Posted on July 22, 2021
A timeframe to gradually implement the new MIPS Value Pathways (MVPs) program was recently released as part of the Proposed Rule for the 2022 Medicare Physician Fee Schedule (PFS). The proposal would 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 proposes to gradually introduce MVPs beginning with the 2023 performance year so clinicians have time to prepare for the new reporting requirements. Under the Proposed Rule, MVPs would be voluntary for the 2023-2027 performance years but could become mandatory beginning with the 2028 performance year. CMS is considering phasing out the traditional MIPS program after 2027 as outlined in their proposed timeline below.
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 has proposed seven MVPs for the 2023 performance year:
- Stroke Care and Prevention
- Heart Disease
- Chronic Disease Management
- Emergency Medicine
- Lower Extremity Joint Repair
Who Can Report MVPs?
CMS would make MVPs available for certain MVP participants as outlined in the table below.
|Proposed MVP Participation Options|
|2023 and 2024 performance years|
- Individual clinicians
- Single specialty groups
- Multispecialty groups*
- APM Entities
|2025 performance year and for future years|
- Individual clinicians
- Single specialty groups
- APM Entities
*Multispecialty groups would be required to report as subgroups in order to report MVPs beginning in 2025.
What is the MVP Registration Process?
Clinicians reporting MVPs would 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 would need to complete registration by June 30th to align with the CAHPS for MIPS registration deadline.
MVP Participants would 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 would 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 would 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 proposed MVP framework, clinicians would report on measures and activities that reflect an episode of care or clinical condition. The MVP would incorporate a foundational layer consisting of Promoting Interoperability and administrative claims-based quality measures focused on population health. Additionally, each MVP would 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 (finalized in CY 2021 PFS final rule)
• Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions (proposed)
What is Subgroup Reporting?
CMS is proposing to establish “subgroup” reporting which would be voluntary for the 2023 and 2024 performance years. According to the proposed rule, multispecialty groups would be required to report as subgroups in order to report MVPs beginning in 2025.
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).
Subgroups would consist of a subset of a group that contains at least one MIPS eligible clinician and is identified by a combination of the group Tax Identification Number (TIN), the subgroup identifier, and each eligible clinician’s NPI. Subgroups would have the same eligibility and special status determinations of the affiliated group (identified by TIN). CMS would 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).
How are MVPs Scored?
CMS proposes that the scoring for the MVPs would generally align with the traditional MIPS program. Performance category weights would be consistent with traditional MIPS performance category weights. The reweighting policies would also align with traditional MIPS, except that CMS would 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 proposed MVP reporting framework would overhaul the existing MIPS reporting requirements. CMS intends to transition to MVPs beginning with voluntary reporting in 2023. While many of the MVP details are only proposed at this time, clinicians should become familiar with the provisions to ensure a smooth transition in the years ahead.
MACRA MIPS MVPs 2022 Proposed QPP Rule