MIPS can’t be fixed, MedPAC argues in report to Congress
The Medicare Payment Advisory Commission has released its March 2018 report for Congress, which includes its recommendation to eliminate the Merit-based Incentive Payment System (MIPS) after only one year of clinician reporting to the program.
Following up on MedPAC’s vote in January, the report argues Congress should eliminate MIPS, saying the design of the program is “fundamentally incompatible with the goals of a beneficiary-focused approach to quality measurement” as intended under the Medicare Access and CHIP Reauthorization Act (MACRA).
“The Commission believes that the MIPS program impedes the movement toward high-value care,” the report said. “MIPS will not succeed in helping beneficiaries choose clinicians, in helping clinicians collectively change practice patterns to improve value, or in helping the Medicare program to reward clinicians based on value.”
The report said MIPS has failed on many levels, such as imposing a greater reporting burden on clinicians (by CMS estimates, $1.3 billion in its first year) and having more clinicians exempt than participate. The flexibility touted by CMS in creating the system—where clinicians could choose from a variety of measures on which to be judged—makes scores easy to inflate and impossible to compare, MedPAC determined, even suggesting it “may be worse than no measurement at all.”
MedPAC urged Congress to replace MIPS “as soon as possible” with a concept it calls the Voluntary Value Program, or VVP. While not a fully fleshed out proposal, MedPAC said VVP would revolve around sorting clinicians into virtual groups and being measured on a unified set of measures—clinical quality, patient experience, and value—unless they joined an Advanced Alternative Payment Model (AAPM). The motivation, MedPAC said, would be to “get clinicians comfortable” with AAPM-style measurement.
“With that experience, clinicians would be positioned to form or join robust AAPMs, under which the risk and reward is more meaningful and the potential for true delivery system reform is within reach,” the report said. “Over time, if additional incentives are needed to help clinicians move to AAPMs, the parameters of a VVP could be modified.”
Healthcare groups had been divided on MedPAC’s recommendation earlier this year. The Medical Group Management Association (MGMA) said the March report is “an indictment of MIPS as implemented,” but it disagreed that MIPS couldn’t be improved.
“Its conceptual ‘VVP’ alternative lacks details,” Anders Gilberg, MGMA’s senior vice president of government affairs, said to HealthExec. “MGMA believes there are steps that can be taken now to reduce clinician burden. CMS can begin by shortening the 2018 MIPS data reporting period from one-year to 90 days in the same way the Agency did for Meaningful Use in 2014, 2015, and 2016.”
Beyond the MIPS elimination proposal, the MedPAC report also included its annual recommendations on Medicare payment updates. For three Medicare fee-for-service (FFS) systems—ambulatory surgical centers, long-term care hospitals and hospice care—the commission suggested their payments not be increased in 2019, while skilled nursed facilities shouldn’t get a bump in pay in either 2019 or 2020. Additionally, it recommended a 5 percent cut in payments to home health agencies and inpatient rehabilitation facilities.
Payment was determined to be adequate in several of the major Medicare payment systems, including those for inpatient and outpatient hospital services, physicians and dialysis centers. MedPAC recommended those payments be increased only by “the amount specified in current law.”