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 16 MVPs available for 2024. This includes five new MVPs for the 2024 performance year:
- Focusing on Women’s Health (MVP ID: M1366)
- Quality Care for the Treatment of Ear, Nose, and Throat Disorders (MVP ID: M1367)
- Prevention and Treatment of Infectious Disorders Including Hepatitis C and HIV (MVP ID: M1368)
- Quality Care in Mental Health and Substance Use Disorders (MVP ID: M1369)
- Rehabilitative Support for Musculoskeletal Care (MVP ID: M1370)
Modifications are also made to the previously finalized MVPs*:
- Adopting Best Practices and Promoting Patient Safety within Emergency Medicine (MVP ID: G0057)
- Advancing Cancer Care (MVP ID: M0001)
- Advancing Care for Heart Disease (MVP ID: G0055)
- Advancing Rheumatology Patient Care (MVP ID: G0053)
- Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes (MVP ID: G0054)
- Improving Care for Lower Extremity Joint Repair (MVP ID: G0058)
- Optimal Care for Kidney Health (MVP ID: M0002)
- Optimal Care for Patients with Episodic Neurological Conditions (MVP ID: M0003)
- Patient Safety and Support of Positive Experiences with Anesthesia (MVP ID: G0059)
- Value in Primary Care (MVP ID: M0005)
- Supportive Care for Neurodegenerative Conditions (MVP ID: M0004)
*The Promoting Wellness MVP and the Optimizing Chronic Disease Management MVP are combined into one MVP called Value in Primary Care.
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 |
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| 2026 performance year and for future years |
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*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 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.
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.
Participants will not be able to make changes to the MVP they select after the close of the registration period on November 30th.
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 Category | Improvement Activities Category | Cost 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 | MVP participant selects: -Two medium-weighted | CMS will calculate performance exclusively on the cost measures that are included in the MVP using administrative claims data. |
| Foundational Layer | ||
Population Health Measures*
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*There are two population health measures available for selection for the 2024 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.
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