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MedPAC Urges Congress to Axe MIPS

News  |  By John Commins  
   March 15, 2018

The commission wants Congress to adopt a Voluntary Value Program that eases the administrative burden on clinicians, and provides a more objective assessment of the value of care delivered based on population health metrics.

The Medicare Payment Advisory Commission (MedPAC) on Thursday issued its massive, semiannual report to Congress, with a recommendation that lawmakers end the Merit-based Incentive Payment System (MIPS).

In its place, MedPAC recommends establishing a Voluntary Value Program that it says would be less taxing on physicians, and which would more objectively assess the value of the care provided by using broader population health metrics.

The recommendations in the 563-page report follow the commission’s vote at its January meeting to eliminate MIPS. Congress is free to either take up the recommendations or ignore them.

"We came to this determination based on a two-year analytic work in which we started out examining ways in which MIPS might be improved," MedPAC Executive Director James Mathews said in a media conference call on Thursday.

"Over the course of two years we came to the conclusion that there were certain fundamental flaws in the premise of MIPs that suggest could not be improved," he said.

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Mathews cited a number of flaws in MIPS, which he said makes the program "inequitable among physicians."

"Physicians get to choose their own measures under MIPS and the incentive is going to be for each physician to choose measures upon which they will likely succeed and perform well," he said.

He said MIPS also imposes a significant time and money burden on clinicians.

"CMS estimated a compliance cost of $1.3 billion in first year and costs of well over $500 million in years going forward," Mathews said. "We believe these expenditures will not result in a meaningful assessment of clinicians' performance such that it provides the basis for Medicare to move dollars around under MIPS."

Mathews called MedPAC's proposed replacement for MIPS—the VVP—a more streamlined approach that leaves the heavy lifting of data compilation to Medicare.

MIPS allows clinicians to choose six from 300 different quality measures, and the vector in which their performance gets reported. "Then Medicare makes a determination of whether their performance exceeds a performance threshold," Mathews said.

"What we have in mind is a system in which physicians would not be measured on an individual basis but would come together as a group to be measured on a much smaller set of population-based outcomes measures," he said.

"This would be on a voluntary basis where all of the physicians in a multi-specialty practice could volunteer to be measured as a group, or all of the physicians on a hospital staff could voluntarily be measured as a group, or all of the members of a county medical society could say 'we want to be measured,'" he said. "It would be purely up to the physicians themselves to make this determination of whether they wanted to be measured."

The smaller set of population health outcomes could include hospital admissions, mortality rates in the population they serve, and Medicare spending per beneficiary for the patients they touch.

"These would largely be measures that were not within the ability of any individual to influence how they were reported," Mathews said. "These are things that the Medicare program would be able to measure independently on the basis of claims or beneficiary satisfaction surveys. There would be no administrative burden associated with being measured under the VVP. Instead, it would all be conducted with readily available administrative or survey data."

Mathews says physicians would have two primary incentives for participating in VVP.

"One, obviously, is this program is going to provide quality bonus payments to physicians operating in fee-for-service Medicare," he said. "We are talking about those physicians who do not elect to join or form APMs (Alternative Payment Models). Those bonus payments have to be funded. We have suggested that the funding could come in the form of a withhold that would apply to all clinicians. We suggested something in the vicinity of 2% as a potential starting point for this withhold."

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"Any given physician would see their payments under the fee schedule reduced by 2% and in order to have any potential of getting that withhold back or getting bonus payments on top of that withhold, they would want to raise their hands and volunteer to be measured under the VVP," Mathews said.

Another incentive makes the quality measures proposed in the VVP applicable under the Advanced APM performance assessment.

"This program would provide a stepping stone to get groups of physicians who are not necessarily ready to take on financial risk to nonetheless start to become measured under the same construct that would apply under AAPMs,” Mathews said. “Basically, it provides greater incentives for them to continue down that path, which would hopefully result in true delivery system reform, which we do not see as a real outcome under the current MIPS construct."

John Commins is a content specialist and online news editor for HealthLeaders, a Simplify Compliance brand.

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