MedPAC Proposing to Replace MIPS

The Medicare Payment Advisory Commission (MedPAC) is researching a proposal that includes a recommendation to eliminate the Merit-based Incentive Payment System (MIPS) in favor of a value-based payment system that is less administratively burdensome. MedPAC is essentially Congress’s private think tank on Medicare payment policy. It is a nonpartisan agency of Congress that conducts analysis and makes recommendations to Congress on Medicare payment policy.

In addition to its criticism that MIPS is too much of an administrative burden on providers, the Commission does not feel like MIPS measures meaningful quality performance. Specifically, MedPAC says that “MIPS will not achieve [its] goal of identifying and rewarding high-value clinicians, but there should be a value component in Medicare [fee-for-service].”

However, MedPAC is not proposing to completely eliminate value-based payments. It is proposing a replacement system for MIPS that would reduce the number of measures and collect data automatically through claims or through surveys.

Under the MedPAC proposals, all eligible clinicians would have a percentage of their Medicare Physician Fee Schedule (MPFS) payments withheld. The number MedPAC uses to illustrate this system is two percent.

Clinicians would be able to earn back the withheld amount by performing well on the new quality and cost measures or by joining an Advanced Alternative Payment Model (Advanced APM). Clinicians could also earn more than the withheld amount (a bonus) for high performance. This system would not be required to be budget neutral but it would be designed with the intention that budget neutrality is achieved.

To report, clinicians would report on a small number of population health measures that assess clinical quality, patient experience and value. Clinical quality measures could include avoidable readmissions, emergency department utilization or mortality. Patient experience measures could include ability to obtain needed care or ability to communicate concerns to clinician. Value (cost) measures could include spending per beneficiary after a hospitalization, relative resource use or rates of low-value care.

The vast majority of Commissioners have expressed their support for this concept but acknowledge this proposal is still missing many important details. MedPAC is continuing to refine this proposal with the intention of issuing a formal recommendation to Congress in one of its two annual reports to Congress in 2018.

It is no secret that the goal of MedPAC’s recommendations is to drive providers towards APMs. The commissioners have said it themselves on many occasions. Whatever system MedPAC recommends to replace MIPS will likely have a lower incentive (bonus) payment than what providers can earn by participating in an APM.

It is unclear how Congress views this proposal. The Centers for Medicare and Medicaid Services (CMS) does not have the authority to implement this proposal. MIPS was passed under the Medicare Access and CHIP Reauthorization Act of 2015 meaning Congress would have to act to implement this recommendation.

As always, ADVOCATE will keep you up to date on this and all issues impacting radiology as they become available.

Lauren Sloan, MHA, RD, LD
Director of Regulatory Affairs