Since the Quality Payment Program launched in 2017, CMS has taken steps to update both the MIPS and Advanced Alternative Payment Models (APMs) participation tracks to acknowledge the unique variation in clinician practices, further refine program requirements, respond to stakeholder feedback, reduce reporting burden, encourage meaningful participation, and improve patient outcomes. They have consistently heard from clinicians that the programs and more specifically MIPS, remains overly complex.

With this in mind, CMS has attempted to address some of these concerns over the last few years by leveraging their Patients over Paperwork initiative to review MIPS and remove unnecessary elements to help streamline program requirements and reduce clinician burden. Their goal is to move away from siloed activities and measures and move toward an aligned set measure options more relevant to a clinician’s scope of practice that is meaningful to patient care.

In the most recent Medicare Physician Fee Schedule Final Rule, CMS finalized its MIPS Value Pathways (MVPs), a participation framework that would begin with the 2021 performance period. The MVPs framework aims to align and connect measures and activities across the Quality, Cost, Promoting Interoperability, and Improvement Activities performance categories of MIPS for different specialties or conditions. All MVPs would be organized around a clinician specialty or health condition and encompass a set of related measures and activities. CMS intends to ensure equity in MVPs so that clinicians are not advantaged by reporting one MVP over another

Another key component of the MVPs framework is that CMS will provide enhanced data and feedback to clinicians. They also intend to analyze existing Medicare information so that clinicians and patients receive more information to improve health outcomes. CMS believes the MVPs framework will help to simplify MIPS, create a more cohesive and meaningful participation experience, improve value, reduce clinician burden, and better align with APMs to help ease the transition between the two tracks. In addition to achieving better health outcomes and lowering costs for patients, CMS anticipates that these MVPs will result in comparable performance data that helps patients make more informed health care decisions.

Once again, this new framework would unite and connect measures and activities across the Quality, Cost, Promoting Interoperability, and Improvement Activities performance categories of MIPS and incorporate a set of administrative claims-based quality measures that focus on population health/public health priorities. The administrative claims-based quality measures would focus on public health priorities and/or cross-cutting population health issues. There would be no submission burden as CMS would provide and calculate the data for the administrative claims measures. An example would be the current MIPS All-Cause Hospital Readmission measure that CMS calculates for groups of 16 or more.

In a diabetic MVP example given by CMS we see the current structure of MIPS, including 6 Quality measures, the 6 plus measures included in Promoting Interoperability, 2-4 improvement activities depending on practice size, and one or more cost measures. Over the next 1-2 years physicians, and more specifically endocrinologists in this example, would report all applicable Promoting Interoperability and population health measures but now have a MIPS Value Pathway with measures and activities that focus on diabetes prevention and treatment. This MVP would allow the Endocrinologist to report on fewer measures overall in a pathway that is meaningful to their practice.

The example includes Quality measures for

  • Hemoglobin A1c: Poor Care Control,
  • Diabetes: Medical Attention for Neuropathy, and
  • Evaluation: Controlling High Blood Pressure.

The Improvement Activities might consist of Glycemic Management Services and Chronic Care and Preventative Care Management for Empaneled Patients. Then finally the Cost would include Total Per Capita Costs (TPCC) and Medicare Spending per Beneficiary (MSPB). While this is not all that dissimilar from what may have been reported in previous years, it does have less requirements and gives the physician a clear direction with less variability.

Other MVP categories we could see soon includes Preventative Health, Major Surgery, and General Ophthalmology, just to name few. CMS anticipates that eventually many clinicians would have at least one relevant MVP, while other clinicians may have several.

While scoring has not been finalized up to this point, CMS anticipates that both the quality and cost performance category measures within MVPs would be scored using a scale of 0 to 10 and performance assessed by comparing to a benchmark, using the current approach to calculate benchmarks. One could then assume that Improvement Activities scoring would remain similar to its current form, while Promoting Interoperability has the most variability due to its measure applicability to each physician or group.

What does all of this mean for your physicians and specialty? Over 2020, CMS is considering convening public forum listening sessions, webinars, and office hours, or use additional opportunities such as the pre-rulemaking measures process to understand what is important to clinicians, patients, and stakeholders, as they develop MVPs.

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