During the October public meeting of the Medicare Payment Advisory Commission (MedPAC), the Commissioners held a session to examine the future of the Merit-based Incentive Payment System (MIPS) in which they discussed recommending that MIPS be repealed. During the session, commissioners discussed the complexities and administrative burden associated with implementing MIPS, with specific criticisms focused on measures and scoring concerns, as well as clinical practice improvement areas.
David Glass, MedPAC Principal Policy Analyst, outlined in greater detail the concerns with MIPS. The problem with the MIPS scoring system, he said, stems from the inability to measure clinician’s performance on an individual level. Also, he noted that clinicians can choose the six criteria areas that they wish to be measured in, making it easy to optimize an individual score and rendering the score less reliable.
What Does This Mean
It’s unclear how Congress would react if MedPAC were to recommend repealing or replacing MIPS. Congress is often hesitant to adopt on the Commission’s most ambitious priorities, and lawmakers may be hesitant to reopen discussions on MACRA, particularly given its widely bipartisan history. Similarly, provider organizations — many of whom appreciate the relative flexibility under MIPS — have made significant infrastructure investments to support the adoption of MIPS. While a MedPAC recommendation could foster changes to the program in the vein of relieving administrative burden, wholesale repeal of MIPS is extremely unlikely.
Commissioners, who almost unanimously agreed that MIPS was flawed, concentrated on finding an alternative policy solution that would achieve the original ambitions of MIPS by incentivizing providers to achieve high quality patient care.
MedPAC staff presented an alternative to MIPS that included withholding 2 percent of payments from providers not in an advanced alternative payment model (A-APM), and allowing providers to earn back funds by joining groups of clinicians that would be rated on population-based performance measures. This new approach – the Voluntary Value Program (VVP) – would attempt to align quality and value delivery across the health care system and equitably measure physician performance.
Not all the Commissioners agreed that the VVP represented a significant improvement over MIPS. The VVP would require that clinicians join large “virtual” groups for the purposes of achieving statistically relevant population-based data. There was a concern that clinicians would want to form groups with other high performing clinicians and leave the remaining clinicians in less desirable situations behind. While not all the Commissioners agreed that this alternative represented a significant improvement, the overwhelming sentiment among the commissioners was that MedPAC should recommend repealing MIPS.
There continues to be strong support among commissioners for maintaining the development of APMs. It is important to note that recommending to Congress that they repeal MIPS would not affect the APM program that MedPAC supports.
What Comes Next
MedPAC staff plans to return in December to present draft recommendations to the Commission, which could include a MIPS replacement policy. If they are ultimately approved, they would be slated to appear in MedPAC’s annual March report. We will be sure to monitor the progress of MedPAC in December, and if any progress is made, will provide an update.