The MIPS Needs Ongoing Improvement, Not Replacement

The second year of the Merit-based Incentive Payment System (MIPS) required by the Medicare Access and CHIP Reauthorization Act (MACRA) began on Jan. 1. Yet last month, the Medicare Payment Advisory Commission (MedPAC) voted to recommend that Congress repeal the MIPS and replace it with a new “voluntary value program” (VVP). MedPAC suggests that MIPS is burdensome, inequitable, and too complex and thus “cannot succeed.” But is it really time to scrap the MIPS barely one year into implementation?

Would the VVP Work?

While MedPAC’s recommendation lacks some details, the proposed framework for the VVP would incentivize clinicians to move toward advanced alternative payment models (A-APMs) by limiting potential bonuses in fee-for-service Medicare. Clinicians not in an A-APM would have a choice between entering the VVP or losing the entire fee schedule withhold. Under the VVP, clinicians would form groups and be scored on uniform, population-level, claims-based measures. MedPAC suggests the use of these measures would reduce data reporting burden. If clinicians could not find a group to join, MedPAC has suggested that CMS could create a virtual “fallback” group as a default. MedPAC suggests that forming these groups under the VVP would serve as an “on-ramp” to forming an A-APM.

However, the AHA believes that MedPAC’s recommendation to scrap the MIPS is not only premature but also misguided. Clinicians and hospitals will submit MIPS data for the first time this month. Instead of assuming the program is unworkable before clinicians submit any data, MedPAC should use data and experience from the field to inform any major changes.

Furthermore, the AHA and other stakeholders question the feasibility VVP. The proposed measures would apply to all groups, but may be irrelevant to some specialties, and there are few A-APMs for specialists to join as an alternative. And forming groups might be impossible for some clinicians due to practice or geographic constraints; the virtual “fallback” group would be both logistically challenging and of dubious value, as clinicians would be a group in name only and could do little to influence the overall quality of care provided. Further, AHA and others are concerned by the heavy reliance on claims-based measures, whose reliability and accuracy can be problematic, to evaluate performance.

In short, now is not the time to scrap the MIPS. The MACRA passed with strong bipartisan support, and the VVP is not a compelling alternative. Moreover, hospitals and their clinician partners have made significant investments of time, effort, and other resources to prepare for the new program.

Making MIPS Better

However, the MIPS is not perfect, and AHA has advocated for several improvements to make the MIPS fairer and less burdensome. For example, as we have long urged, hospital-based clinicians will be able to use their hospital’s value-based purchasing program results in the MIPS – rather than reporting separate data – starting with the 2019 performance year. We have urged CMS to expand the option to a broader range of facility types. And we will continue to urge CMS to refine its approach to accounting for the impact of socioeconomic factors on MIPS performance.

For additional information about AHA’s resources to help hospitals and health systems and their clinician partners prepare for MACRA, visit www.aha.org/MACRA.

Nancy Foster, vice president of quality and patient safety policy, is part of AHA’s MACRA team.