MIPS & MVPs: Moving Forward - Part 2

In the 1st part of this blog, we learned why MIPs are essential and when and how the system will be updated to MVP in 2023.

The transition from the current data management platform to the new one will occur over time, with the final implementation scheduled for 2028.

Starting anew, let's continue where we closed the discussion last time and further learn who will be able to participate in the program.

The following individuals are eligible to submit MVP reports:

How does one sign up to be a part of MVP?

Between April 1st and November 30th of the performance year, individuals, organizations, and APM entities reporting MVPs must register with CMS as MVP participants.

To comply with the CAHPS for MIPS registration deadline of June 30th, every organization, sub-organization, or APM entity planning to report the CAHPS for MIPS survey must register by that date.

At the time of signup, MVP participants will choose from the following options:

• The key reason they want to report.
• One measure of population health is part of the MVP.
• An administrative claims measure based on results that the MVP Participant wants to be graded on if it is available in the MVP.

Clinicians will also choose whether or not they want to submit as a subgroup when they sign up.

In addition to the information about the MVP that must be included in the registration, the subgroup registration must also include the following:

• A list of Taxpayer Identification Numbers (TINs) or National Provider Identifiers (NPIs) in the subgroup;
• A name for the subgroup that is easy to understand (this will be used in public reports);
• A description of who is in the subgroup. This can be chosen from a list or written out in a story.

Following the end of the registration period on November 30th, participants will not be able to alter their MVP selection.

What exactly does "subgroup reporting" mean when referring to a report?

By combining the TIN of the parent organization with the subgroup identity and the National Provider Identifier (NPI) of each MIPS-eligible physician, subgroups will be created.

CMS restricts subgroup reporting to physicians under the MIPS or APM Performance Pathway (APP) to reduce administrative burden.

Subgroup reporting will be optional for 2023, 2024, and 2025 performance years.

To report MVPs, multispecialty groups will need to establish subgroups starting in 2026.

As a result of implementation issues, CMS will not accept MVP reports from voluntary reporters, opt-in eligible doctors, or virtual groups for the 2023 performance year.

Subgroup participation requires a TIN over the low-volume criterion at the group level (subgroups are not tested against this threshold).

When it comes to MVPs, what are the necessary reporting parameters?

Metrics and actions that are representative of a patient's condition or care episode will be reported by doctors using the MVP framework.

Promoting Interoperability and administrative claims-based quality metrics centered on population health will form the MVP's groundwork layer.

Each MVP will also have clinically-relevant Quality, Improvement Activities, and Cost measurements and tasks.

The scoring system for MVPs.

In general, the scoring for the MVPs will be the same as for the regular MIPS program.

Performance category weights will be the same as they have been in the past with MIPS.

The reweighting policies will also be the same as traditional MIPS, except that CMS will not reweight the Quality category if there isn't at least one quality measure that applies to the MIPS-eligible clinician.

The administration claims measures from CMS will be scored and calculated at the TIN level, not the subgroup level.

• Foundational Layer (MVP Agnostic): For each chosen population health measure in an MVP, the affiliated group's score would be given to each subgroup if available. If there isn't a group score, each of these measures would be taken out of the subgroup's final score.
• Quality Performance Category:?For each selected outcome-based administrative claims measure in an MVP, the affiliated group's score would be given to subgroups if it was available. When there isn't a group score, each measure would be given a score of zero.
• Cost Performance Category:?If there is a cost performance category in an MVP, subgroups will get the cost score of the affiliated group. If there isn't a group score, each of these measures would be taken out of the subgroup's final score.

CMS will not award a score if a subgroup registers but does not submit data as a subgroup.

What's Next?

Starting with the 2023 performance year, MVPs may be used as an alternative to traditional MIPS reporting.?

The new MVP framework is designed to let participants report on the measures and activities most relevant to their specialty, clinical condition, or episode of treatment (within the measures and activities available for standard MIPS).