The Texas Medical Association has raised concerns about Medicare’s Merit-Based Incentive Payment System (MIPS) for years. Now, the U.S. Government Accountability Office (GAO), often called the congressional watchdog, has done the same.
GAO released a report on Oct. 1 that analyzed MIPS data for the program’s first three performance years, 2017 through 2019, and drew on interviews with officials from the Centers for Medicare & Medicaid Services (CMS) and 11 professional organizations that represent Medicare physicians.
It details what TMA and Texas physicians have long known: MIPS is overly complicated, contributes to physician burnout, and does little to improve quality of care and patient outcomes.
Physicians can choose between two CMS Quality Payment Program (QPP) tracks: MIPS, which was designed to incentivize high-quality care through performance-based payment adjustments, or advanced alternative payment models (APMs).
The GAO report found about 950,000 – or roughly half of – Medicare-participating physicians and health care professionals were eligible to participate in MIPS in 2019. The vast majority of eligible physicians – between 95% and 98% – participated in the program, according to CMS, and at least 93% of those who did earned a modest “positive adjustment,” or incentive payment, between 2017 and 2019.
But those interviewed reported that MIPS offered low incentive payments relative to the high administrative burden of participating and did not meaningfully improve patient outcomes. Some also said MIPS incentivized reporting over quality improvements, meaning participants could cherry-pick which performance measures to report, regardless of their relevance.
“For example, to collect data for a particular measure, a physical therapist may evaluate all diabetic patients for proper footwear and sizing, even if the original purpose of their visit was to evaluate their finger,” according to the report.
TMA submitted comments last month in response to CMS’ 2022 fee-schedule proposal, in which it urged CMS to minimize annual changes to MIPS unless they are needed or significantly reduce the administrative burdens required to participate. TMA also called on CMS to provide physicians with a MIPS escape hatch by developing voluntary, physician-led APMs.
TMA and GAO are not the only critics of MIPS. The Medicare Payment Advisory Commission (MedPAC), a congressional support agency that provides independent, nonpartisan advice on issues related to Medicare, has called for MIPS to be scrapped altogether.
“MedPAC shares Congress’s goal, expressed in MIPS, of having a value component for clinician services in traditional Medicare that promotes high-quality care,” Executive Director James Matthews testified before the U.S. Senate Committee on Finance in May 2019. “However, MedPAC believes that MIPS, as currently structured, cannot achieved this goal and, therefore, should be replaced with a better quality payment program.”