What is going on with MIPS and what are “MVPs”?
The Merit-based Incentive Payment System (MIPS) is one of two tracks under the Quality Payment Program (QPP) that was established by CMS under the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). The MIPS track rewards eligible healthcare providers based on their performance in four categories: Quality, Improvement Activities, Promoting Interoperability, and Cost. It was designed to measure and incentivize high-quality care, effective use of technology, and cost-efficient practices. The MIPS program was implemented in 2017, and has undergone several changes since. One of the newest changes is that in 2023, clinicians will have 3 MIPS reporting options: MIPS Value Pathways (MVP)s, traditional MIPS, and the APM Performance Pathway (APP). The MVP option is designed to streamline the MIPS reporting process and make it more relevant to clinicians. It is meant to help clinicians focus on the measures that are most aligned with their practice, and reduce the burden of reporting on measures that may not be applicable.
What is the timeline?
For the 2023 MIPS performance year, reporting with the MVPs will be voluntary. However, CMS encourages participation so that clinicians can become familiar with MVP reporting before it is mandatory. Currently, participants can choose to report both an MVP and either traditional MIPS or the APP and CMS will take the highest score. Starting in 2026, any multispecialty groups intending to report MVPs will be required to report as subgroups. CMS plans to sunset traditional MIPS in the future and then MVPs will become mandatory unless the clinician is able to report via the APP.
Tell me more about MIPS MVPs.
Under the MIPS MVP program, clinicians will be able to select a specialty-specific or condition-specific set of measures and activities to report on, rather than having to report on all measures across all categories. All clinicians will report on a set of foundational measures that promote interoperability and population health measures. Similar to traditional MIPS, small practices will continue to have flexibility when reporting an MVP. CMS’s goal with the program is to make the reporting process more cohesive and purposeful by having clinicians report on measures that are clinically related. CMS also said that there will be an opportunity for enhanced performance feedback by being able to compare similar practices that report under certain MVPs.
Clinicians can choose to report on one or more of the MVPs, depending on their specialty and practice focus. Each MVP will have a set of measures and activities that are relevant to that area of care. There are currently 12 MVPs that are available for the 2023 performance year.
Below is a brief overview of each of the 12 MVPs:
- Emergency Medicine: focuses on improving quality of care and reducing costs for patients with high-risk conditions by focusing on specific measures and activities related to emergency medicine.
- Advancing Cancer Care: focuses on patient experience, end-of-life care, diagnostics, and treatment options to enhance the fundamental management of cancer care.
- Advancing Care for Heart Disease: focuses on treatment and management of clinical conditions that are caused by or contribute to heart disease.
- Advancing Rheumatology Patient Care: focuses on treatment and management of rheumatological conditions.
- Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes: focuses on prevention and treatment of patients at risk for or that have had a stroke.
- Improving Care for Lower Extremity Joint Repair: focuses treatment and management of people with osteoarthritis who have undergone lower extremity joint repair
- Optimal Care for Kidney Health: focuses on treatment and management of clinical conditions that are caused by or contribute to heart disease.
- Optimal Care for Patients with Episodic Neurological Conditions: focuses on improving quality of care for patients with neurological conditions.
- Optimizing Chronic Disease Management: focuses on the treatment and management of chronic diseases such as diabetes, coronary artery disease, chronic obstructive disease, and major adult depression.
- Patient Safety and Support of Positive Experiences with Anesthesia: focuses on improving the quality of anesthesia care, enhancing postoperative recovery, ensuring patient safety, and increasing patient satisfaction for those undergoing anesthesia in settings ranging from outpatient clinics, ambulatory centers, and hospitals.
- Promoting Wellness: focuses on reducing the risk of diseases, disabilities and death.
- Supportive Care for Neurodegenerative Conditions: focuses on improving the quality of care for patients living with cognitive-based neurological disorders such as dementia, Parkinson’s Disease (PD), and Amyotrophic Lateral Sclerosis (ALS).
Why would a practice choose to report before it’s mandatory?
- More streamlined set of measures that are more applicable to the specialty
- Clinicians can become familiar with MVP reporting before it is mandatory
- There will be an opportunity to receive more relevant feedback from CMS
How will orthopedics be impacted?
The MVP for Lower Extremity Joint Repair includes a set of measures and activities that are designed to improve the quality of care, reduce costs, and promote better outcomes for patients with osteoarthritis who are in need of joint care, such as fracture and total joint replacement. Below is a brief overview of the requirements for 2023.
Quality: this performance category includes measures related to patient outcomes, patient experience, and patient safety. To fulfill quality requirements:
- Select four (4) quality measures from CMS’ list of measures.
- Some examples of quality measures include: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan, Functional Status Assessment for Total Hip Replacement, and Functional Status After Primary Total Knee Replacement.
- At least one (1) quality measure must be an outcome measure
- An example of an outcome measure is the Functional Status After Primary Total Knee Replacement measure.
- Note: if no outcome measures are available, a high priority measure can be reported on.
Improvement Activities (IA): this performance category includes measures related to the implementation of evidence-based practices that improve patient outcomes and reduce complications. To fulfill IA requirements report on one (1) of the following three (3) options:
- Two (2) medium weighted improvement activities from CMS’ list of activities, or
- Some examples of medium weighted activities include: Use of evidence-based decision aids to support shared decision-making, regular training in care coordination and use of QCDR data for ongoing practice assessment and improvements
- One (1) high weighted improvement activity from CMS’ list of activities, or
- Some examples of high weighted activities include Promoting Use of Patient-Reported Outcome Tools or Regularly Assess Patient Experience of Care and Follow Up on Findings.
- The IA_PCMH activity (participation in a certified or recognized patient-centered medical home or a comparable specialty practice).
Cost: this performance category includes measures related to the total cost of care for patients undergoing knee arthroplasty and hip arthroplasty.
- Data does not need to be submitted for this category. CMS uses Medicare claims data to calculate cost measure performance.
Foundational Layer – Promoting Interoperability (PI): this performance category includes measures related to the use of electronic health records (EHRs). To fulfill PI requirements:
- Submit the required PI measures (the same as under traditional MIPS) CMS’ list of activities.
- Some examples of PI measures include E-prescribing, Provide Patients Electronic Access to Their Health Information, and more.
Foundational Layer – Population Health:
- Select one (1) population health measure:
- There are two different population health measures: Hospital-Wide, 30-Day, All-Cause Unplanned Readmission (HWR) Rate for the Merit-Based Incentive Payment System (MIPS) Groups and Clinician & Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions
- You don’t have to submit any data for this measure, CMS will calculate the population health measures using administrative claims data.
Note: The requirements throughout this blog are subject to change annually, so it is important to stay up-to-date with the latest information from CMS to ensure compliance with reporting requirements.
In summary, the MIPS MVP program is a significant change in the ever-evolving MIPS program. While we understand that CMS’s goal was to make the reporting process more relevant to each clinician’s specialty, we also understand that the program is still burdensome for practices. CODE can help practices be successful with outcome-related measures such as the Functional Status After Primary Total Knee Replacement.
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