October 9, 2017

MedPAC pans MIPS, may urge Congress to scrap it

Daily Briefing

    The Medicare Payment Advisory Commission (MedPAC) during a meeting Thursday discussed whether the commission should recommend Congress eliminate or replace MACRA's Merit-based Incentive Payment System (MIPS).

    Access the 2017 Merit-Based Incentive Payment System (MIPS) score estimator

    Background

    Under MACRA's Quality Payment Program (QPP), which took effect in 2017, eligible professionals can choose from two payment tracks:

    • The Advanced Alternative Payment Model (APM) track, for clinicians who take on a significant portfolio of Advanced APMs, which include risk-based accountable care organization models; or
    • The MIPS track, for providers who are reimbursed largely through fee-for-service.

    Eligible providers who participate in MIPS for the 2017 reporting year will receive penalties or bonuses of up to 4 percent beginning in 2019. That percentage will rise incrementally until it reaches 9 percent in payment year 2022.

    CMS has called 2017 a "transition" year for the program. Providers who were ready to begin participating in the program could start collecting performance data on Jan. 1. Providers who were not yet prepared to participate had until Oct. 2 to begin collecting performance data. Providers participating in the program for the 2017 reporting year must submit all data to CMS by March 31, 2018, regardless of when collection began.

    MedPAC considers whether MIPS should be eliminated and replaced

    MedPAC members suggested that MIPS' flexibility makes it overly complex and is unlikely to achieve its intended policy goal of rewarding high-quality care, MedPage Today reports.

    According to CQ HealthBeat, that echoes the concerns of some providers, who have said that MIPS in its current form imposes burdensome reporting requirements.

    During Thursday's meeting, MedPAC members also critiqued the degree to which MIPS:

    • Allows clinicians to decide which measures they will be evaluated on, likely leading clinicians to pick metrics for which they are high-performers; and
    • Focuses on process measures, rather than patient outcomes measures.

    Nearly all members of the commission on Thursday agreed MIPS should be eliminated, but they were undecided on whether MIPS should be replaced with a new payment system, CQ HealthBeat reports.

    Two commission members—David Glass, a principal policy analyst for MedPAC, and Kate Bloniarz, a senior analyst for MedPAC—recommended replacing MIPS with a "voluntary value program." Bloniarz said the voluntary program would eliminate MIPS' data reporting requirements and instead leverage population-based measures from Medicare claims data or "centrally conducted surveys."

    Under the voluntary value program, CMS would withhold a certain amount of a physician's pay, unless they agreed to be evaluated on a set of population measures among a larger group of physicians. Specifically, MedPage Today reports clinicians would have the option to:

    • Be measured with a "sufficiently large entity" of clinicians and receive value payment;
    • Lose withheld fee schedule money; or
    • Participate in an advanced APM model.

    Bloniarz said the large entity of clinicians could include physicians at a single hospital or in one geographic region. She said an "entity's performance would then be collectively measured using a set of population-based measures." Those population measures could fall into three categories:

    • Clinical quality, which might include measures such as avoidable admissions or mortality;
    • Patient experience; and
    • Value.

    Most of the commission members expressed their support for a new payment system, but a few questioned whether another program is necessary. Craig Samitt of Anthem said, "If a replacement is a voluntary model that would allow us to keep practicing healthcare the way we've been practicing, then that replacement is not a good replacement."

    Ultimately, Commission Chair Francis Crosson tasked MedPAC's technical team to develop draft recommendations for repealing MIPS and replacing it with a voluntary program similar to the one proposed by Glass and Bloniarz, as well as ways to increase physician access to advanced APMs.

    MedPAC will vote on whether to recommend the proposal to Congress in December (Clason, CQ HealthBeat, 10/5; Dickson, Modern Healthcare, 10/5; Firth, MedPage Today, 10/5).

    5 things everyone should know about MACRA

    The implementation of MACRA is the most notable change to Medicare physician payment in over a decade. Passed with bipartisan support, MACRA changes the way Medicare pays clinicians.

    Check out our infographic to see the no-regrets strategies to prepare your organization for success under MACRA.

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