- The Medicare Payment Advisory Commission (MedPAC) called for the cancellation of the Merit-Based Incentive Payment System (MIPS) in a public meeting held on October 5.
In its presentation, MedPAC asserted MIPS should be eliminated and replaced with a voluntary value program. The commission stated the current payment system places significant burden on clinicians, includes extremely complex requirements, and lacks a compelling association with high-value care.
Specifically, MedPAC stated the payment system’s structure could potentially cause score compression and a limited ability to detect performance.
“MIPS is structured to maximize clinician scores,” wrote the commission. MedPAC also stated MIPS scoring is inequitable across clinicians, since clinicians are able to choose their own measures.
Given the payment system’s inefficiencies and complexities, MedPAC suggested a new approach to accommodate the value-based care system in its place.
The commission stated the new approach should achieve the following:
- Align quality and value signals across the healthcare delivery system
- Equitably measure aggregate clinician performance in fee for service (FFS)
- Limit bonuses available in traditional FFS
- Reduce clinician burden.
To achieve these priorities, MedPAC recommended eliminating MIPS and its related reporting requirements. The commission stated policymakers should move to eliminate clinician reporting of quality measures, Advancing Care Information, and Clinical Practice Improvement Activities. Additionally, the commission recommended eliminating CMS support of EHR reporting, no-pay claims, and web interfaces.
To replace MIPS, MedPAC recommended creating a new voluntary value program to build on its June 2017 report to Congress. The June 2017 report highlighted remodeling MIPS so that the program differentiates between high and low performing practices and suggested using population-based measures.
The commission recommended the voluntary value program allow clinicians to elect to be measured with a large entity of clinicians and be eligible for a value payment. Under the new program, all clinicians would have a portion of fee schedule payments withheld—MedPAC suggested a withhold of about two percent. Clinicians would be permitted to elect to join alternative APMs to receive withhold back or opt not to make an election and lose withhold. This would allow for the population-based measurement recommended in the June 2017 report.
“Entities would be collectively measured on population-based measures assessing clinical quality, patient experience and value (similar to alternative APMs),” stated the commission.
CMS would make the same value payment adjustments to all clinicians in each entity, and the downward adjustment would be set as a withhold ahead of time. Additionally, there would be a cap on the value payment as part of the new program.
MedPAC also suggested illustrative measures surrounding clinical quality, patient experience, and value. These measures would be calculated from claims or surveys and aligned with alternative APM measures. Measures could potentially be combined to balance incentives.
Ultimately, MedPAC declared that MIPS is unsustainable in its current form and urged policymakers to take action immediately given that CMS is set to begin making MIPS payment adjustments in 2019.
“The option will encourage clinician’s to join with other clinician’s to assume responsibility for the outcomes of their patients,” wrote the commission.
The voluntary value option would also allow Medicare to adjust funding based on population-based outcomes and allow others to collect and report individual clinician performance.
In June, CMS responded to clinician concerns about the complexity of requirements part of the Quality Payment Program (QPP) by issuing a simplified proposed rule. The proposed rule aimed to reduce clinician burden and benefit small, independent, and rural practices in particular.
Several healthcare organizations and associations—including AMA, AMIA, and AAFP—commended CMS for taking provider feedback into account to improve the program in its second year.