Is MIPS dead? 5 questions, answered

The Medicare Payment Advisory Committee, a federal group tasked to advise Congress on Medicare, voted in January to eliminate the Merit-based Incentive Payment System and replace it with an alternative program. MedPAC characterized the clinician payment program as "burdensome and complex." What does this change mean for providers?

Becker's tapped Tim Gronniger, senior vice president of strategy and development at Caravan Health, to answer this question. Mr. Gronniger served as the CMS deputy chief of staff under the Obama administration and helped write MIPS. Here we answer five top questions about the short-term future of the MIPS program.

1. What's wrong with MIPS? That MIPS is flawed is no secret among clinicians. "There's no question that they don't like MIPS," Mr. Gronniger says. "There's an attitude that this is a lot of work with no benefit." The program is seen as confusing and particularly burdensome for independent physicians.

To be fair, MIPS has baggage. It's a mashup of past programs, like the value-based payment modifier program and meaningful use, and as such, it has been dogged with complaints that once haunted those initiatives. For example, MedPAC has pointed to studies that show the value-based patient modifier worsened care disparities and resulted in payment adjustments for a concentrated group of physicians. Many clinicians also feel the incentives are misaligned, pushing them to report on measures that are easiest to improve, rather than working on true practice or outcome improvements. "No one wants to practice that way," Mr. Gronniger says.

2. What does MedPAC want to replace it with? MedPAC's solution is the voluntary value program, which — like MIPS — still has an overarching goal to push physicians toward participation in Advanced Alternative Payment Models, the more "elite" track of the Quality Payment Program. However, the VVP would automatically withhold 2 percent of a physician's fee schedule payments, which could be earned back by participating in an AAPM or by opting into a voluntary group for a performance assessment. The assessment would use population-based, claims-calculated measures and evaluate groups on clinical quality, patient experience and value.

3. How does the VVP compare? The VVP has its own flaws. "Claims-collected measures, as applied to physicians right now, haven't been working very well either, which is one reason I'm skeptical of this proposed replacement," Mr. Gronniger says. "The reason most clinicians and Congress don't like it is it starts with a 2 percent withhold, and then your best upside case is clawing back that 2 percent."

4. How likely is Congress to act on MedPAC's recommendation? The short answer? Not likely. Though MedPAC plays an important role in what Medicare legislation Congress considers, MIPS is an unlikely target at the moment. "Congress has made it pretty clear they don't want to comprehensively revisit the MIPS program right now," Mr. Gronniger says. Much of the discussion is tied up by funding legislation, and there's no easy fix. "There's not a silver bullet," he says. "There is a lot of attachment to the structure of MIPS, and I think the major thing to do is to figure out another way to reward participation in AAPMs and focus on a discrete set of activities that are known to improve care, not attempt to measure each physician in the country individually."

5. Will MIPS change at all this year? Some small changes are likely, according to Mr. Gronniger. Specialty societies, in particular, are pushing CMS to keep delaying full implementation of MIPS. This could happen, Mr. Gronniger says, but it's unlikely delays will continue forever. Another change to the program physicians may see this year is taking Part B drugs out of the payment adjustment, he says.

Unless Congress takes up MedPAC's recommendation, Mr. Gronniger advises physicians to get involved in other value-based programs like ACOs, which can provide a framework to proactively address many MIPS requirements. "[It's] better, from our perspective, to have physicians and hospitals working together to improve quality and cost on predefined dimensions. The ACO program has a set of 30-plus quality measures that are tracked. When you sign up for the ACO program, that's what you're signing up to work on, and there's a very well-understood cost benchmarking process that you are judged on as part of an ACO," Mr. Gronniger says. "

Editor's note: This article was updated at 4:55 p.m. CT. It incorrectly stated Part B drugs might be brought into the MIPS payment adjustment, but Part B drugs are already part of the payment adjustment. They may be taken out this year. We apologize for this error. 


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