The discussion arose in response to concerns that some physicians cannot access Advanced Alternative Payment Models (A-APMs), which are key to the MIPS program. The commission considered ways to repeal MIPS and either replace it with a population-based "voluntary value program" or by substantially changing the rules applied to A-APMs.
The MIPS program adjusts Medicare Physician Fee Schedule (MPFS) payments up or down based on clinician performance, using Medicare quality and electronic health record program measures, according to MedPAC. The measures are "quality," "advancing care information," "clinical practice improvement activities," and "cost."
But the MIPS program is too burdensome for clinicians, MedPAC presenters Kate Bloniarz and David Glass said. The U.S. Centers for Medicare and Medicaid Services (CMS) estimated that it will cost over $1 billion to meet MIPS reporting requirements this year. In addition, MIPS is extremely complex and its measures aren't necessarily associated with high-value care, according to Bloniarz and Glass.
"MIPS is structured to maximize clinician scores, which leads to score compression and a limited ability to detect performance," they said. "Clinicians can choose their own measures, thus the resulting MIPS score is inequitable across clinicians."
MIPS will not achieve the goal of identifying and rewarding high-value physicians, according to Bloniarz and Glass. But there should be a value component in the MPFS framework. As such, an alternative to MIPS could consist of a new voluntary value program in which all clinicians would have a portion of fee schedule payments withheld (for example, 2%). Physicians could elect to be measured with a sufficiently large group of clinicians and be eligible for value payment, elect to join an advanced APM and receive withheld funds, or make no election and lose the withheld funds.
"Entities would be collectively measured on population-based measures that assess clinical quality, patient experience, and value," Bloniarz and Glass said.
Commissioners discussed whether a voluntary value program policy would be viable, according to the American College of Radiology (ACR). Many expressed concern that a 2% withhold wouldn't be a sufficient incentive, and they questioned not only whether clinicians could meet the population-based measures, but also whether some physicians might get left behind, the ACR said.
MedPAC plans to review draft recommendations for the MIPS repeal and policy alternatives at its December meeting; it will vote on recommendations at its January 2018 meeting for inclusion in its March 2018 report to Congress.
"CMS will start making MIPS adjustments in 2019," Bloniarz and Glass said. "Therefore action is needed now."
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