GAO Report on MIPS
Jason Shafrin
Senior Managing Director, Center for Healthcare Economics & Policy at FTI Consulting; Adjunct Professor, University of Southern California
The Government Accountability Office (GAO) last week published a report evaluating the Merit-based
Incentive Payment System (MIPS). MIPS is an approach for CMS to pay physicians caring for Medicare beneficiaries based not just on volume but on value. MIPS evaluates provider value along four dimensions: (1) quality, (2) improvement activities, (3) promoting interoperability, and (4) cost. Below I summarize the report including background on the MIPS program, the results of the GAO evaluation of MIPS scores and bonus payments, and summary of stakeholder feedback.
MIPS PROGRAM BACKGROUND
RESULTS OF GAO MIPS ANALYSIS
How did Medicare physicians fare on the MIPS program? GAO writes:
... MIPS final scores were generally high from 2017 through 2019, with most MIPS-eligible providers qualifying for a positive payment adjustment. Across the 3 years, median final scores ranged from about 89.7 to 99.6 (out of a possible 100)—well above the performance threshold (see fig. 2).26 At least 93 percent of providers qualified for a positive payment adjustment in any year, and no more than 4.8 percent of providers qualified for a negative payment adjustment...
The maximum positive payment adjustment for any of performance years 2017 through 2019 resulted in relatively small increases in Medicare payments. For example, a provider with $90,000 in Medicare Physician Fee Schedule payments would only see an increase of $1,692 in payment year 2019 if they received the maximum positive adjustment of 1.88 percent based on their performance in 2017.
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STAKEHOLDER FEEDBACK
Unsurprisingly, provider groups welcomed more flexibility. For instance, some provider groups received exemptions from reporting along certain dimensions (e.g., radiologists and pathologists did not have to report "promoting interoperability"). Smaller provider groups also appreciated the "small practice bonus" and the low volume threshold which exempted the smallest providers from MIPS participation.
Key critiques include: that feedback was not timely or meaningful to many providers.
MIPS VALUE PATHWAY (MVP)
To address some challenges, CMS's 2022 proposed rule plans to implement the MIPS Value Pathway (MVP) in performance year 2023.
If the rule is finalized as proposed, MVPs will allow providers the option of reporting on a group of activities and measures from the four MIPS performance categories that are relevant to a specific specialty, medical condition, or episode of care.39 Under the proposal, in 2023, providers may register to report data and receive feedback on one of seven MVPs related to the following clinical topics: (1) anesthesia, (2) chronic disease management, (3) emergency medicine, (4) heart disease, (5) lower extremity joint repair, (6) rheumatology, and (7) stroke
In addition, CMS proposes to allow subgroup reporting for MVPs..[which] would allow a specialty within a large multi-specialty group to register as a subgroup and receive more clinically meaningful feedback on its measures and activities in the quality, improvement activities, and cost performance categories.
The MVP framework would also standardize performance measurement across selected specialties, medical conditions, or episodes of care. A more cohesive set of measures can help reduce the amount of "gaming" the system that providers can do.
Originally posted at Healthcare Economist.
The views expressed herein are those of the author and not necessarily the views of?FTI Consulting, Inc., its management, its subsidiaries, its affiliates, or its other professionals.