CMS Proposes Ongoing Voluntary Status for CT Radiation Dose Quality Measure Amid Physician Concerns
The Centers for Medicare & Medicaid Services (CMS) has announced a proposal to keep its radiation-related quality measure, Excessive Radiation Dose or Inadequate Image Quality for Diagnostic Computed Tomography in Adults (CMS1074v3), in voluntary reporting status beyond 2027. The decision follows sustained concerns from radiologists and healthcare leaders regarding the measure’s technical feasibility and operational burden.
The quality measure, first introduced to balance rising CT utilization with radiation safety, evaluates the proportion of scans that exceed set thresholds for radiation dose or image noise across 18 exam categories. Reporting began on a voluntary basis in January 2024, with mandatory participation originally scheduled for 2027. CMS is now proposing to indefinitely extend the voluntary status in its 2026 Hospital Outpatient Prospective Payment System and Ambulatory Surgical Center Payment Systems proposed rule.
The American College of Radiology (ACR) welcomed the proposal, citing the challenges of widespread implementation. “ACR supports continuing voluntary reporting for this measure, recognizing the technical and operational challenges it presents,” the organization stated, while reaffirming its commitment to radiation safety through initiatives such as Image Wisely, Image Gently, and the Dose Index Registry.
Research published earlier this year in both the American Journal of Roentgenology and the Journal of the American College of Radiology outlined multiple barriers to adoption. These include ambiguities in applying the measure to combination studies, IT burdens tied to implementation and data security, and uncertainty about how facilities can appeal results perceived as inaccurate.
While CMS is leaning toward keeping the program optional, some experts worry the decision could slow adoption of best practices for radiation dose reduction. “The program being optional is going to lead to many hospitals not reporting on this measure, which would be such a backslide because that’s what’s really driving adoption,” said Rebecca Smith-Bindman, MD, of UCSF, who has studied CT radiation effects extensively. “We care about CT doses. We care about safety. These doses should come down.”
ACR has encouraged facilities to engage with the voluntary measure when possible, acknowledging that implementation may not be feasible for all sites. Advocates hope the measure will eventually become mandatory, driving broader alignment around radiation dose optimization and image quality standards.
If finalized, CMS’s proposal would represent a cautious step, balancing the drive for radiation dose safety with recognition of the technical and resource challenges facilities face in implementing complex quality reporting requirements.