Despite recent objections from the Texas Medical Association, Medicare’s Merit-Based Incentive Payment System (MIPS) will launch a new, optional reporting framework during the 2023 performance year.
The Centers for Medicare & Medicaid Services (CMS) says the so-called MIPS Value Pathways (MVPs) will reduce physicians’ reporting burden and integrate measures to be more relevant to physicians’ scope of practice.
But TMA and others in organized medicine have long voiced concerns about the complexity of the MIPS program and the heightened administrative burden that comes with each update.
MVPs are one way MIPS-eligible physicians can meet their MIPS reporting requirements. They include a subset of measures and activities tied to a specific specialty, clinical condition, or episode of care, according to the recently launched Explore MVPs webpage.
The seven pathways available starting in the 2023 performance year are:
- Chronic disease management,
- Emergency medicine,
- Heart disease,
- Lower extremity joint repair,
- Rheumatology, and
- Stroke care and prevention.
Jorge Duchicela, MD, a family medicine physician in Weimar and a member of TMA’s Council on Health Care Quality, participates in MIPS. He says his rural, three-physician practice has had to hire medical assistants to keep up with the program’s onerous reporting requirements. In exchange, MIPS offers small incentives, large financial penalties, and little proof it is improving patient outcomes.
“My experience with MIPS has been a love-hate relationship,” he said. “More of a hate relationship than a love relationship.”
Although MVPs will be optional in the 2023 performance year, CMS indicated in the 2022 physician fee schedule final rule that it plans to make the reporting framework mandatory in the future, starting with multispecialty groups. They will be required to form “subgroups” based on specialty, with each subgroup choosing a pathway to report in the 2026 performance year.
Dr. Duchicela acknowledges the good intentions and hard work that have gone into developing MVPs. But he fears this eventual takeover will force physicians like him to adapt to a new, unproven iteration – or risk consequences.
“The specter is that … if you don’t get on board sooner or later, they’re going to ding you for not participating and cut your fees,” he said.
TMA has asked CMS to reconsider MVPs and instead focus on the development of voluntary, physician-led alternative payment models, most recently in a September 2021 comment letter. But CMS remains on track to implement the new MVP reporting framework in the next performance year.
MIPS-eligible physicians who choose the MVP route – as an individual, group, subgroup, or alternative payment model entity – will receive comparative performance feedback based on like clinicians who report on the same pathway, according to CMS. The agency says it will delay public reporting of new improvement activities and certain measures by one year to give MIPS-eligible clinicians time to familiarize themselves with the new framework, according to an FAQ on the Explore MVP webpage.
The 2023 proposed Medicare physician fee schedule is expected to further address MVPs and their implementation. CMS typically releases the fee schedule proposal in early July.