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Perhaps the biggest news impacting your participation in the Quality Payment Program (QPP) doesn’t have to do with 2020 (PBN 8/12/19). The Pathways (MVP) version of the Merit-based Incentive Payment System (MIPS) is slated to launch in 2021 and offers sufficiently meaningful changes that you may expect some transitional bumps that year.
CMS envisions a new design for MIPS in 2021 — specifically, the MIPS Value Pathways (MVPs), which the federal agency says will create “a cohesive and meaningful participation experience for clinicians by moving away from siloed activities and measures and towards an aligned set of measures that are more relevant to a clinician’s scope of practice, while further reducing reporting burden and easing the transition to APMs,” according to the proposed 2020 Medicare physician fee schedule released July 29.
What might that mean in practice? Responding to stakeholders who argue MIPS has “too much complexity and choice,” and is thus burdensome and confusing to clinicians, CMS says MVP would:
- Be “organized around clinician specialty or health condition and encompass a set of related measures and activities.”
- Have “limited sets of measures and activities.”
- Create and disseminate “comparative performance data that is valuable to patients and caregivers.
- Have “measures that encourage performance improvements in high-priority areas.”
- Lower barriers to alternative payment method (APM) participation by means of “measures that are part of APMs where feasible, and by linking cost and quality measurement.”
CMS has issued diagrams showing how such a program might work (see Resources, below). In one example, working under the “MIPS Value Pathways for Diabetes Prevention and Treatment,” an endocrinologist would have not six but three quality measures to fulfill—Hemoglobin A1c (HbA1c) Poor Care Control (>9%); Diabetes: Medical Attention for Nephropathy; and Evaluation Controlling High Blood Pressure. Improvement activities (IA) requirements would vary by specialty and in some cases—for example, for surgeons—so would cost measures.
While Promoting Interoperability would start out being uniform for all clinician types, CMS believes the category “could benefit from more targeted approaches to assessing the meaningful use of health IT” down the road.
CMS also says MVP will have “an emphasis on patient-reported measures” so clinicians “can use feedback from the patient perspective to inform care improvement efforts,” and also place an emphasis on population health.
The agency also expects to include “administrative claims-based population health” measures in MVP—in fact, CMS announces one such measure for 2021, All-Cause Unplanned Admission for Patients with Multiple Chronic Conditions, in this rule. Tom Lee, former CEO of Ignite SA and now strategic advisor to SPH Analytics in Alpharetta, Ga., finds this ironic: “They’re moving toward using more administrative claims to measure quality, which is moving in the opposite direction from the past few years,” given the recent push for other MIPS reporting mechanisms over claims (PBN 11/8/18).
CMS says it seeks “significant input from clinicians and specialty societies, to ensure that measures and activities within MVPs are relevant and important to clinician practices,” and has dozens of specific questions for the comment period. For example, CMS asks “whether clinicians would like to see outlier analysis or other types of actionable data feedback” from the MVP program and how to identify which MVPs are most relevant for a provider.
Quality reporting experts are latching onto the opportunity this presents to interrogate CMS on MIPS issues that have not been resolved under the old regimen. For example, Linda DiBenedetto, CMHP, practice advisor, payer initiatives at McKesson, is interested in CMS’ queries about small and rural practices, such as “How can we reduce barriers to small and/or rural groups to transitioning into APMs, such as lack of information on performance on quality and cost measures and limited resources?”
“At McKesson, we are committed to helping community specialty practices succeed in value-based care programs and stay in business,” says DiBenedetto.
Even at this early stage, some stakeholders are already experiencing pushback from clients and peers on the MVP proposal. At quality clinical data registry (QCDR) Patient360, "we can tell you already that there is pushback on the idea of ‘pre-selection’ by CMS [as to] which MVP should be used by which specialty,” says Amanda Lord Darbani, the company's chief operating officer and subject matter expert for MIPS and CMS relations. She refers to the current tentative plan mentioned in the rule of “assigning MVPs to clinicians and groups” rather than vice-versa. This reminds Lord of the “rigid” measures groups format in the old PQRS quality reporting system (PBN 7/18/11).
“Providers should look to their associations and see what they want to respond to — particularly those specialties that have the most to gain or lose from how it gets finalized,” Lee advises. “They should ask: Does this really reduce our burden? Because just because you have fewer measures doesn’t mean you’ll have a lighter burden. You could have two rather than five measures required, but if they’re two with a large data extraction burden, it could still be more work.”
Darbani believes that “CMS is trying to uphold the spirit of the program and simplify the current model” but warns that “the concepts of the MVP framework are most definitely not fully baked yet, and that there will almost certainly be a myriad of unintended consequences as a result of launching such a new framework when the current MIPS model has barely gained traction and true comprehension” by providers. “Our opinion is that as long as the structure remains in place of shifting [CMS] contractors every year for implementing all the various elements and stages of the program, burden will never truly be reduced because the very framework that creates, implements and supports the program is deeply fractured,” Darbani says.
— Roy Edroso (firstname.lastname@example.org)