The MACRA journey of more than 3 years to advance the value-based reimbursement was difficult for clinicians to adapt – economically and operationally. Significant time and effort were invested in reaching out to clinicians and educating them on MACRA and its impact on payment. Clinicians felt disconnect in the number of measures across the four performance categories of MACRA that they need to report on. Burden of reporting, penalties when thresholds are not met were few reasons that had led the clinicians to demand for changes in the way performance is evaluated. CMS plans to cluster practice according to specialties MIPS Value Pathways (MVP) to report on a subset of measures, which are relevant to their work across the four performance categories. MVPs are intended to reduce the complexity of the MIPS program and the burden to participate.
MVP Overview
MIPS Value Pathways (MVPs) is a conceptual participation framework that would apply to future proposals beginning with the 2021 Performance Year. The goal of MVPs is to shift from siloed activities and measures to an aligned set of measure options relevant to a clinician’s specialty or practice area that is meaningful to patient care.
CMS suggests four guiding principles for developing MVPs:
Benefits of this framework include:
MVP Key Highlights
Performance Category
Category |
Current Implementation |
MVP Implementation |
Promoting Interoperability |
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Quality |
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Cost |
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Improvement Activities |
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Population Health Measures |
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Group Reporting
Multispecialty Practices
Challenge: Multispecialty groups, especially with several clinicians, often provide an array of services that may not be captured in a single set of measures or in a single MVP.
Possible solution
1. Allow a portion of a group to report as a separate sub-group on measures and activities that are more applicable to the subgroup and be assessed and scored accordingly based on the performance of the sub-group.
2. MVP approach - Multispecialty groups would report on multiple assigned or selected MVPs, where assignment or selection of MVPs would be at group level. Depending on how the MVPs are then combined and scored at the group level, this may eliminate the need for groups to create sub-TIN identifiers and apply eligibility criteria at the sub-TIN level.
3. This will avoid unwanted operational and data collection efforts associated with creation and maintenance of identifiers for sub-groups. An upper limit will be placed on the number of MVPs, measures, and activities reported by the multispecialty practices.
Scoring
The quality and cost performance measures within MVPs would be scored on a scale of 0 to 10 and performance is assessed against a benchmark(using the current approach to calculate benchmarks). The framework for scoring Promoting Interoperability measures may not change.
Overall Impact on Clinicians
Specialties can now focus on measures affecting their practices, rather than having to choose from some generic MACRA measures, which’d have diluted focus and prevented them from achieving their best performance.
Future State of MIPS
CMS will systematically align Quality measures and Improvement activities to provide more relevant data to clinicians on their performance, which may lead to significant cost savings. The quality, cost and improvement activities will be further aligned and be based on foundational measures in the areas of patient-reported outcomes. This will encourage clinicians to shift to APM participation.
In the future state of MIPS, clinicians will report on a foundational set of measures with focus on patient care which will include:
Patient Reported Outcomes: CMS may include additional patient reported measures such as patient experience and satisfaction measures and clinical outcomes measures. Patient feedback will enable clinicians to deliver better patient care and also empower patients to take decisions about their healthcare.
Enhanced Performance Feedback: Subsequently, stable MPVs will enable CMS to provide clinicians with actionable data feedback which will help clinicians to understand their performance and encourage them to take risks which may be necessary in Advanced APMs.
CitiusTech Perspective
MVPs will allow clinicians from same specialties to be compared on the same set of quality and cost measures. This will not only help patients to choose between care providers but also encourage providers to constantly make changes in practice patterns to improve performance.
Since its inception, MIPS has caused lot of confusion and unnecessary burden on clinicians from specialties. Such clinicians not only chose from a common pool of performance measures every year, but also would need to select measures which did not meaningfully target an episode of care undergone. With MVP, this can be significantly reduced since an active participation of specialty or condition clinicians during the rule making process will ensure that each MVP will contain only those measures which come under clinician’s scope of practice that is meaningful to patient care.
With Promoting Interoperability as part of the foundational element and greater focus on the specialty, new measures can be developed that supports not only on certified health records (EHRs), but also on technology that builds on certified EHRs.
MVP largely seems to be a step in the right direction to reduce reporting complexity, help specialties maintain focus on their relevant areas and constantly improve clinical performance through CMS affected feedback mechanisms. The new framework will be instrumental in helping CMS gather more statistical data that can be used in analyzing and improving overall population health.