MIPS/MIPS Value Pathways update

The Merit-Based Incentive Payment System (MIPS) was established as part of the Medicare Access and CHIP Reauthorization Act (MACRA) in 2017. MIPS is an option for the Quality Payment Program (QPP), which began as a value-based payment model designed to reward providers for delivering high-quality care and to reduce payments for those who fail to meet performance standards. In addition to MIPS updates, there is a now a new framework for eligible healthcare providers, MIPS Value Pathways (MVP).

Since its inception, MIPS and other value-based payment plans have presented challenges for independent physicians. Although well-intentioned and beneficial to providers who meet the reporting requirements, many clinicians have expressed criticism of structural flaws within the system. Recent MIPS and MIPS Value Pathways updates have focused on resolving some of those issues.

The Centers for Medicare & Medicaid Services (CMS) has announced plans to increase the MIPS performance threshold for CY 2022 from 60 to 75 points, as well as to revise the reporting requirements for promoting interoperability. They are also open to receiving feedback on how the QPP can advance their efforts toward health equity.

CMS’s MIPS update also includes tweaks to the MIPS performance categories, adding three new health equity measures under the improvement activities performance category as well as five new episode-based cost measures under the cost performance category. In addition, CMS has introduced the MIPS Value Pathways (MVP) in an attempt to rectify many of the criticisms that providers have voiced about the MIPS program itself.

Part of the concern with MIPS is that the four performance areas (quality, improvement activities, promoting interoperability, and cost) are too siloed. Another concern is that MIPS provides clinicians with autonomy to select the quality measures and activities that they want to report. For example, providers can select quality measures in an area where their performance is high, even if those measures are not relevant to their core activity.

The new MVPs promote targeted concepts across the four MIPS categories, as they are focused on making the program more meaningful and valuable. Healthcare providers will report on the measures and activities that are specific to their areas of practice. MVPs will attempt to eliminate the silos seen in the MIPS program.

The MVP framework has as its goal aligning and connecting the reported activities and measures across the quality, cost, and improvement activities performance categories. The framework also incorporates a foundation leveraging the measure of promoting interoperability and a set of administrative claims-based quality measures focusing on population health and reduced reporting requirements.

Additional MIPS updates include the announcement of relief around reporting requirements due to the effects of the COVID-19 pandemic. As a result of the issues facing many healthcare providers during the pandemic, CMS has created a COVID-19 hardship exemption policy. The new policy applies to the performance years 2020 and 2021. To date, no decision has been made regarding 2022.

Providers can submit an online application requesting an exemption for one or more of the performance categories if their practice was adversely affected by COVID-19. If an exemption from all four categories is requested, the practice will not receive a MIPS payment adjustment in 2023 based on its 2021 performance. The provider will not be required to report any data and the practice will be held harmless from any possible downward payment adjustments. The practice will also not be eligible for a bonus based on the performance year for which an exemption is requested.