MedPAC Suggests Redesigning MIPS Reporting

On June 15th, The Medicare Payment Advisory Commission (MedPAC) submitted its annual June Report to Congress. MedPAC is a non-partisan, independent Congressional body that is tasked with evaluating the Medicare program and making recommendations to Congress on Medicare payment policy. MedPAC’s scope covers all Medicare payment systems.

The June 2017 report included a particularly noteworthy chapter titled “Redesigning the Merit-based Incentive Payment System and strengthening advanced alternative payment models.” Although the chapter does not include any formal recommendations, the Commission puts forward suggestions for a radically different approach to implementing the new Medicare Quality Payment Program (QPP).

The QPP replaced the Medicare Sustainable Growth Rate (SGR) formula for calculating annual updates to Medicare Physician Fee Schedule (MPFS) payments. The QPP creates two participation options, the Merit based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APM). Under MIPS, eligible clinicians (EC) report data under four performance categories: quality, cost, practice improvement, and electronic health record use. MIPS applies positive, negative or neutral payment adjustments based on a clinicians total score across all categories.

ECs can be exempt from MIPS reporting if they qualify as a participant in an Advanced APM. ECs can also earn bonus payments for participation in an Advanced APM and are subject to potential financial risk/rewards under the design of the model.

In general, MedPAC is critical of the reporting structure of MIPS. MedPAC thinks the reporting measures are overly complex, overly burdensome and will not actually be useful in determining which clinicians are high- or low-performing clinicians. For example, many quality measures are either topped-out or undeveloped in that they lack a performance benchmark. MedPAC criticizes MIPS as another pay for reporting program rather than a program that effectively rewards or penalizes clinicians for the quality and efficiency of care they provide.

MedPAC puts forth several proposals for how to strengthen the incentives of MIPS. One proposal is to automatically withhold some fee-for-service (FFS) payments to eligible clinicians. This money would fund a “quality pool.” ECs can participate in MIPS or Advanced APMs to earn some or all of the withhold back plus the possibility of additional quality incentive payments. ECs who do nothing would lose the withheld money.

Another proposal is to eliminate all of the reporting requirements for ECs under MIPS. Instead, ECs would report data on broader population health measures automatically through claims and through surveys. While this would greatly reduce a practice’s administrative burden, MedPAC acknowledges that population health measures are not yet reliable on an individual clinician level. MedPAC proposes to assess performance and adjust payment based on performance at a group or local area level. MedPAC believes this will help “counter the silo-driven FFS system that encourages providers to focus only on the service they provide.”

Examples of population outcome measures MedPAC has in mind include:

  • Potentially preventable admissions and emergency department visits
  • Mortality and readmission rates
  • Patient experience
  • Healthy days at home
  • Rates of low-value care
  • Relative resource uses

MEDPAC also includes suggestions to expedite the transition from MIPS participation to Advanced APM participation. MedPAC does not like how ECs can earn a five percent bonus just for participating in Advanced APM. MedPAC wants this bonus to actually be tied to performance in some way. It also wants to change how ECs qualify for the bonus from a percentage of MPFS revenue to a percentage of total revenue. MedPAC also wants a less restrictive definition of Advanced APMs to make this option more available to ECs.

Again, MedPAC is not making a formal recommendation (i.e. not endorsing any particular option). MedPAC will continue to examine the details of implementing the options and potentially make formal recommendations in a future report to Congress. Congress is not required to adopt MedPAC recommendations but it will certainly be interesting to see if Congress takes any of these suggestions into consideration.

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

Best regards,
Kirk Reinitz, CPA