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, voted 14-2 on Thursday in favor of scrapping the Merit-based Incentive Payment System (MIPS) and replacing it with an alternative model of reimbursement.
MedPAC submits two reports to Congress each year, in March and in June. The set of recommendations voted on Jan. 11--eliminating MIPS and replacing MIPS with the Voluntary Value Program--will be included in the advisory group's March report to Congress.
The Medicare Access and CHIP Reauthorization Act (MACRA) 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.
Back in June, MedPAC discussed MIPS issues and alternatives to MIPS. As noted by Healthcare Informatics’ Managing Editor Rajiv Leventhal in an article this fall, MedPAC 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.
According to a story in MedPage Today, during the more recent Jan. 11 meeting, MedPAC policy analysts discussed the many challenges of the MIPS program. “The main problem with the MIPS program, as MedPAC's analysts see it, is that MIPS won't achieve the policy goals that it's designed to achieve,” as the MedPage report noted.
In a presentation at the Jan. 11 meeting, MedPAC policy analysts Katie Bloniarz, Ariel Winter, and David Glass, wrote, quite bluntly, “MIPS cannot succeed.” The MedPAC policy analysts wrote that the program “replicates flaws of prior value-based purchasing programs,” is “burdensome and complex,” and “much of the reporting information is not meaningful.” What’s more, the policy analysts noted that scores are not comparable across clinicians and “MIPS payment adjustments will be minimal in first two years, large and arbitrary in later years.”
Further, Bloniarz, Winter and Glass wrote in the presentation, “MIPS will not succeed in helping beneficiaries choose clinicians, helping clinicians change practice patterns to improve value, or helping the Medicare program to reward clinicians based on value.”
"Our most basic concern is that the measures in MIPS have not been proven to be associated with high-value care," Glass said, according to the MedPage report on the meeting.
According to the Jan. 11 presentation, the MedPAC policy analysts proposed an alternative program, called the Voluntary Value Program (VVP). MedPage reports that the Voluntary Value Program 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 reporting. "In the new model, all clinicians would see a portion of their fee schedule dollars withheld, which would be lumped into a pool -- for example 2%, though analysts stressed the percent amount had not been decided," MedPage reported.
In this new model, 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 alternative payment model or lose the withheld fee schedule dollars.
“Voluntary group performance will be assessed using uniform population-based measures in the categories of clinical quality, patient experience and value,” the presentation stated. As stated above, MedPAC voted 14-2 to both eliminate MIPS and replace it with the VVP.
As Leventhal has reported, 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.
Many in the healthcare industry sounded off on the MedPAC recommendations on Twitter. Greg Fuller, M.D., tweeted, “This physician (I’m not a provider) is elated, not angered. MIPS-too burdensome and costly to do.”
Ashish Jha, a physician with the Harvard T.H. Chan School of Public Health and the director of the Harvard Global Health Institute, tweeted, “MedPAC is completely right. MIPS cannot succeed.”
However, many clinicians and providers criticized MedPAC’s recommendation.
The Medical Group Management Association (MGMA) does not support MedPAC’s recommendation on MIPS. MGMA senior vice president of government affairs Anders Gilberg wrote “MGMA shares MedPAC’s concern that aspects of the current MIPS program are unduly burdensome and impede patient-centered care and innovation. However, we believe its recommendation to eliminate the program fails to adequately address the problem and does not reflect of the current value-based landscape. MedPAC’s alternative that would conscript physician groups into virtual groups and evaluate them on broad claims-based measures is inconsistent with the congressional intent in MACRA to put physicians in the driver seat of Medicare’s transition from volume to value.”
Ed Gaines tweeted, “After clinicians and RCMs have invested untold millions for MIPS, MedPAC would like to move the goal posts.”
According to the MedPage report, “most members of the commission expressed support for the new model or at least felt it was a good start.”