News: MIPS won’t achieve its policy goals, according to MedPAC

CDI Strategies - Volume 11, Issue 50

What’s the main problem with the Merit-based Incentive Payment System (MIPS) program? It won’t achieve its policy goals, say members of the Medicare Payment Advisory Commission (MedPAC) which met Thursday, October 12, HealthLeaders Media reported.

The MIPS program is one of two payment vehicles created as a result of the Medicare Access and CHIP Reauthorization Act (MACRA)—which replaced the almost universally disliked Sustainable Growth Rate (SGR) formula. The other payment pathway consists of an array of advanced Alternative Payment Models (APMs)

The flexibility of the program—the various options for how physicians can report measures and the broad exemptions for certain types of clinicians—has made it overly complex, MedPAC says, and senior analyst Kate Bloniarz suggested an alternative policy approach that leverages population-based measures.

The Voluntary Value Program, as MedPAC dubbed its  proposal, would get rid of the MIPS program and all three types of reporting requirements—Advancing Care Information (ACI), Clinical Practice Improvement Activities (CPIA), and quality measures—and scrap CMS support for electronic health records reporting.

In the new model, all clinicians would see a portion of their fee schedule dollars withheld, which would be lumped into a pool—for example 2%, though analysts stressed the percent amount had not been decided.

Clinicians would then have three options:

  • Choose to be measured with a "sufficiently large entity" of clinicians and be eligible for value payments
  • Choose to participate in an advanced APM model
  • Lose the withheld fee schedule dollars

In the first option, the “sufficiently large entity” could be those physicians affiliated with a single hospital or one geographic area, Bloniarz said.

“An entity's performance would then be collectively measured using a set of population-based measures,” she added.

These measures could potentially fall under three categories: clinical quality, patient experience, and value. For example, a clinical quality measure might include mortality or avoidable admissions.

Unlike the MIPS program, all of the measures could be pulled from Medicare claims data or "centrally conducted surveys" avoiding the clinician reporting burden, Bloniarz explained.

MedPAC's technical team is expected to return to the group with draft recommendations for repealing the MIPS program and offer two options: a voluntary replacement program similar to the one discussed at Thursday's meeting with some revisions, and suggestions on how to make the advanced Alternative Payment Models more accessible for physicians.

The commission could then decide whether to recommend one or both options to HHS.

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