There is no shortage of opinions, and criticism, about the Medicare Access and CHIP Re-Authorization Act (MACRA), the federal government’s payment program that aims to push providers to transition from volume to value. More specifically, many providers have voiced frustration with the performance measures under MACRA’s Merit-based Incentive Payment System (MIPS).
The Medicare Payment Advisory Commission (MedPAC), a nonpartisan legislative branch agency that provides the U.S. Congress with analysis and policy advice on the Medicare program, has been vocal about its concerns and criticism of MIPS, and is, in fact, recommending in its March report to Congress, which was made available to the public last week, that federal legislative leaders eliminate MIPS and replace it with an alternative model of reimbursement.
MedPAC submits two reports to Congress each year, in March and in June. Back in January, MedPAC voted 14-2 to recommend scrapping MIPS and replacing MIPS with a new clinician value-based purchasing program, called the Voluntary Value Program (VVP), and this proposal was included in the advisory group's recent report to Congress.
MedPAC’s approach to a new value-based purchasing program is to allow clinicians to self-organize into groups that collectively assume responsibility for their patients’ outcomes. Under the VVP, clinicians can elect to be measured as part of a voluntary group and clinicians in voluntary groups can qualify for a value payment based on their group’s performance on a set of population-based measures, according to the report. The VPP would measure all clinicians on the same set of measures—clinical quality, patient experience and value.
In its 563-page report (the section on replacing MIPS starts on page 475), MedPAC says that the Commission supports the elements of MACRA that repealed the sustainable growth rate (SGR) and encouraged comprehensive, patient-centered care delivery models such as advanced alternative payment models (A–APMs). However, the Commission has concluded that MIPS “will not fulfill its goals and therefore should be eliminated.”
MedPAC concluded, according to the report, “that the MIPS program impedes the movement toward high-value care. MIPS will not succeed in helping beneficiaries choose clinicians, in helping clinicians collectively change practice patterns to improve value, or in helping the Medicare program to reward clinicians based on value.”
The March MedPAC report also lays out the Commission’s additional concerns and criticism: MIPS imposes a significant reporting burden on clinicians (estimated by CMS as over $1.3 billion in the first year) and MIPS scores are not comparable among clinicians because each clinician’s composite MIPS score will reflect a mix of different, self-chosen, measures. MedPAC also contends that MIPS is complex and inequitable, with different rules for clinicians depending on location, practice size, and other factors; and it exempts more clinicians than will participate.
As much as clinicians dislike aspects of MIPS, many physician groups and industry associations disagree with the proposal to eliminate MIPS—indicating a sort of “better the devil you know, than the devil you don’t” mentality. Anders Gilberg, senior vice president for government affairs at the Medical Group Management Association (MGMA), said in a statement, “MedPAC’s March Report is an indictment of MIPS as implemented. However, its conceptual ‘VVP’ alternative lacks details. MGMA believes there are steps that can be taken now to reduce clinician burden. CMS can begin by shortening the 2018 MIPS data reporting period from one-year to 90 days in the same way the Agency did for Meaningful Use in 2014, 2015, and 2016.”
In a Healthcare Informatics podcast interview, which was recorded back in January, David Barbe, M.D., president of the American Medical Association, said that he believes it is “premature” to abandon MIPS at this point. “We do believe there are significant improvements and opportunities in the MIPS program, but we’re not quite ready to abandon it, we think that’s premature. We’re not that far along in to the second year of the program; it has not given us as an industry and as individual physicians time to acclimate to this program.”
Barbe added, “We’re concerned that the [MedPAC] proposal suggests that the primary way, if not the only way, is through group reporting, and while that has some advantages, forcing physicians into group reporting, or making that the only way one can participate in what I’ll generically call value-based programs, is probably not right. Our industry is not a one-size-fits-all industry. We have some reservations, but we’re waiting to see more details of the proposal.”
In the report to Congress, MedPAC concedes that many have argued that MIPS should be given a chance to succeed and that considerable resources have already been invested in the program. However, MedPAC stated, “MIPS will continue to consume limited CMS and clinician time and resources, and the burden of MIPS will outweigh its value to Medicare beneficiaries, the Medicare program, and clinicians. Progress in a more useful direction is feasible. MIPS should be eliminated, and a VVP should be established to encourage clinicians to move in a more productive direction.”
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