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January 16, 2018

MIPS would be scrapped—if MedPAC gets its way

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    The Medicare Payment Advisory Commission (MedPAC) on Thursday voted 14-2 in favor of urging Congress to end the Merit-based Incentive Payment System (MIPS) program and replace it with a new voluntary value-based payment program.

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

    MedPAC will include the recommendation in its annual report to Congress in March. Medscape reports that it is uncertain how lawmakers—which passed MACRA with broad bipartisan support—will react to the recommendation to scrap MIPS.


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

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

    Eligible providers who participate in MIPS in 2017, which CMS deemed as a "transition" year for the program, will receive penalties or bonuses of up to 4% beginning in 2019. That percentage will increase up to 5% in payment year 2020, and rise incrementally until it reaches 9% in payment year 2022.

    MedPAC members during an October 2017 meeting said that MIPS' flexibility makes it overly complex and that the model is unlikely to achieve its intended policy goal of rewarding high-quality care. 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 outcome measures.

    MedPAC members vote in favor of replacing MIPS

    MedPAC members on Thursday voted to approve a draft recommendation to replace MIPS with a voluntary value-based payment program, called the Voluntary Value Program (VVP), under which physicians would join reporting groups that would be compared with other groups on certain performance-based quality of care measures. CMS would track physicians' performance on the measures based on their Medicare claims, meaning physicians themselves would not have to report on the quality measures.

    Under the new model:

    • Physicians with comparatively higher scores on the measures would receive incentive payments; and
    • Physicians that do not participate in any alternative payment model would have a certain percentage of their Medicare payments withheld.

    According to MedPage Today, MedPAC originally had considered withholding 2% of nonparticipating physicians' payments, but ultimately did not include a specific suggested rate in their recommendation.


    Prior to the vote, several commissioners discussed whether the proposed MIPS replacement would be adequate—and following the vote, some industry stakeholders said the commission would have done better to propose ways to improve MIPS, instead of replacing it, Modern Healthcare reports.

    Commissioner Warner Thomas, president and CEO of Ochsner Health System in New Orleans, said, "I'm not afraid to make an unpopular decision, but I want to make sure we do something constructive" that moves the industry in "the right direction.'"

    However, Commissioner Alice Coombs, of South Shore Hospital in Weymouth, Massachusetts, who voted against the recommendation, said she believes MIPS does have "a lot of problems," but objecting to the timing of implementing VVP.

    The other no vote, Commissioner David Nerenz of Henry Ford Health System in Detroit, said that he was concerned that the "cool people," which he defined as those who perform well because their patients are "educated" and "take good care of themselves," will form their own groups, leaving whoever isn't part of "the cool people's rush process" out of the program. He also expressed concerns that the model would rely on CMS to adjust for different social and economic risk factors. "I do not have confidence that that will go well," he said, adding, "Poor people will be hurt."

    David Barbe, the president of the American Medical Association, in a statement said he preferred a simplification of MIPS to a new program. "The best remedy is to fix MIPS rather than jumping into another sweeping change that has not been fleshed out and would have many of the same methodological issues as MIPS," he said. "We strongly urge Congress to pass our proposal to provide CMS with the time and flexibility to address these issues."

    Stephen Epstein, an emergency physician at Beth Israel Deaconess Medical Center in Boston, said that he believes MedPAC was wrong. "MIPS could change practice patterns by aligning incentives with performance measures," he said (Firth, MedPage Today, 1/11; Dickson, Modern Healthcare, 1/11; Young, Medscape, 1/11).

    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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