As it is currently designed, MIPS doesn't clearly identify high- or low-value clinicians and is therefore of limited benefit to Medicare patients, according to the June report. MedPAC's concerns about MIPS include the following:
- Clinicians will be assessed on noncomparable measures. "A clinician's relative performance on each measure is compared with the performance of others who reported the same measure," MedPAC wrote. "Many of these measures are poorly linked to outcomes of importance for beneficiaries and the program and, instead, reinforce the incentive in fee-for-service Medicare to provide more services than are clinically necessary."
- Individual clinicians tend to have small numbers of patients who qualify for each measure. "Reliably measuring performance is also a concern," the commission wrote. "For many clinicians, any individual quality measure will apply only for a subset of their patients. That number may be too small to distinguish real differences in performance."
- Small differences in clinician performance could result in large payment differences. "In future years (when the MIPS benchmark is set at the median or mean of performance), small variations in quality measures can have an outsize effect on the MIPS composite score, even if the differences in quality performance among clinicians are clinically insignificant," MedPAC wrote.
The commission suggested a possible redesign of the program based not on clinician measures but on population outcome measures such as preventable admissions and emergency department visits, mortality, and readmissions, as well as patient experience and rates of low-value care. The measures would be calculated from claims or surveys, which would reduce clinicians' reporting burden, according to MedPAC.
"Under this construct, clinicians would need to be associated with a group ... and there would be no individual-level assessment of clinician performance, only group-level assessment," the commission wrote.
MedPAC also offered an overview of the medical device industry, standalone emergency departments, and the role of the Medicare program in the consolidation of the healthcare industry, including provider and insurer functions by accountable care organizations (ACOs) or Medicare Advantage plans.
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