The Medicare Payment Advisory Committee believes the Merit-based Incentive Payment System, which CMS began implementing this year, is "burdensome and inequitable," and should be eliminated with urgency, according to a report issued Dec. 7.
MedPAC is an independent federal committee that advises Congress on Medicare issues. The committee took issue specifically with MIPS, one of two tracks in the Medicare Access and CHIP Reauthorization Act's Quality Payment Program, not other parts of MACRA.
"Overall, [MIPS] is inequitable, burdensome and will not improve care for beneficiaries nor move the Medicare program and clinicians towards high-value care," the committee's report reads.
Here are five reasons why MedPAC believes MIPS should be eliminated and replaced.
1. MIPS is based on the Value-based Payment Modifier Program, which recent studies suggest worsened care disparities and resulted in high payment adjustments for a small group of physicians, according to MedPAC. For example, of more than 125 physician practices evaluated under the Value-based Payment Modifier in 2015, just 14 received positive payment adjustments.
2. Reporting is burdensome. MedPAC estimates reporting under MIPS in 2017 alone — which was the first year of reporting and did not require reporting in full — will cost clinicians more than $1 billion.
3. Many of the reported measures are not meaningful. MedPAC specifically called out the Advancing Care Information and Clinical Practice Improvement Activities categories of the program as irrelevant to high-value care.
4. Scores will not be comparable across clinicians, but will be used to allocate payment across clinicians. Three of four categories in MIPS allow physicians to choose and report measures, resulting in little overlap between measures and requiring different levels of effort.
5. Sample sizes are small. This makes the data less meaningful, particularly in view of population-based measures.
MedPAC called for urgent action on MIPS to eliminate it and create a new program.
The committee believes an improved, voluntary alternative to MIPS should be created. It envisioned this alternative as preserving the value components of MIPS and the program's overall goal to push physicians into Advanced Alternative Payment Models. However, the new program would be uniform, population-based and claims-calculated, and measures would be determined in part by what patients believe is important. The committee would allow physicians to join on a voluntary basis and form larger groups to support population-based measures, ultimately allowing group performance to determine a value payment to physicians.
"[The] time for action is now, before there is an established constituency of clinicians getting very high positive adjustments," the committee reported.
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