Physicians wouldn’t be measured on meaningful use of electronic health records (EHRs) in the new Merit-based Incentive Payment System (MIPS) under a proposal floated by the Medicare Payment Advisory Commission (MedPAC).

It’s only a discussion at this point, as MedPAC serves to advise Congress on Medicare issues and the elimination of meaningful use would require action from Congress, but it shows a level of contempt from the organization toward the new Medicare Access and CHIP Reauthorization Act (MACRA) payment tracks.

In a presentation from MedPAC analysts Kate Bloniarz, David Glass and Ariel Winter, MIPS is labeled as “unlikely to succeed at identifying or paying for clinicians delivering value to the program” and will only increase administrative burden on providers. The attestation-only data elements in MU activities, the trio said, haven’t been shown to correspond to high-value care.

Their recommendation is to use a set of “population-based outcome measures” to assess performance within a virtual group or a referral area. Among those suggested outcomes are preventable readmissions and emergency department visits, mortality rates, patient experience and relative resource use.

Under the system, no meaningful use or practice improvement activities would be reported by individual clinicians to Medicare. Clinicians would instead be measured as a group or area.

The “illustrative proposal” suggests MIPS should be made less attractive to drive more clinicians toward advanced alternative payment models (APMs), limiting the upside risk and moving MIPS’ $500 million fund to reward exceptional performance to advanced APMs to create “asymmetric risk corridors” that would offer greater performance bonuses than penalties.

According to the presentation, this would encourage more accountable care organizations to take on two-sided risk.

While providers expressing frustration with MU requirements is nothing new, major medical groups aren’t eager to make such drastic changes to MACRA—at least not yet. A letter sent from the American Hospital Association (AHA) to MedPAC after its January meeting said since the law’s first performance period in MIPS and advanced APMs began only this year, with most providers being allowed to “pick their pace” in 2017, there’s not enough data or experience with the programs for MedPAC to suggest major shifts.

“The commission’s proposals to, for example, limit the upside potential under the MIPS and eliminate the exceptional performance bonus could serve to punish providers who are devoting significant resources to transitioning into the more value-based approach encompassed by the MIPS,” AHA Executive Vice President Tom Nickels wrote. “It could be especially biased against small practices that have many fewer options to participate in advanced APM models.”