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MedPAC Recommends CMS Simplify MIPS Reporting Requirements

MedPAC issued a detailed proposal to Congress requesting simplified MIPS reporting requirements and further incorporation of patient outcomes.

Merit-based Incentive Payment System reporting

Source: Thinkstock

By Kate Monica

- A congressional agency recently issued its June report highlighting the need to improve the Merit-based Incentive Payment System (MIPS) track part of the Quality Payment Program (QPP) by reducing administrative burden and increasing the importance of positive patient health outcomes.

Presently, physicians participating in MIPS will be assessed based on quality, cost, practice improvement, and use of EHRs.

Physicians participating in the advanced alternative payment model (AAPM) track take on more risk to qualify for higher incentive payments. Physicians using advanced APMs earn up to a 5 percent incentive payment starting in 2019 for delivering high quality coordinated patient care.

According to the American Academy of Family Physicians (AAFP), health policy analysts are skeptical MIPS will attract enough physicians to meet the goals CMS has set forth for the program.

In its report, the Medicare Payment Advisory Commission (MedPAC) took issue with the fact that MIPS in its current form does not differentiate between high and low performing practices, opening the door to the possibility that minor variations in quality scores could yield starkly different payment bonuses. 

Presently, there are 275 quality measures in MIPS.

These quality measures mostly assess standards of care and processes. Rather than directly measuring patient health outcomes, MIPS focuses on whether clinicians are ordering tests appropriately or properly adhering to clinician guidelines.

According to MedPAC, the degree of difficulty between MIPS performance categories varies greatly. As such, CMS may not meet its goals for the program if a large amount of physicians choose measures in which a considerable percentage of practices score well.

"Many of these measures are poorly linked to outcomes of importance for beneficiaries and the program and, instead, reinforce the incentive in fee-for-service (FFS) Medicare to provide more services than are clinically necessary," stated MedPAC in its report.

Additionally, individual physicians often have few patients qualifying for each measure. This makes it difficult to differentiate between contrasts in performance and differences in sample size.

"MIPS as presently designed is unlikely to succeed in helping beneficiaries choose clinicians, helping clinicians change practice patterns to improve value, or helping the Medicare program reward clinicians based on value," stated the report.

To mitigate potential issues, MedPAC suggested CMS use more population-based outcome measures. Additionally, the organization recommended CMS rely more on claims data and survey results rather than physician reporting.

The MedPAC proposal recommended modifying MIPS to use claims data as a way to score performance in population health management categories such as avoidable hospital and emergency room visits, mortality and readmission rates following hospital stays, healthy days, patient experience, rates of low-value care, and resource use.

Utilizing this data, said MedPAC, would offer insight into ambulatory care settings and care delivery systems without requiring physicians to spend time on data reporting that could be better spent focusing on patient care.

"The benefits of using population-based measures are significant," stated the organization. "This approach sends clinicians a signal that they should view the care they provide as part of a continuum that crosses sectors and incorporates the totality of patient care. This perspective helps to counter the silo-driven FFS system that encourages providers to focus only on the services they directly provide."

However, MedPAC admits, modifying MIPS in this way would not give CMS access to data on individual practice performance.

These recommendations could encourage physicians that do not want to be measured against their local performance group to join a virtual group of practices, readying them to potentially join an accountable care organization or advanced APM.

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