GAO Report Indicates Providers Question MIPS Outcomes

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Some providers question whether the Merit-based Incentive Payment System (MIPS) program is improving the quality of patient care or outcomes, according to a new report released October 1. The U.S. Government Accountability Office (GAO) recently analyzed performance data from 2017-2019 and interviewed officials from both the Centers for Medicare & Medicaid Services (CMS) and 11 organizations representing MIPS-eligible specialty providers. Many of those interviewed expressed doubts about the effectiveness of the initiative.

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Congress authorized MIPS under the Medicare Access and CHIP Reauthorization Act of 2015, hoping to reward value, rather than complexity and volume of services. The system incentivizes physicians and other providers through payment adjustments based on their performance. All told, about 950,000 providers were MIPS-eligible participants in 2019, the GAO noted.

“Stakeholders stated that the design of the MIPS program may incentivize reporting over quality improvement, and thus, MIPS scores did not necessarily reflect the quality of care provided, but rather how well providers were complying with the reporting requirements of the program,” the report noted. “Some stakeholders said that to maximize payment adjustments, providers may choose to report on performance measures on which they are performing well or that are easy to achieve, rather than measures in areas where they may need improvement or that are clinically relevant.”

Among other concerns, 10 of the 11 stakeholders said that CMS’ feedback on providers’ scores and performance was not timely or meaningful. Some also believe certain quality measurements assess activities that are irrelevant for some specialties, and that the process for developing new metrics can be “time consuming and expensive.” Another eight stakeholders said participating in MIPS produces a low return on investment, with miniscule payment adjustments compared to the high administrative costs incurred.

Positively, 2 of 11 interviewees cited the MIPS low-volume threshold as a strength, reducing participation burden for smaller practices with lesser Medicare tallies. Two stakeholders also highlighted bonuses for small practices and treating complex patients, which increased scores for otherwise disadvantage providers. Three of 11 respondents commended the performance-category exemption, allowing participants to reduce excess burden.

“For example, some providers, such as radiologists and pathologists, automatically qualify for the ‘promoting interoperability hardship’ exception, and thus, are exempt from that category,” the report noted. “CMS acknowledged that the exception was beneficial for certain providers who lack the ability to (1) affect their practices’ health information technology decisions or (2) have the face-to-face patient interactions required for many of the measures in the promoting interoperability category,” it added.

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