AHA to MedPAC: Eliminating, changing MIPS would confuse providers

The American Hospital Association (AHA) suggested the Medicare Payment Advisory Commission (MedPAC) pump the brakes on advocating for major changes to Merit-based Incentive Payment System (MIPS), saying any major shifts wouldn’t have “the benefit of data or experience” considering this is the program’s first performance year.

At its November meeting, MedPAC said MIPS should be eliminated altogether, arguing it’s too complex, too burdensome on physicians and its measures won’t push high-value care. In its place, the commission proposed the Voluntary Value Program (VVP), where 2 percent of clinician payment would be withheld unless clinicians either joined an advanced alternative payment model (APM) or elect to be measured as part of larger group on “population-based measures” assessing clinical quality, patient experience and value.”

The AHA did support the general idea of allowing clinicians choose their own groups “as it provides a way to share resources and improvement strategies.” But the VVP approach suggested by MedPAC would likely using measures drawn by Medicare claims data and patient surveys which the AHA considers unreliable.

“Without question, using Medicare claims entails less data collection effort on the part of clinicians,” Ashley Thompson, AHA’s senior vice president of public policy analysis, wrote to MedPAC. “However, claims data cannot and do not fully reflect the details of a patient’s history, course of care and clinical risk factors. Such information is crucial to performing the risk adjustment that most outcome measures require to fairly compare provider performance. As a result, many claims-derived outcome measures do not accurately reflect provider performance.”

Thompson’s letter said the AHA “appreciates” the commission’s interest in improving MIPS. The association has been in favor of CMS policies to ease the transition into the new system, such as making 2017 a “pick your pace” year for clinicians and exempting many more from participation in 2018. Making significant changes, however, won’t help AHA members who are still getting used to MIPS.

“Changing course on the MIPS so soon after program implementation could lead to confusion in the field, and prompt clinicians to spend time deciphering the requirements of a new program rather than on improving care,” Thompson wrote.

The AHA made a similar plea to MedPAC earlier this year when it suggested making MIPS less attractive to drive more clinicians towards Advanced APMs and two-sided risk.