The Slowing of the Quality Payment Program

What does the delay in implementation mean for your practice?

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In 2015, MACRA was introduced to considerable fanfare. The new legislation replaced the Sustainable Growth Rate physician payment formula with the Quality Payment Program (QPP). MACRA promised to stabilize physician payments, consolidate and simplify quality reporting programs, and provide a useful on-ramp to new value-based payment models. The legislation passed with overwhelming bipartisan support in both houses of Congress.

The implementation timeline of the QPP was aggres­sive. Full implementation of the fee-for-service payment arm, the Merit-Based Incentive Payment System (MIPS), was mandated by 2019. And the move to alternative pay­ment models was similarly fast-paced. To accommodate these lofty goals and the short timeline, the regulations have been extensive and complex (the display copy of the earliest MACRA proposed rule was 962 pages).

Not everyone liked what they saw. Criticism originated both inside and outside CMS. MedPAC, which advises Congress on Medicare policy, recently voted 14–2 to recommend replacing the MIPS program altogether. CMS Administrator Seema Verma, MPH, has also criticized MACRA’s metrics and proposed the creation of more meaningful measures.1 The move to slow the roll-out culminated with the Bipartisan Budget Act (BBA) of 2018, which was signed into law in Febru­ary. As a result, full implementation has been postponed until 2022.

What’s Changed With the QPP?

The slowing of the QPP is significant for radiology. On a governmental level, the delays suggest a lack of confidence in the legislation and CMS (the agency charged with implementation). The delay affords the ACR the opportunity to better understand the program, educate our members, and influence its evolution. For radiology practices, the delay means that the magnitude of the payment adjustments is smaller.


On one hand, this is favorable, as the fear of penal­ties is lessened. On the other hand, the upside potential for bonuses is decreased. Therefore, the financial motivation to implement quality initiatives is lower, which could either delay action or prompt no action by practices. The ACR Commission on Economics will continue to monitor the evolving QPP and help ensure that the program prompts meaningful change for the radiology profession and our patients.


  1. Remarks by CMS Administrator Seema Verma at the Healthcare Payment Learning and Action Network Fall Summit. Available at

By Ezequiel Silva III, MD, FACR, Chair

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