The Medicare Payment Advisory Commission (MedPAC) recently published its semiannual report to Congress, which includes a recommendation to eliminate the Merit-Based Incentive Payment System (MIPS). While MedPAC has recommended the elimination of MIPS on more than one occasion, Congress is not likely to take action on repealing MIPS and will leave any changes to the Centers for Medicare & Medicaid Services. The AAHKS advocacy firm, Epstein Becker & Green, has prepared a list of frequently asked questions about MIPS and how an elimination could impact hip and knee surgeons.
What is MIPS again?
MIPS is one of two payment models created pursuant to the Medicare Access and CHIP Reauthorization Act of 2015. In general, physicians who choose the MIPS track over the Advanced Payment Model are scored on four different components:
- Advancing care information i.e. meaningful use of EHRs
- Clinical practice improvement
- Resource use
Different measures are available within each performance category, and clinicians can choose which measures to be scored on for a particular category. Each physician’s score in each of the four categories is weighted to determine a provider’s MIPS Composite Performance Score of up to 100 points. This is used to determine a provider’s overall care delivery and to compute a positive, negative, or neutral adjustment to their future Medicare payments. Participating physicians are compared to all other MIPS-eligible clinicians, regardless of specialty.
Why does MedPAC want to eliminate MIPS?
According to MedPAC, MIPS is “profoundly flawed.” In its report, MedPAC cites the fact that it does not believe MIPS will succeed at its stated goals of rewarding high-value clinicians and reducing payment for low-value clinicians, nor that it will succeed as an incentive program to improve clinician practice patterns. MedPAC also found that MIPS reporting standards were overly burdensome and complex. It was reported by CMS that for 2017, the reporting burden on clinician practices was quantified at $1.3 billion and estimated at $694 million for 2018. The reduction is due primarily to the fact that more clinicians will be exempt from MIPS this year. MedPAC has generally criticized MIPS’ focus on process measures over patient outcome measures, which is another reason why MedPAC voted to eliminate it.
How does MedPAC believe Congress could replace MIPS?
MedPAC proposed that Congress replace MIPS and establish a new voluntary value program (VVP) in its place for clinician services in Medicare fee-for service (FFS). The idea is to encourage clinicians to self-organize into voluntary groups of other clinicians, who would be collectively responsible for patient outcomes. Under a VVP, clinicians would be measured on the same set of population-based measures (clinical quality, patient experience and value), and a group’s performance as a whole would determine if its members qualified for a value payment. Unlike MIPS, measures would be based on claims data rather than criteria tracked in EHRs under meaningful use – significantly reducing a provider’s reporting burden. The goal of the VVP is to sustain a value-based component in Medicare FFS while ultimately encouraging providers to move to advanced alternative payment models.