:
- #360 – OPEIR: Count of Potential High Dose Radiation Imaging Studies: Computed Tomography (CT) and Cardiac Nuclear Medicine Studies
- #364 – OPEIR: Appropriateness: Follow-up CT Imaging for Incidentally Detected Pulmonary Nodules According to Recommended Guidelines
- #405 – Appropriate Follow-up Imaging for Incidental Abdominal Lesions
- #406 – Appropriate Follow-up Imaging for Incidental Thyroid Nodules in Patients
Note: One measure was removed entirely:
- #436 – Radiation Consideration for Adult CT — Utilization of Dose Lowering Techniques
To illustrate the significance of the benchmarking change, a Radiology group that earned 74.5 points in 2024 under the topped-out model would now achieve a score of 97.16 for the same metrics and performance in 2025.
Old Benchmarks
Measure | Performance Rate (%) | Decile Score |
360 | 100% | 7 |
364 | 100% | 7 |
405 | 99% | 4 |
406 | 99% | 4 |
322 | 100% | 10 |
145 | 100% | 10 |
Total Quality Points | 42 | |
Estimated MIPS Score | 74.50 |
New 2025 Benchmarks
Measure | Performance Rate (%) | Decile Score |
360 | 100% | 10 |
364 | 100% | 10 |
405 | 99% | 9 |
406 | 99% | 9 |
322 | 100% | 10 |
145 | 100% | 10 |
Total Quality Points | 58 | |
Estimated MIPS Score | 97.16 |
* This calculation is made with the assumption that the practice does not have any applicable Cost measures and has received full points for the Improvement Activity category.
Improvement Activities
CMS has removed three common Radiology-specific Improvement Activities beginning in 2025:
- IA_EPA_1 – Provide 24/7 Access to MIPS Eligible Clinicians or Groups Who Have Real-Time Access to Patient’s Medical Record
- IA_CC_1 – Implementation of use of specialist reports back to referring clinician or group to close referral loop
- IA_CC_2 – Implementation of improvements that contribute to more timely communication of test results
Clinicians, groups, and virtual groups with a Special Status attest to one activity, where all other clinicians and groups must attest to two. Check your 2025 MIPS eligibility to determine any Special Status.
Cost
CMS modified the scoring methodology starting in 2024 to increase points awarded in the Cost category. The median performance score will receive 7.5 points. Points are awarded based on standard deviation from the median performance. Under this new methodology, CMS anticipates an additional 3.89 points in the Cost performance category for clinicians with at least one Cost measure.
Promoting Interoperability
PI is voluntary for most hospital-based physicians and groups, and their categories are automatically re-weighted to omit PI. However, PI scores are typically high and can offset lower Quality measures when contributed toward your final score. We recommend contacting hospital IT to request a PI report for 2025, ideally by September 2025.
MIPS Value Pathways (MVPs)
CMS remains committed to the MIPS Value Pathways program, introducing six new MVPs for 2025: Ophthalmology, Dermatology, Gastroenterology, Pulmonology, Urology, and Surgical Care. However, there are currently no MVPs specific to Radiology.
Physician Fee Schedule
For 2025, the conversion factor (CF) is set at $32.3465, marking a 2.83% decrease from the 2024 CF of $33.2875. This decrease resulted from a temporary update that expired at the end of 2024. The impact of the conversion factor rate may vary based on a practice’s procedural charge volumes, site of service, modality charge mix, and practice-specific billing arrangements. Radiology groups need to consider the potential financial implications of this change and adjust their budgets accordingly.
Beyond MIPS
The 2025 changes particularly in the Quality category are likely to improve MIPS performance for Radiology Groups. Additionally, Ventra encourages groups to think beyond MIPSwhen it comes to quality outcomes tracking, because data collected for MIPS reporting can also be leveraged with your facilities and payers. Quality outcomes can be used for value-based care contracts, as well as credentialing and licensing. Groups with strong QI programs are also likely to improve their professional satisfaction and increase their appeal to potential hires. This approach to QI empowers Radiology groups to take control of their quality outcomes and build stronger relationships with key stakeholders.
