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MIPS Value Pathways (MVP)

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The MACRA journey of more than 3 years to advance the value-based reimbursement was difficult for clinicians to adapt – economically and operationally. Significant time and effort were invested in reaching out to clinicians and educating them on MACRA and its impact on payment. Clinicians felt disconnect in the number of measures across the four performance categories of MACRA that they need to report on. Burden of reporting, penalties when thresholds are not met were few reasons that had led the clinicians to demand for changes in the way performance is evaluated. CMS plans to cluster practice according to specialties MIPS Value Pathways (MVP) to report on a subset of measures, which are relevant to their work across the four performance categories. MVPs are intended to reduce the complexity of the MIPS program and the burden to participate.

MVP Overview

MIPS Value Pathways (MVPs) is a conceptual participation framework that would apply to future proposals beginning with the 2021 Performance Year. The goal of MVPs is to shift from siloed activities and measures to an aligned set of measure options relevant to a clinician’s specialty or practice area that is meaningful to patient care.

  • Based on feedback on MIPS program from multiple stakeholders, CMS intends to:
  • Reduce clinical burden
  • Drive value through meaningful participation of all clinicians from specialists to primary care clinicians
  • Improve outcomes for patients
  • Ease clinician’s transition to <insert full form> (APMs)
  • Focus on important public health priorities

CMS suggests four guiding principles for developing MVPs:

  • Reduce clinician burden and simplify scoring by allowing clinicians to choose MVPs that encompass limited sets of measures and activities that are connected to their specialty or condition
  • Patients and caregivers should be able to choose their clinicians through comparative evaluation of clinician performance
  • Encourage clinicians to focus on performance improvement in high priority areas
  • Facilitate transition of clinicians to APMs by prioritizing quality measures that align with improvement activities and cost measures

Benefits of this framework include:

  • More streamlined and cohesive reporting
  • Enhanced and timely feedback
  • Enable physicians to focus on episodes of care instead of current, fragmented approach, making MIPS more clinically relevant and practical
  • Help patients compare clinician performance and make informed choice in selecting clinicians

MVP Key Highlights

  • MVPs will come into effect from 2021 MIPS Performance Year
  • The MVP framework will initially consist of a foundational layer of population health claims-based measures
  • The framework will also consist of interoperability over which measures from quality, cost and improvement activities that are relevant to the specialty or condition would be aligned
  • Each MVP will compose of a subset of measures and activities established through rulemaking rather than being specified by CMS
  • CMS will be working closely with clinicians, patients, specialty societies, stakeholders, third parties and others in the rule making process
  • Clinicians would have one or more applicable MVPs since the existing 39 specialty measure sets target more than one condition
  • If clinicians do not have a relevant MVP to choose in 2021, they will continue to participate in MIPS as in previous years

Performance Category

Category

Current Implementation

MVP Implementation

Promoting Interoperability

  • ​MIPS eligible clinicians must report on a minimum of 6 Interoperability measures
  • Promoting Interoperability measures will for part of the foundational element
  • Initially, most clinicians might report on a uniform set of measures related to Promoting Interoperability (PI)
  • Thereafter, PI measures will be aligned to each specialty
 

Quality

  • MIPS eligible clinicians must choose a minimum of 6 quality measures from  250+ MIPS quality measures available for reporting in the 2019 performance period of MIPS
  • This includes measures available through most MIPS collection types such as eCQMs, MIPS CQMs, Medicare Part B claims measures (small practices only), CMS Web Interface measures (registered groups of 25+), and the CAHPS for MIPS survey measure
  • Clinician reporting through a QCDR can report on approved QCDR measures developed by the QCDRs
  • For each MVP, CMS intends to prioritize outcome and patient reported measures, non-topped out measures that will best assess the quality and value of care within a specialty or condition
  • CMS might focus more on Electronic Clinical Quality Measures (eCQMs) as they have the potential to decrease reporting burden within MVPs

Cost

  • Total per capita cost (TPCC) and Medicare spending per beneficiary (MSBP), two measures that capture global spending. These are limited in providing clinically relevant, episode specific spending information
  • 8 episode-based cost measures from 2019 PY
  • Each MVP will include those Cost measures that fit into that specialty or condition. For this CMS will be increasing the number of available episode-based cost measures

Improvement Activities

  • Clinicians must choose relevant activities from an inventory of 118 activities
  • Specialty-specific, condition focused improvement activities for each MVP or,
  • Any improvement activities that are relevant to the practice such as patient experience and engagement, team-based care, and care coordination

Population Health Measures

  • Currently there is one administrative claims-based population health in BPCI Advanced Payment Model
  • The All-cause Hospital Readmission measure, which is calculated and scored for groups with 16 or more clinicians that meet a 200-patient case minimum
  • These foundational measures will be focused on public health priorities and/or cross-cutting population health issues
  • CMS will provide data through administrative claims measures,  consequently reducing clinician burden

 



Group Reporting

Multispecialty Practices

Challenge: Multispecialty groups, especially with several clinicians, often provide an array of services that may not be captured in a single set of measures or in a single MVP.

Possible solution

1. Allow a portion of a group to report as a separate sub-group on measures and activities that are more applicable to the subgroup and be assessed and scored accordingly based on the performance of the sub-group.

2. MVP approach - Multispecialty groups would report on multiple assigned or selected MVPs, where assignment or selection of MVPs would be at group level. Depending on how the MVPs are then combined and scored at the group level, this may eliminate the need for groups to create sub-TIN identifiers and apply eligibility criteria at the sub-TIN level.

3. This will avoid unwanted operational and data collection efforts associated with creation and maintenance of identifiers for sub-groups. An upper limit will be placed on the number of MVPs, measures, and activities reported by the multispecialty practices.


Scoring

The quality and cost performance measures within MVPs would be scored on a scale of 0 to 10 and performance is assessed against a benchmark(using the current approach to calculate benchmarks). The framework for scoring Promoting Interoperability measures may not change.

  • Benchmark: For quality measures, MVPs would use a single benchmark for each measure and all clinicians and groups in the MVP would be compared against the same standard. With the standardized sets of measures in MVPs, data collected can be used to develop robust benchmarks in the future before scoring on performance new measures.
  • Bonuses: As clinicians would be required to report all measures and activities in the MVP, there won’t be any bonuses and special scoring policies that were traditionally added to incentivize selection of certain measures.


Overall Impact on Clinicians

Specialties can now focus on measures affecting their practices, rather than having to choose from some generic MACRA measures, which’d have diluted focus and prevented them from achieving their best performance.

Future State of MIPS

CMS will systematically align Quality measures and Improvement activities to provide more relevant data to clinicians on their performance, which may lead to significant cost savings. The quality, cost and improvement activities will be further aligned and be based on foundational measures in the areas of patient-reported outcomes. This will encourage clinicians to shift to APM participation.

In the future state of MIPS, clinicians will report on a foundational set of measures with focus on patient care which will include:

  1. Promoting Interoperability
  2. Population Health Measures
  3. Enhanced Performance Feedback
  4. Patient-Reported Outcomes

Patient Reported Outcomes: CMS may include additional patient reported measures such as patient experience and satisfaction measures and clinical outcomes measures. Patient feedback will enable clinicians to deliver better patient care and also empower patients to take decisions about their healthcare.

Enhanced Performance Feedback: Subsequently, stable MPVs will enable CMS to provide clinicians with actionable data feedback which will help clinicians to understand their performance and encourage them to take risks which may be necessary in Advanced APMs.

CitiusTech Perspective

MVPs will allow clinicians from same specialties to be compared on the same set of quality and cost measures. This will not only help patients to choose between care providers but also encourage providers to constantly make changes in practice patterns to improve performance.

Since its inception, MIPS has caused lot of confusion and unnecessary burden on clinicians from specialties. Such clinicians not only chose from a common pool of performance measures every year, but also would need to select measures which did not meaningfully target an episode of care undergone. With MVP, this can be significantly reduced since an active participation of specialty or condition clinicians during the rule making process will ensure that each MVP will contain only those measures which come under clinician’s scope of practice that is meaningful to patient care.

With Promoting Interoperability as part of the foundational element and greater focus on the specialty, new measures can be developed that supports not only on certified health records (EHRs), but also on technology that builds on certified EHRs.

MVP largely seems to be a step in the right direction to reduce reporting complexity, help specialties maintain focus on their relevant areas and constantly improve clinical performance through CMS affected feedback mechanisms. The new framework will be instrumental in helping CMS gather more statistical data that can be used in analyzing and improving overall population health.

 

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