Merit-Based Incentive Payment System Participation: Radiologists Can Run but Cannot Hide.

Area of Science:

• Health Policy
• Medical Economics
• Radiology

Background:

• The Centers for Medicare & Medicaid Services (CMS) offers flexibility in the Merit-Based Incentive Payment System (MIPS) through exemptions and relaxed reporting for certain physicians and groups.
• Assessing the real-world impact of these special status determinations is essential for understanding physician participation and compliance.

Purpose of the Study:

• To evaluate the practical implications of MIPS special status determinations for radiologists.
• To determine the extent of MIPS participation requirements for individual radiologists and radiology groups.

Main Methods:

• A random sample of 1,000 Medicare-participating radiologists was analyzed.
• The CMS MIPS Participation Lookup Tool was used to assess individual and group participation requirements and special statuses for each radiologist.

Main Results:

• Considering all associated Taxpayer Identification Numbers (TINs), 83% of radiologists were required to participate in MIPS individually, and 97% of radiology groups were required to participate using the group reporting option.
• High participation rates were observed across various practice types, including generalist and subspecialist, small and rural, and academic and nonacademic practices.
• Discrepancies in special status assignments were noted between individual radiologists and group practices, particularly for non-patient-facing, hospital-based, rural, and health professional shortage area statuses.

Conclusions:

• The vast majority of radiologists face MIPS participation requirements at either the individual or group level, even if not immediately apparent from single TIN analysis.
• Radiology groups should proactively review physician MIPS participation requirements and special statuses to ensure accurate reporting and maximize performance scores and payment adjustments.