Posted on July 22, 2021
A timeframe to gradually implement the new MIPS Value Pathways (MVPs) program was recently released as part of the Final Rule for the 2022 Medicare Physician Fee Schedule (PFS). The Rule will allow clinicians to report MVPs beginning with the 2023 MIPS performance year. 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 will mark a significant shift in how clinicians report under the program. CMS points out that the new reporting framework 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 will gradually introduce MVPs beginning with the 2023 performance year so clinicians have time to prepare for the new reporting requirements. Under the Final Rule, MVPs will be voluntary for the 2023-2027 performance years. CMS previously indicated it is considering making MVPs mandatory in 2028 and sunsetting the traditional MIPS program at that time. However, it did not establish a timeframe for this in the Final Rule.
What are the MVPs?
MVPs are intended to align and connect measures and activities across all of the MIPS performance categories (Quality, Cost, Promoting Interoperability, and Improvement Activities) for different specialties or conditions. CMS finalized seven MVPs for the 2023 performance year:
Who Can Report MVPs?
CMS makes MVPs available for certain MVP participants as outlined in the table below.
|MVP Participation Options|
|2023 to 2025 performance years|
- Individual clinicians
- Single specialty groups
- Multispecialty groups*
- APM Entities
|2026 performance year and for future years|
- Individual clinicians
- Single specialty groups
- APM Entities
*Multispecialty groups are required to form subgroups in order to report MVPs beginning in 2026.
What is the MVP Registration Process?
Clinicians reporting MVPs will have to register with CMS as MVP participants between April 1st and November 30th of the performance year. 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 they intend to report.
- One population health measure included in the MVP.
- An outcomes-based administrative claims measure on which the MVP Participant intends to be scored, if available within the MVP.
Clinicians participating as a subgroup will be required to:
- Identify the MVP the subgroup will report (including one population health measure included in the MVP and any outcomes-based administrative claims measure on which the subgroup intends to be scored, if available).
- Identify the clinicians in the subgroup by Taxpayer Identification Number (TIN) / National Provider Identifier (NPI).
- Provide a plain language name for the subgroup for purposes of public reporting.
Participants will not be able to make changes to the MVP they select after the close of the registration period.
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.
*CMS anticipates there will be 2 population health measures available for selection for the 2023 performance year:
• Hospital-Wide, 30-day, All-Cause Unplanned Readmission (HWR) Rate for the MIPS Eligible Clinician Groups
• Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions
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.
Subgroups will 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).
To generate more clinically relevant and granular information about clinician performance, CMS believes that subgroups should be assessed using subgroup level data to the extent that it is operationally feasible. CMS anticipates more granular data would be available for patients, clinicians, and other stakeholders through a three-pronged approach of mandatory subgroup reporting, broad use of FHIR APIs, and the creation and use of digital quality measures (dQMs).
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.
The MVP reporting framework will overhaul the existing MIPS reporting requirements. CMS intends to transition to MVPs beginning with voluntary reporting in 2023 to provide practices the time they need to review requirements and update workflows and systems as needed to report MVPs. Clinicians should become familiar with the provisions to ensure a smooth transition in the years ahead.
MACRA MIPS MVPs 2022 Proposed QPP Rule