CMS ExRAD eCQM: Regulatory History and Current Status
- The deadline disappeared, but the measure did not. The CY 2026 OPPS Final Rule extended voluntary OQR reporting indefinitely and removed the CY 2027 mandatory date without replacing it, while CMS restated its commitment to the measure in the same rule. Hospitals treating the delay as a cancellation are reading it wrong.
- ExRAD is three measures across three programs, not one. IP-ExRad (CMS 1074) sits in IQR, OP-ExRad (CMS 1206) sits in OQR, and a clinician-level version (CMS 1056) sits in MIPS. NQF endorsed the measure at both the facility and clinician levels in 2022. Where your organization is exposed depends on which programs you report into.
- Operational burden is the reason for the delay, and it is the whole story. CMS pointed to implementation experience, data collection burden, and response rates as the drivers for extending the voluntary period. The measure’s intent was never seriously contested. The infrastructure required to report it was.
- There is no certification program and no required vendor. CMS clarified in January 2025 that hospitals may use any translation software meeting the measure specifications. No one can claim to be the approved or certified option, and no one can lock you in on that basis.
- The specifications are still being refined. An AAPM expert panel identified 20 issues and ambiguities spanning metrology, terminology, and consistency with existing practice standards, and the Joint Commission removed IP-ExRad from ORYX over a specification issue in CMS1074v2. Organizations building now are building against a moving target, which is an argument for transparency into how calculations are derived rather than a black box.
Updated May 2026
The Problem It Was Meant to Solve
With more than 90 million CT scans performed annually in the United States, studies have consistently shown wide and often unexplained variation in the radiation doses used to perform these exams. At the same time, inadequate image quality can lead to missed diagnoses, delayed treatment, or unnecessary repeat scans. CMS developed the ExRAD measure to address both sides of this equation: discouraging unnecessarily high radiation doses while preserving the image quality clinicians need for accurate diagnosis.
From Announcement to Today
Mid-2023: CMS Proposed Rule. CMS introduced the Excessive Radiation Dose or Inadequate Image Quality measure for inclusion in its major quality-based payment programs. The medical community responded with a mix of support for the patient safety intent and concern about the operational burden.
August 2023: IQR Finalized. The FY 2024 IPPS Final Rule added IP-ExRad (CMS 1074) to the IQR program as a self-selectable eCQM beginning CY 2025, with FY 2027 payment determination.
November 2023: OQR Finalized. The CY 2024 OPPS Final Rule added OP-ExRad (CMS 1206) to the OQR program for voluntary reporting beginning CY 2025, with mandatory reporting originally planned for CY 2027.
Late 2023: MIPS Finalized. The 2024 Medicare Physician Fee Schedule Final Rule added the clinician-level measure (CMS 1056) to MIPS for the 2025 performance year.
January 2025: Reporting Begins. The CY 2025 performance period opened. Voluntary reporting is live across all three programs.
January 2025: CMS Vendor Clarification. CMS confirmed that hospitals may use any vendor’s translation software that meets the measure specifications. There is no certification program and no required vendor.
January 2025: Joint Commission Removes IP-ExRad. The Joint Commission removed the inpatient version from its ORYX program due to a specification issue in CMS1074v2. The outpatient version (OP-ExRad) was not affected.
Early 2025: AAPM Expert Panel. The American Association of Physicists in Medicine published findings identifying 20 issues and ambiguities in the measure specifications, spanning metrology concerns, unconventional terminology, and inconsistencies with existing practice standards.
November 2025: Mandatory Reporting Postponed. The CY 2026 OPPS Final Rule extended voluntary OQR reporting indefinitely. The original CY 2027 mandatory date was removed. No new mandatory date has been set.
| What CMS Said
CMS remains committed to the Excessive Radiation eCQM as a patient safety issue for cancer prevention. Extending the voluntary reporting period will provide additional time for hospitals to gain experience with implementing the eCQM, as well as provide CMS with additional time to monitor implementation progress, including data collection burden and response rates. |
Key Milestones
| Date | Milestone |
| 2022 | NQF endorses the measure at facility (NQF #3663e) and clinician (NQF #3633e) levels |
| Mid-2023 | CMS publishes proposed rule introducing the ExRAD measure |
| Aug 2023 | IPPS Final Rule finalizes IP-ExRad (CMS 1074) for IQR |
| Nov 2023 | OPPS Final Rule finalizes OP-ExRad (CMS 1206) for OQR |
| Late 2023 | PFS Final Rule finalizes clinician-level ExRad (CMS 1056) for MIPS |
| Jan 2025 | Voluntary reporting begins across all programs |
| Jan 2025 | CMS confirms vendor flexibility; no required vendor or certification |
| Jan 2025 | Joint Commission removes IP-ExRad from ORYX (specification issue) |
| Early 2025 | AAPM panel identifies 20 issues in measure specifications |
| Nov 2025 | CY 2026 OPPS Final Rule extends OQR voluntary reporting indefinitely |
Operational Burden Was the Concern. We Built the Solution.
CMS cited infrastructure concerns and operational burden as the primary reasons for extending the voluntary reporting period. Those are the exact problems Imalogix was built to eliminate. Imalogix is already connected to over 1,000 healthcare facilities. For organizations already on the platform, the path to ExRAD compliance requires no new infrastructure, no new integrations, and no new workflows. The data pipeline is already in place. The translation software capabilities are built in. Reporting readiness is a configuration step, not an implementation project.
For organizations not yet on the platform, Imalogix dramatically compresses the implementation timeline. Cloud-based deployment eliminates the on-premises IT burden. Seamless integration with existing scanners, PACS, and EMR systems means you are not starting from scratch. And because Imalogix provides full transparency into how every calculation is derived, your team can review, validate, and improve your results before a single data point is ever reported.
The operational burden CMS was worried about is real for most hospitals. It doesn’t have to be for yours.
Imalogix | info@imalogix.com | 855-687-9100
Questions from This Article
- If reporting is voluntary with no end date, why prepare now?
Because voluntary reporting is still live and the performance period opened in January 2025. CMS said explicitly that the extension gives hospitals time to gain implementation experience, which means the organizations that use the window will be ready when a mandatory date returns. Those that wait will be implementing under a deadline instead of ahead of one.
- Do we need to buy a specific vendor's software to report ExRAD?
No. CMS confirmed that any vendor’s translation software meeting the measure specifications is acceptable. There is no certification program. The question to ask a vendor is not whether they are approved, but whether they can show you exactly how each value in your submission was calculated.
- What does readiness actually require for an organization already on Imalogix?
No new infrastructure, no new integrations, and no new workflows. The data pipeline is already in place and the translation software capabilities are built in, so reporting readiness is a configuration step rather than an implementation project. For organizations not yet on the platform, cloud-based deployment and integration with existing scanners, PACS, and EMR systems compress the timeline considerably.
More Articles You'll Find Useful
All Articles
CMS Translation Software, Timelines & Vendor Selection
CMS Clarifies eCQM Compliance: Hospitals Have a Choice
Demystifying “Translation Software” in Healthcare Imaging: A Perspective from Imalogix