MIPS Reporting for Radiology and Imaging Groups: Measure Selection, Promoting Interoperability, and Where Practices Lose Points

A radiology group with a strong clinical reputation can still land in negative payment adjustment territory under MIPS. The physicians are not reading fewer studies or producing worse outcomes than anyone else. The scorecard radiology gets simply does not match the one primary care gets.

Fewer quality measures apply, and Promoting Interoperability works differently for hospital-based readers than for office-based physicians. The categories that end up carrying the final score are often not the ones a practice spent the most time on.

For the 2026 performance year, the MIPS performance threshold sits at 75 points. A score below it produces a negative payment adjustment on Medicare Part B claims two years later.

The data completeness threshold is 75 percent of eligible patients or encounters per measure. Those numbers are the same for every specialty. What differs for radiology and imaging groups is the mechanics underneath them, and that is where most of the point loss happens.

Why Radiology’s MIPS Scorecard Looks Different

Most diagnostic radiologists qualify for one or more special statuses under MIPS: non-patient-facing, hospital-based, ASC-based, or small practice (15 or fewer clinicians). Each status changes how CMS weights the four performance categories.

Under the standard model, Quality and Cost are each weighted 30 percent of the final score, Promoting Interoperability (PI) 25 percent, and Improvement Activities (IA) 15 percent. Radiology groups rarely operate under the standard model.

A group that qualifies as hospital-based or non-patient-facing typically gets PI automatically reweighted to 0 percent. When only PI is reweighted, that 25 percent moves to Quality, which becomes 55 percent of the score. Many radiology groups, however, also have Cost left uncalculated because too few episodes are attributed to them, and when both PI and Cost are reweighted, Quality climbs to 85 percent for a large group. The scenario a given practice lands in depends on whether Cost is attributed:

That distribution explains a pattern that catches many radiology administrators off guard. For a large group with both PI and Cost reweighted, Quality can carry 85 percent of the final score, and even with Cost scored it still carries 55 percent. Either way, a single low-scoring or improperly benchmarked measure does far more damage to a radiology group’s composite score than it would to a primary care practice, which spreads that same weight across a wider measure set and a fuller category mix.

Quality Measure Selection: Working With a Narrow Set

Radiology’s specialty measure set is short. Traditional MIPS reporting requires six measures, including at least one outcome measure, or a high-priority measure if no outcome measure applies. That rule does not hold when the specialty measure set itself contains fewer than six measures.

In that case, a group reports every measure in the set. Radiology and interventional radiology measure sets frequently fall into that second category. This removes the flexibility other specialties have to swap out a weak performer for a stronger one.

Getting this right without outside help is possible, but many groups work through measure selection and benchmark modeling early in the performance year, before the numbers lock in, rather than discovering a weak benchmark after the fact with the help of MIPS consulting partners.

Two rule changes for 2025 and 2026 work in radiology’s favor here. First, CMS removed the 7-point scoring cap that previously applied to topped-out measures within limited specialty sets. Several radiology measures can now score up to 10 points instead of being capped below full credit.

Second, CMS finalized new MIPS Value Pathways, or MVPs, covering diagnostic radiology for the 2026 performance year. These are among the first radiology-specific MVPs made available. Adoption remains optional, and most groups are still reporting through traditional MIPS or a Qualified Clinical Data Registry such as the ACR’s NRDR.

Measure selection decisions that hold up well for radiology groups include:

• Confirm which measures in the applicable specialty set are still active. CMS retires and modifies measures every performance year, so a measure reported successfully last year is not guaranteed to exist under the same specification this year.
• Check each candidate measure’s historical benchmark decile distribution before committing, since a measure with a compressed benchmark can cap achievable points regardless of clinical performance.
• Report through a QCDR when the group’s procedure mix (interventional radiology, mammography, nuclear medicine) is better represented outside the standard specialty set.
• Model Quality category performance under the reweighted weighting scenario before the performance year closes, not after. A late benchmark surprise in a single measure carries more weight than it would for a specialty with even category distribution.

Promoting Interoperability: The Category Most Radiology Groups Get Wrong

PI is where radiology-specific MIPS reporting produces the most confusion, and it runs in two directions.

The first mistake is treating PI as automatically irrelevant. Most hospital-based and non-patient-facing radiologists do qualify for automatic PI reweighting, and CMS does not require these groups to report the category. But an automatic exemption from reporting is not the same as an automatic benefit from skipping it.

When a group has access to a hospital’s certified EHR and reports through it, PI scores tend to run high relative to Quality performance in a compressed specialty measure set. It is worth requesting a PI report from hospital IT well before the submission deadline.

Hospital IT teams often serve dozens of provider groups on the same cycle. That report lets a group decide whether contributing the PI score actually raises the composite, instead of leaving PI reweighted out by default.

The second mistake is misclassifying special status in the first place. Status determination for PI exemption depends on claims-based criteria that CMS applies automatically. But groups that changed billing structure, added office-based imaging locations, or shifted clinicians between hospital-employed and independent status mid-year should double check.

Their assumed exemption often does not match what CMS actually determined. Verifying special status through the QPP Participation Status lookup, rather than assuming last year’s status carried forward, catches this before it becomes a scoring surprise.

For groups that do report PI, typically office-based imaging centers and independent radiology practices, the 2026 rule year adds several requirements that generate avoidable point loss:

• The electronic case reporting, or eCR, measure now determines the full score for the Public Health and Clinical Data Exchange objective. Groups not actively submitting eCR data receive zero points on that objective, rather than a partial score.
• The Security Risk Analysis measure now requires attesting not only that an SRA was conducted, but that identified vulnerabilities were actually remediated. That is a second attestation component that audits will check against documentation.
• CMS requires the 2025 SAFER Guides for the 2026 performance year, replacing the 2016 version many practices still reference in their compliance documentation.
• An optional bonus measure for Public Health Reporting Using TEFCA is available for up to 5 combined PI bonus points. It only applies to groups actively engaged with a public health agency through TEFCA’s validated data production option.

For imaging groups, PI performance depends on bidirectional data exchange between PACS, RIS, and referring EHR systems. Interoperability infrastructure that actually supports certified exchange, rather than one-way image delivery, determines whether these measures are achievable at all. That is independent of documentation effort.

Where Radiology and Imaging Groups Actually Lose Points

Across measure selection and PI, the recurring failure points for radiology and imaging groups are rarely about clinical performance. They are procedural:

• Status misdetermination. Assuming hospital-based or non-patient-facing status carried over from the prior year, without re-verifying it, causes two problems. A group CMS already exempted might attempt a PI submission anyway. Or a group that no longer qualifies for exemption might miss the reporting opportunity entirely.
• Falling short of the 75 percent data completeness threshold on a Quality measure. This often happens because a subset of studies read through a locum or teleradiology arrangement were not captured in the same reporting workflow as the core group’s data.
• Improvement Activities attestation gaps. Group reporting requires that at least 50 percent of the group’s clinicians actually performed the attested activity, for a minimum of 90 continuous days. Attesting for the group without confirming that threshold across all NPIs creates exposure in a CMS audit. Supporting documentation should be retained for six years, consistent with CMS record-retention guidance.
• Conflicting submission mechanisms. Reporting the same measure through a QCDR and an EHR vendor simultaneously can backfire. So can reporting through both group and individual channels for overlapping clinicians. Either one can cause CMS to apply the lower-scoring submission, or reject the measure outright.
• Leaving PI bonus measures unclaimed. This happens when groups that do report PI have not updated their measure set. Newly available bonus points, like the TEFCA public health measure, go unclaimed as a result.
• Treating MVP eligibility as irrelevant. Groups skip evaluating whether the new diagnostic radiology MVPs reduce reporting burden for their specific procedure mix. MVP reporting also simplifies Improvement Activities to a single attestation, which many groups overlook.

Closing the Gap

This is not a single-department problem. Measure selection sits with whoever owns quality reporting. PI mechanics sit with IT and compliance. Status determination sits with billing. Radiology and imaging groups that consistently clear the 75-point threshold run these three functions as one coordinated MIPS workflow.

They do not treat them as three separate year-end scrambles. That means modeling category weights before the performance year closes. It means confirming special status against CMS’s own determination, not assumption. And it means treating PI as a decision point, not a default exemption.

The rules shift enough year over year, through topped-out measure caps, PI bonus measures, and MVP availability, that a group optimizing against last year’s scorecard is often solving the wrong problem.

The performance threshold is holding at 75 points through the 2028 performance year. For radiology and imaging groups, the score that clears it is decided less by clinical quality and more by whether measure selection, status determination, and PI mechanics were treated as connected decisions, instead of three separate reporting tasks.