March 29, 2018

MedPAC Recommends Alternative to Medicare MIPS

In its March 2018 Report to the Congress, the Medicare Payment Advisory Commission (MedPAC) recommended eliminating the Merit-based Incentive Payment System (MIPS), one of two programs – along with Advanced Alternative Payment Models (AAPMs) – instituted under the Quality Payment Program (QPP) and authorized as part of the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).

With this proposal, MedPAC also advised Congress to leave intact the AAPMs system and the other components of MACRA.

The primary driver for MedPAC’s recommendation was the commission’s concern that MIPS will fail to achieve its primary goals of increasing payments for high-value clinicians, reducing payments for low-value clinicians and improving clinical practice patterns.

In place of MIPS, MedPAC recommended consideration of a voluntary value program (VVP), a value-based payment alteration of the traditional fee-for-service reimbursement model that would be structured around the measurement of providers in “meaningful groups” using claims and survey data.

In the report, MedPAC illustrated the following key aspects of the current structure of MIPS that may limit its potential success:

  • Repeating unsuccessful methods of prior Medicare value-based purchasing programs;
  • Using an inequitable quality measurement system with limited clinical relevance and the potential to punish providers for clinically meaningless score differences;
  • Undue flexibility and incentives for clinicians to report measures of performance that reflect the existing strengths of their practices rather than measures that could lead to actual quality improvement;
  • Failure to measure the combined efforts of providers to improve patient outcomes;
  • Exempts for more clinicians than will participate, and 
  • Imposes of significant cost and time reporting burden on clinicians.

While MedPAC acknowledged that substantial resources have already been invested into MIPS, the commission recommended eliminating the program now because of the perceived high probability of future failure, a perspective akin to the economic principle of sunk costs, which refers to business costs that have been incurred and cannot be recovered.

MedPAC recommended a VVP that would measure as well as reward or penalize meaningful, self-organized groups of providers to align their incentives to increase quality. MedPAC envisions the VVP would involve fewer risks and rewards than AAPMs but would get clinicians accustomed to being measured in groups to promote their later transition to AAPMs. The VVP approach would use claims and survey data to eliminate the reporting burden associated with MIPS and would allow modifications of the measures, scoring or payment adjustment calculations without requiring clinicians to alter their reporting process.