MIPS Value Pathways (MVPs) - The Future of MIPS

Posted on November 18, 2024
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The MIPS Value Pathways (MVPs) is a new reporting structure available for the Merit-based Incentive Payment System (MIPS).  The MVP framework is intended to ease the reporting burden on clinicians and groups by aligning measures and activities across the Quality, Cost, and Improvement Activities categories of MIPS that are more relevant to a clinician’s scope of practice. This article answers key questions about MVPs and how MIPS reporting is expected to change in the years ahead.  

The Next Evolution of MIPS

The Centers for Medicare and Medicaid Services (CMS) originally established the Merit-Based Incentive System (MIPS) program in 2017 as one of two tracks under the Quality Payment Program to move Medicare Part B clinicians to a value-based payment system. While MIPS has gone through incremental changes since its inception, MVPs mark a significant shift in how clinicians report under the program. CMS points out that the new reporting approach is aimed at moving away from siloed reporting of measures and activities towards focused sets of measures and activities that are more meaningful to a clinician’s practice, specialty, or public health priority.  

The MVP Transition Timeline

CMS introduced MVPs during the 2023 performance year. MVPs will be voluntary for the 2023-2027 performance years, but CMS is considering making them mandatory in 2028 and sunsetting the traditional MIPS program at that time. 

What are MVPs?

MVPs are composed of Quality measures (including one outcome measure [or high-priority measure if an outcome measure is not applicable]), Improvement Activities, and Cost measures relevant to the condition, specialty, or patient population. MVPs also include a foundational layer made up of population health measures and the Promoting Interoperability performance category measures. 

There are 21 MVPs available for the 2025 performance year. This includes six new MVPs related to ophthalmology, dermatology, gastroenterology, pulmonology, urology, and surgical care. There are also limited modifications to the previously finalized MVPs, including the consolidation of two neurology-focused MVPs into a single neurological MVP.

*The Optimal Care for Patients with Episodic Neurological Conditions and the Supportive Care for Neurodegenerative Conditions MVPs have been combined into a single consolidated neurological MVP titled Quality Care for Patients with Neurological Conditions.

CMS plans to expand MVPs to include more specialties and subspecialties that participate in MIPS in future years.

Who Can Report MVPs?

MVPs can be reported by the following list of participants:

MVP Participation Options
2023 to 2025 performance years
  • Individual clinicians
  • Single specialty groups
  • Multispecialty groups*
  • Subgroups
  • APM Entities
2026 performance year and for future years
  • Individual clinicians
  • Single specialty groups
  • Subgroups
  • APM Entities

*Multispecialty groups will be required to form subgroups in order to report MVPs beginning in 2026.

Medicare Part B claims will be used for determining specialty type. A single-specialty group is defined as a group that consists of one specialty type as determined by CMS using Medicare Part B claims, and a multispecialty group as a group that consists of 2 or more specialty types as determined by CMS using Medicare Part B claims.

What is the MVP Registration Process?

Individuals, groups, and APM entities reporting MVPs will have to register with CMS as MVP participants between April 1st and December 1st, 2025. Groups, subgroups, or APM entities that plan to report the CAHPS for MIPS survey will have to complete their registration by June 30th to align with the CAHPS for MIPS registration deadline. 

MVP Participants will select the following at the time of registration:

  • The MVP you plan to report.
  • Whether you plan to administer the Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey, if it’s a quality measure option in your selected MVP.
  • Whether you want to be evaluated on an outcomes-based administrative claims quality measure, if it is a quality measure option in your selected MVP.
  • The participation option you plan to use: individual, group, subgroup, or APM Entity.

At the time of registration, clinicians will also select if they want to submit as a subgroup.  In addition to the required MVP registration information outlined above, the subgroup registration must also include:

  • A list of Taxpayer Identification Numbers (TINs)/National Provider Identifiers (NPIs) in the subgroup;
  • A plain language name for the subgroup (which will be used for public reporting);
  • A description of the composition of the subgroup, which may be selected from a list or described in a narrative.

MVP Participants can make changes to an MVP registration throughout the registration window until it closes on December 1, 2025, but can’t change the CAHPS for MIPS Survey registration after June 30, 2025. 

Beginning with the 2025 performance year, clinicians will no longer be required to select a population health measure during the MVP registration. 

What is Subgroup Reporting?

Subgroups will consist of a subset of a group that contains at least one MIPS eligible clinician and is identified by a combination of the group TIN, the subgroup identifier, and each eligible clinician’s NPI. CMS is limiting subgroup reporting only to clinicians reporting through MVPs or APM Performance Pathway (APP). Subgroup reporting will be voluntary for the 2023, 2024, and 2025 performance years. Multispecialty groups will be required to form subgroups in order to report MVPs beginning in 2026. 

CMS is using the initial 12-month segment of the 24-month MIPS determination period to determine the eligibility of clinicians intending to participate and register as a subgroup. Subgroups would have the same eligibility and special status determinations of the affiliated group (identified by TIN). CMS will not allow voluntary reporters, opt-in eligible clinicians, and virtual groups to report MVPs for the 2023 performance year due to implementation challenges. To participate as a subgroup, the TIN would have to exceed the low-volume threshold at the group level (subgroups wouldn’t be evaluated for the low-volume threshold at the subgroup level). 

What are the MVP Reporting Requirements?

Under the MVP framework, clinicians will report on measures and activities that reflect an episode of care or clinical condition. The MVP will incorporate a foundational layer consisting of Promoting Interoperability and administrative claims-based quality measures focused on population health. Additionally, each MVP will include clinically relevant measures and activities for the Quality, Improvement Activities, and Cost categories.

MVP Reporting Requirements
Quality CategoryImprovement Activities CategoryCost Category

MVP participant selects 4 quality measures (1 must be an outcome or a high priority measure).

*If applicable, an administrative claims measure that is outcome-based may be
selected to meet the outcome measure requirement.
 

MVP participants must attest to:

-1 Improvement Activity from those available within the selected MVP;* Or
-Participation in a certified or recognized patient-centered medical home (PCMH) or comparable specialty practice.

*Improvement activities no longer have assigned weights.

CMS will calculate performance exclusively on the cost measures that are 
included in the MVP using administrative claims data. 

Foundational Layer
Population Health Measures*
  • CMS will calculate both population health measures (if the clinician meets the case minimum) and assign the higher of these measures to the clinician's Quality score. If neither of the population health measures can be calculated, they will be excluded from scoring.
Promoting Interoperability (PI) Performance Category
  • MVP participants will report on the same PI measures required under traditional MIPS unless they qualified for automatic reweighting or had an approved hardship exception.

*There are two population health measures available for selection for the 2025 performance year:

  • Q479: Hospital-Wide, 30-day, All-Cause Unplanned Readmission (HWR) Rate for the MIPS Eligible Clinician Groups
  • Q484: Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions  

How are MVPs Scored?

Scoring for the MVPs will generally align with the traditional MIPS program. Performance category weights will be consistent with traditional MIPS performance category weights. The reweighting policies will also align with traditional MIPS, except that CMS will not reweight the Quality category if they cannot calculate a score for the MIPS eligible clinician because there isn’t at least one quality measure applicable to the clinician.

Subgroup Scoring

CMS will calculate and score administrative claims measures at the TIN level, not at the subgroup level:

  • Foundational Layer (MVP Agnostic) - For each selected population health measure in an MVP, subgroups would be assigned the affiliated group’s score, if available. In instances where a group score is not available, each such measure would be excluded from the subgroup’s final score.
  • Quality Performance Category - For each selected outcomes-based administrative claims measure in an MVP, subgroups would be assigned the affiliated group’s score, if available. In instances where a group score is not available, each such measure would be assigned a zero score.
  • Cost Performance Category -  Subgroups would be assigned the affiliated group’s cost score, if available for the cost performance category in an MVP. In instances where a group score is not available, each such measure would be excluded from the subgroup’s final score.

CMS will not assign a score for a subgroup that registers but does not submit data as a subgroup.

Next Steps

MVPs are a new optional way to meet MIPS reporting requirements. The new MVP framework is intended to allow MVP participants to report on a smaller subset of measures and activities (within the measures and activities available for traditional MIPS) that are relevant to a specialty, clinical condition, or episode of care.  Contact us today if you are interested in reporting a MVP in 2024.
 


 

MACRA MIPS MVPs 2022 Proposed QPP Rule

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