MIPS Value Pathways (MVP) Overview

Purpose

The Centers for Medicare & Medicaid Services (CMS) introduced MIPS Value Pathways (MVPs) to simplify reporting and align measures with clinical practice. For 2026, ACR members in Diagnostic Radiology (DR) and Interventional Radiology (IR) may participate in specialty-specific MVPs designed to reduce reporting burden and improve relevance.

MVPs can be reported in lieu of the traditional Merit-based Incentive Payment System.

Why It Matters

• MVPs are CMS’s new approach to streamline MIPS reporting by offering a smaller selection of Quality measures and Improvement Activities.
• Specialty-specific pathways reduce burden by reducing the number of measures required and offering reporting options more relevant to specific specialties.
• CMS will eventually sunset traditional MIPS and only support MVP participation. 

Key Dates

• Performance Year: January 1 – December 31, 2026
• MVP Enrollment Deadline: April 1 – December 1, 2026
• Submission Deadline: March 31, 2027

Overview of MIPS Value Pathways (MVPs)

• What is an MVP: Brief definition and CMS intent behind MVPs.
• How MVPs differ from traditional MIPS reporting 

DR and IR MVP Structure

    Components of Each: 

• Quality Measures
  • Requires four measures rather than six, with at least one Outcome measure.
• Improvement Activities
  • As with traditional MIPS, non-patient facing participants will be required to attest to one activity.
• Cost measures
  • Includes only the Total Per Capita Cost (TPCC) measure; groups who are exempt from the TPCC will have their Cost score reweighted.
• Promoting Interoperability
  • As with cost, most radiologists will be exempt from this category.

Eligibility and Participation Requirements

• Who can report under DR and IR MVPs? 
  • Much like traditional MIPS, eligible clinicians can participate in MVPs as groups, subgroups, individuals, or APM entities.
• Enrollment Process 
  • Facilities have between April 1 and December 1 of the current participation year to register for MVP submission. To register for 2026 MVP submission, login to your QPP account and choose the “Registration” tab.
  • Click “Register or edit an MVP registration” and then complete the application.
  • Note that groups who register for MVP submission are not obligated to submit under the MVP. Groups can still elect to report under traditional MIPS.
• Technical Requirements 
  • Use of QCDR, registry, or other CMS-approved mechanisms.

Next Steps to Prepare for 2026 Reporting

• Assess Readiness 
  • Review available measures and Improvement Activities; if 
  • The process of data collection and uploading is unchanged from measures in traditional MIPS, but there is one important thing to consider:
    • As with traditional MIPS, an outcome measure is required (if eligible to report it). This year the only outcome measure within the Diagnostic Radiology MVP is the new eCQM #494, for which all radiology groups who read CT exams will be identified as eligible. Data collection for this measure’s specific elements requires third party software.
• Select Reporting Mechanism 
  • Groups using the NRDR QCDR to submit MVP data must simply provide their MVP  enrollment number under the Manage Physician Groups tab in NRDR. These 
• Identify Required Measures 
  • Quality, Improvement Activities, PI, Cost.
• Compliance and Documentation 
  • Ensure interoperability and data submission standards.

Resources and Support

• ACR Tools and Guidance 
  • Links to ACR MVP resources.
  • FAQs and help desk information.
• CMS Resources 
  • MVP-specific documentation and submission portals.
• Strategies for Success 

During the MIPS 2026 Performance Year

• CMS allows clinicians or groups to submit data through multiple reporting options (e.g., MVP, traditional MIPS, APM Performance Pathway).
  If you submit both: 
  • CMS will calculate a score for each reporting option.
  • You will receive the highest final score across all options for the performance year.

 Why Would You Report Both?

• Safety Net Strategy: 
  • If you’re unsure about MVP readiness or measure performance, reporting both ensures you don’t risk a lower score.
• Maximize Incentives: 
  • MVPs are specialty-focused, so they may give you better performance in Quality and Improvement Activities.
  • Traditional MIPS might still be advantageous if you have strong historical performance on measures outside the MVP set.

 How CMS Chooses the Best Score

• CMS compares: 
  • MVP Score (Quality + Cost + PI + Improvement Activities).
  • Traditional MIPS Score (same categories but broader measure set).
• Whichever is higher becomes your final MIPS score for payment adjustment.

Practical Considerations for Radiologists

• Non-Patient-Facing Radiologists: 
  • Often exempt from PI, so MVP participation can simplify reporting.
• Facility-Based Radiologists: 
  • If you qualify for facility-based scoring, CMS may apply the hospital’s VBP score automatically—but you can still report MVP for a potentially higher score.
    
• Registry Reporting (ACR NRDR/QCDR):
  • Supports both MVP and traditional MIPS, so you can submit both without doubling your workload.