What are MVPs?
MVPs are a new reporting option developed by the Centers for Medicare and Medicaid Services (CMS) intended to enhance clinician participation in MIPS. It organizes performance measures around specific medical specialties or clinical conditions, making the process more focused and relevant to everyday practice.
Each MVP includes a defined set of quality and cost measures, improvement activities, and foundational elements like population health and interoperability measures. CMS states that the goal of MVPs is to reduce reporting burden, support team-based care, and better align performance with the type of care clinicians provide.
Are there MVPs for radiologists?
Since CMS adopted MVPs for reporting program data beginning in performance year 2023, it has gradually included more each year and modified existing ones that focus on medical specialties as part of the formal Medicare Physician Fee Schedule (MPFS) rule-making process. It was not until this year that CMS proposed the inclusion of the Diagnostic and Interventional Radiology MVPs in the MPFS Calendar Year 2026 Proposed Rule.
What does this mean for my participation in the MIPS program?
CMS has signaled its intent to sunset traditional MIPS beginning in performance year 2029. This means that if the proposed radiology MVPs become adopted for use beginning in performance year 2026, radiologists may choose to participate in the MVP most applicable to their practice or continue with traditional MIPS. However, when CMS eventually removes traditional MIPS as a program participation mechanism, clinicians must elect the MVP they will use to report MIPS data to CMS or automatically receive that MIPS year’s negative payment adjustment.
How is ACR advocating for radiologists in the MVP space?
ACR has actively worked to ensure that the proposed radiology MVPs accurately reflect the realities of radiologic practice. ACR member leaders have participated in discussions with the Centers for Medicare & Medicaid Services (CMS) during the development of both the Diagnostic and Interventional Radiology MVPs, providing valuable input on the selection and structure of the measures included. In January 2025, ACR submitted formal comments during the public review period for the candidate MVPs for 2026. Among the recommendations were the incorporation of a broader range of quality measures that address the many radiology subspecialties, allowance for the use of Qualified Clinical Data Registry (QCDR) measures, and greater flexibility for group and multispecialty practices. The comment letter emphasized the importance of recognizing the unique roles of non-patient-facing radiologists and their capacity to participate successfully in all performance categories. It also highlighted the need to reduce reporting burdens while ensuring that MVPs remain practical and relevant for radiologists.
Radiologists have limited options when selecting MIPS quality measures that reflect their scope of work. Many of the existing MIPS measures are designed for primary care or other specialties that involve direct patient interaction, which does not align with the consultative and procedural nature of radiology. To address this measure gap, ACR launched a nimble measure development process. This process starts with individual members and ACR groups (like commissions and committees) proposing new measure concepts or measures used locally. Under the oversight of the Metrics Committee, these ideas are refined and developed into formal quality measures. Once finalized, ACR staff submit them to CMS for consideration as either MIPS measures or QCDR (Qualified Clinical Data Registry) measures.
Questions and Comments
For questions, please submit a support request through the NRDR Support ticketing system. Submit comments about the proposed MVPs by completing this form.