Is MIPS 401 the same as MIPS 401?

Yes. CMS uses zero-padded three-digit Quality IDs (401) in official specifications, while clinicians often search for MIPS 401 or Quality ID 401 without the leading zero. Both refer to the same 2026 MIPS quality measure reported through the Quality Payment Program (QPP).

How do I report MIPS Measure 401 in 2026?

MIPS Measure 401 (Quality ID 401) is reported through the Quality Payment Program (QPP) as a MIPS Clinical Quality Measure (CQM) via qualified registry, or Medicare Part B claims where applicable.

Is MIPS 401 a topped-out measure?

No, MIPS 401 is not topped out, meaning there is still meaningful performance variation across clinicians.

Measure ID: MIPS 401|Hepatology|2026 Performance Year

2026 MIPS Measure #401: Hepatitis C: Screening for Hepatocellular Carcinoma (HCC) in Patients with Cirrhosis

Percentage of patients aged 18 years and older with a diagnosis of chronic Hepatitis C cirrhosis who underwent imaging with either ultrasound, contrast enhanced CT or MRI for hepatocellular carcinoma (HCC) at least once within the 12-month submission period.

ProcessHepatologyOncology

Measure ID:MIPS 401 (Quality ID 401)

Collection:MIPS CQM

Topped Out:No

View CMS Spec ↗

Measure Specification

Eligible Population

Patients aged ≥ 18 years on date of encounter

ANDDiagnosis for chronic Hepatitis C

ANDDiagnosis for cirrhosis

ANDPatient encounter during the performance period

Exclusions

None

Numerator

Patients who underwent abdominal imaging with either ultrasound, contrast enhanced CT or MRI.

Reporting Codes

Performance Met:

G9455Patient underwent abdominal imaging with ultrasound, contrast enhanced CT or contrast MRI for HCC

Performance Not Met:

G9457Patient did not undergo abdominal imaging and did not have a documented reason for not undergoing abdominal imaging in the submission period

○ Exceptions:

G9456Documentation of medical or patient reason(s) for not ordering or performing screening for HCC. Medical reason: Comorbid medical conditions with expected survival <5 years, hepatic decompensation and not a candidate for liver transplantation, or other medical reasons. Patient reasons: Patient declined or other patient reasons (e.g., cost of tests, time related to accessing testing equipment)

VBCA Insights

Why This Measure Matters

Hepatitis C patients with cirrhosis are at high risk for hepatocellular carcinoma (HCC)—the fastest-growing cancer type in the U.S. This measure ensures they get abdominal ultrasound, contrast-enhanced CT, or MRI screening at least annually. Early HCC detection opens curative options like resection, transplant, or ablation. Many cirrhosis patients fall through cracks; systematic screening, even every 6 months, catches cancers while they're small and potentially curable.

VBCA is a CMS-approved Qualified Clinical Data Registry (QCDR) that submits MIPS Measure 401 to the Quality Payment Program (QPP). Practices can report this measure as a MIPS Clinical Quality Measure (CQM) or through qualified registry submission.

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Specialty Measure Sets

Family Medicine Gastroenterology Internal Medicine

Related Measures

Hepatology

MIPS 400: One-Time Screening for Hepatitis C Virus (HCV) and Treatment Initiation MIPS 516: Hepatitis C Virus (HCV): Sustained Virological Response (SVR)

Oncology

MIPS 102: Prostate Cancer: Avoidance of Overuse of Bone Scan for Staging Low Risk Prostate MIPS 143: Oncology: Medical and Radiation – Pain Intensity Quantified MIPS 144: Oncology: Medical and Radiation – Plan of Care for Pain MIPS 249: Barrett’s Esophagus MIPS 250: Radical Prostatectomy Pathology Reporting MIPS 395: Lung Cancer Reporting (Biopsy/Cytology Specimens)MIPS 396: Lung Cancer Reporting (Resection Specimens)MIPS 397: Melanoma Reporting MIPS 450: Appropriate Treatment for Patients with Stage I (T1c) – III HER2 Positive MIPS 453: Percentage of Patients who Died from Cancer Receiving Systemic Cancer-Directed MIPS 457: Percentage of Patients who Died from Cancer Admitted to Hospice for Less than 3 MIPS 490: Appropriate Intervention of Immune-Related Diarrhea and/or Colitis in Patients Treated MIPS 491: Mismatch Repair (MMR) or Microsatellite Instability (MSI) Biomarker Testing MIPS 506: Positive PD-L1 Biomarker Expression Test Result Prior to First-Line Immune Checkpoint MIPS 507: Appropriate Germline Testing for Ovarian Cancer Patients MIPS 509: Melanoma: Tracking and Evaluation of Recurrence

Official Resources

📄 CMS Measure Specification (PDF)🔗 QPP Quality Payment Program

Clinical Rationale

HCC (hepatocellular carcinoma) is the fourth most common cancer in the world and is the fastest rising cause of cancer-related deaths in the United States. HCV is the leading cause of HCC and the risk of developing HCC is highest in patients with established HCV cirrhosis. Several potentially curative treatments are available for patients with early-stage HCC.

These include surgical resection, liver transplantation, and local ablation. Long-term survival of patients who have liver resection or transplantation for HCC can be high (40% to 70% for resection and 52% to 81% for transplant patients after 5 years). A recent systematic review of 18 nonrandomized studies found that more screened patients had early-stage HCC than clinically diagnosed patients.

More screened patients received potentially curative treatment. However, these studies were limited by their observational nature (including lead time bias) and thus the effect on overall mortality was unclear. There are no randomized controlled trials that evaluated the impact of HCC screening versus no screening on survival in patients with cirrhosis.

A randomized trial of HCC screening is not forthcoming because, even in the absence of high quality data, most informed patients and their clinicians consider randomization unethical and prefer surveillance. In a recent modeling based study (that corrected for lead time bias), US based screening for HCC in compensated HCV cirrhosis patients reduced mortality compared to no screening.

Collectively, these data suggest that screening has a potential to produce benefits in the highest-risk patients, such as those with HCV cirrhosis who are good candidates for potentially curative treatment.

Clinical Recommendations

Patients at high risk for developing HCC, including patients with Hepatitis C cirrhosis, should be entered into surveillance programs. Surveillance for HCC should be performed using ultrasonography. Patients should be screened at 6-month intervals (AASLD, 2023). HCC surveillance must be continued indefinitely in patients with cirrhosis (A1). Patients with cirrhosis should undergo regular surveillance for HCC, irrespective of SVR (B1) (EASL, 2014) While current US guidelines only specify using ultrasound, evidence suggests that using multiple screening methods, including incorporating the alpha fetoprotein biomarker into surveillance plans, may be more effective in identifying early stages of HCC.

Implementation Notes

This measure contains one strata defined by a single submission criteria. This measure produces a single performance rate. For the purposes of MIPS implementation, this patient-process measure is submitted a minimum of once per patient for the performance period. The most advantageous quality data code will be used if the measure is submitted more than once.

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