As the industry awaits MACRA’s Quality Payment Program (QPP) final rule for 2018, the Medicare Payment Advisory Commission (MedPAC) said during a meeting last week that MIPS, one of the program’s payment tracks, should be repealed.
MedPAC, a Congressional agency that provides policy and technical advice to Congress on healthcare issues, recommended back in June that MIPS (the Merit-based Incentive Payment System) should be redesigned. It said at the time that MIPS, as presently designed, “is unlikely to help beneficiaries choose clinicians, help clinicians change practice patterns to improve value, or help the Medicare program.” The current set of MIPS quality measures could be eliminated and replaced with a smaller set of population-based outcome measures, MedPAC said in that briefing to Congress. The report further noted, “The proposed outcome measures would be calculated from claims or surveys, and thus would not require burdensome clinician reporting.”
MACRA’s Quality Payment program is inclusive of two payment paths that eligible Medicare-participating physicians could partake in—MIPS and the advanced alternative payment model (APM) track—and began in January 2017. The federal government released a proposed rule for year two of the program in June. Centers for Medicare & Medicaid Services’ (CMS) chief medical officer, Kate Goodrich, M.D., reportedly said at the Medical Group Management Association (MGMA) annual conference in Anaheim this week that the final rule for 2018 must be published by Nov. 1.
Nonetheless, in its annual meeting last week, reports are surfacing that MedPAC members reached near-unanimous agreement that MIPS, in its current form, needs to be scrapped. According to a story in MedPage Today, MedPAC analysts have indeed discussed an alternative policy approach that leverages population-based measures. As the MedPage report noted, “The Voluntary Value Program, as they've dubbed the alternative, 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 [EHRs] reporting.”
In this new model, all clinicians would see a portion of their fee schedule dollars withheld, which would be lumped into a pool. 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 (and receive withhold back); or make no election and lose the withheld fee schedule dollars.
During the meeting last week, almost all MedPAC members said they are in favor of a MIPS repeal following the proposal of this alternative model. And, at the MGMA annual conference this week, CMS’ Goodrich said she read the MedPAC report, called it “interesting,” and said that some elements of the proposed model could be added in future program years without changing the law. Importantly, she noted, sunsetting MIPS would not be an option unless it was approved by Congress.
According to that MedPage report, MedPAC members themselves had varying opinions on the new model. One member said that since it’s voluntary, providers can always choose to go back to traditional fee-for-service, which would not be beneficial. Another member pondered if the proposed model was too close to the advanced-APM structure. Another member opined that “politicians will want to do something,” referring to a possible MIPS repeal-and-replace.
Other stakeholders have also called for a rethinking of MIPS, which streamlines existing quality reporting programs such as those under meaningful use, the Physician Quality-Reporting System (PQRS), and the value-based payment modifier, while adding a clinical practice improvement category.
But as MedPAC has noted, MIPS, as currently constructed, “is not sustainable” and “will not identify high- or low-value clinicians.” The organization said that since CMS will begin making MIPS payment adjustments in 2019 (for program year 2017), “action is needed now.”