What is the Impact of Your 2025 MIPS Performance on Your 2027 Medicare Reimbursement

Medical practices have been coping with the burden of reporting under the Quality Payment Program (QPP) since its inception in 2017. Radiology groups commonly report in the Merit-based Incentive Payment System (MIPS) through claims data, and over the course of the program the penalties have been gradually increasing while the opportunity for a big reward through stellar performance has been diminishing. Practices performing well had the opportunity to share in the Exceptional Performance Bonus, which sunset by law following performance year 2023, and in many years exemptions were available that allowed practices to avoid penalties due to hardship circumstances.

Performance year 2025 was the first where there were no blanket exemptions available, the maximum penalty of 9% was in full effect, and no bonus is available to reward the highest performers. Since the MIPS program is budget neutral, in theory a greater number of practices receiving penalties would create a larger pool of funds for positive adjustments. As a result, the initial projection of 2025 performance is that practices reaching the maximum score of 100 points will receive only a 1.38% reimbursement adjustment in 2027 for their efforts.

The 2025 adjustment is nearly the lowest of historical MIPS positive payment adjustments, which never have reached the maximum allowed by law due to budget neutrality requirements. For 2022, a one-time additional Exceptional Performance Bonus was authorized by Congress which pushed the positive adjustment to its highest level.

Practices can obtain their score by signing in to the QPP website using their Health Care Quality Information Systems (HCQIS) Access Roles and Profile (HARP) credentials. A score of at least 75 points is needed to avoid a penalty; a score below 75 results in a reimbursement decrease in 2027. For every point above 75, multiply by 0.055 to get the percentage increase in reimbursement. As an example, a practice earning a score of 90 would receive an increase of 0.825% (90-75=15 x .055=.825%). A score below 75 points will receive a reimbursement penalty with penalties increasing gradually up to a maximum of 9%. For 2025 reporting, CMS has confirmed scores of 18.75 points or less will be subject to a penalty of 9%.

Practices that believe there may be an error in their 2025 MIPS final score may apply for a Targeted Review by November 30, 2026. Examples of errors include data being submitted under the wrong TIN or NPI, having Qualifying APM Participant (QP) status but receiving a MIPS payment adjustment, or not receiving an applicable performance category reweighting due to extreme and uncontrollable circumstances. Eligible participants can request a review through the QPP website by selecting “Targeted Review” after signing in. If a review results in a scoring change, the practice’s final score and applicable payment adjustment will be updated.

While the upside to MIPS participation is relatively small, avoiding a penalty is a significant benefit to any practice. A practice with $1,000,000 of basic Medicare reimbursement would gain $13,800 with a perfect score of 100 points, while a similar practice that suffered the maximum penalty would lose $90,000.

Be sure to review your practice’s results and apply for a targeted review if it is warranted. We will continue to monitor things that affect your reimbursement. Subscribe to this blog for all the latest information that affects your radiology practice’s reimbursement.

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