Rapid-fire regulatory changes and funding cuts at the federal level are creating uncertainty around Medicare and Medicaid reimbursement. Many clients are asking us what these changes at the Centers for Medicare and Medicaid Services (CMS) will mean for the Merit-based Incentive Payment System (MIPS).
This is what we know so far.
CMS has not announced changes to MIPS
Dr. Mehmet Oz was confirmed by the U.S. Senate as the new CMS administrator on April 3, 2025, and he released an official statement outlining his agenda and vision for the agency the following week.
Since then, we’ve received a flurry of communication from CMS, but none that specifically addressed MIPS. Several organizations have been outspoken about requesting changes to the Merit-based Incentive Payment System program, including the American Medical Association (AMA), which recently presented a proposal for a MIPS alternative that is currently under review by CMS.
We are closely monitoring all communications from CMS to ensure that we proactively address any changes that will impact client processes or reimbursement. For MIPS reporting, however, it is business as usual for now.
Recent MIPS changes were beneficial for Radiology
CMS did finalize changes to MIPS for Radiology last fall that will make it significantly easier for groups to be successful with MIPS reporting. In particular, CMS is now applying an alternative benchmarking methodology, 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. As an example, a Radiology group that earned 74.85 points in 2024 under the topped-out model would now achieve a score of 97.33 for the same metrics and performance in 2025.
While CMS will re-evaluate the list of included measures annually, the 2025 list includes all the topped-out Diagnostic Radiology measures.
For a more complete discussion of these and other MIPS rules for 2025, please read our recent blog post.
Stay focused on MIPS
It may be tempting to put MIPS reporting on the back burner while we wait to see where the CMS changes net out. We don’t recommend that approach.
Clinicians are eligible and required to participate in the MIPS incentive program if they meet all the following criteria:
- Bill more than $90,000 in Medicare Part B-covered professional services
- See more than 200 Medicare Part B patients
- Provide more than 200 covered professional services to Medicare Part B patients
With a high percentage of Medicare patients, Radiologists often do meet the criteria for MIPS reporting. Eligible providers who fail to report in 2025 could potentially see up to a 9% penalty on all Medicare Part B claims in 2027. This -9% adjustment could represent a significant impact to a practice’s annual revenue.
We are here to help
As always, the Ventra Health team is monitoring the entire regulatory landscape, and we will keep you informed about any changes to the MIPS program or to CMS policies. We do expect to see a new proposed rule this summer, which will likely provide clarity on the future of the Merit-based Incentive Payment System program.
In the meantime, our Data & Analytics and Customer Success teams will continue to provide the metrics and support you need, not only for MIPS reporting but also for payer contracting, facility subsidy negotiations, and overall revenue cycle optimization. Please reach out to our team with any questions
