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CMS’ new MVPs: Punishment or Prize?

Thursday, February 6, 2020   (0 Comments)
Posted by: Kasia Januszewski
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CMS’ new MVPs: Punishment or Prize?

Published February 6, 2020 on LinkedIn.com

Increased clinician burden, inadequate guidance and specialty customization, and potentially lower quality scores are top concerns with CMS’ upcoming MIPS Value Pathways program (MVPs)

Here’s some tips on getting ready

On January 1, 2021, big changes are coming for the Merit-based Incentive Payment Program (MIPS). That’s when the federal Centers for Medicare & Medicaid Services (CMS) will implement the new MIPS Value Pathways program, also known as MVPs.

According to CMS, MVPs are intended to help better coordinate quality measures, improvement activities and interoperability efforts, and promote their alignment systemwide. CMS will accomplish this by aligning specialty-specific clinical quality measures with standardized cost and population health measures. And, yes, over time participation will be mandatory for clinicians to earn bonuses outside Alternative Payment Models (APMs).

CMS says MVPs also should reduce clinician compliance burden by reducing the number and variety of measures collected. It is also supposed to give clinicians better information for performance improvement, particularly related to overall costs and broad population health goals.

But, as always, the devil is in the details. At least initially, MVPs will challenge many users due to structural flaws it brings forward from previous quality payment schemes, as well as a lack of clear guidance on how the new composite measures should be developed and tested.

Indeed, in our exclusive survey of organizations affected, nearly 80 percent said they are concerned or very concerned about the impact MVP will have on their members. More than 60 percent said they are undecided about whether their clinicians will report using MVPs, while another 30 percent said they were unlikely or definitely would not use MVPs.

That leaves just eight percent of respondents saying they are likely to participate in MVPs – as compared with MIPS, which currently claims 98 percent participation among eligible clinicians.

Survey says…

So why are so many users so leery of MVPs? While concerns vary widely, our MVP survey identified several common themes:

  • Increased clinician burden affecting patient care. “[T]his dramatic change to the MIPS program will actually increase burden on providers and staff, by requiring them to understand and implement yet another reporting methodology which will require provider and staff time, changes in workflow and possible upgrades to their electronic health records system. As a result, time devoted to patient care is further reduced,” a “somewhat concerned” respondent said.
  • Lack of existing clinically relevant MIPS measures for many specialties and sub-specialties. As one “concerned” respondent put it, “CMS is asking stakeholders to reorganize the quality participation model with the same flawed building blocks.” Another “concerned” respondent noted, there is “no relevant pathway for our field.” Given that CMS will also require measures to be fully tested before implementation, a lack of “tested performance measures and cost measures and the lack of guidance on how to do these cross-specialty” is of particular concern.
  • Less flexibility to match measures to actual clinical circumstances. According to one “very concerned” respondent, a “one-size fits all approach will not improve quality or reduce costs. … performance scores on Physician Compare derived from flawed data/unfair program tarnishes physician reputations; etc.” It also is likely to cost clinicians money, another “concerned” respondent said. “MVPs are like the existing quality specialty measure sets on steroids. Specialty measure sets rarely earn [clinicians] the best score.”
  • Insufficient guidance from CMS on developing and testing MVP pathways and measures. Typical responses from respondents noted a “complete lack of information or clarity from CMS,” as well as “not much detail on how the program will work. How do providers choose a pathway?,” and “rolling out the policy without having fully baked development and scoring engines … in place [continues] siloed situations that are already an issue.”
  • Applying untested population health and cost measures to specialty practices. “Many of the existing administrative claims measures have not been tested at the physician level and are based on retrospective analysis of claims and do not provide granular enough information for physicians to make improvements in practice,” a “somewhat concerned” respondent pointed out. Others noted that population health measures may disadvantage providers in some communities, and, because they are largely focused on primary care, may not be appropriate for assessing some specialties.

Overall, these changes, along with other pending MIPS changes, may significantly discourage participation. “CMS’ proposal … to remove a large percentage of the existing quality measures and remove measures after only after two years in the program may cause stakeholders to determine it is not worth their time to develop MVPs if they will soon be removed,” a respondent said.

How PCPI can help

With just 11 months left before implementation begins, the majority of respondents were still early in their efforts to address MVP. As of February 4, just over one-quarter reported they had not started preparing while another 60 percent said they had. Just 12 percent considered themselves well prepared.

As a national leader in developing and implementing clinician-level quality measures and quality improvement programs, many see PCPI as a valuable resource. Nearly 44 percent saw advocacy as the most important way PCPI can help. Another 20 percent cited education while help with measures and pilot testing were named by 13 percent with many organizations stating that PCPI’s expertise across all these domains would be key in the implementation of MVPs.

“These results reflect PCPI’s role as a leading stakeholder convener with deep regulatory knowledge, contacts and compliance experience, and renewed focus on advocacy,” said PCPI Chief Scientific Officer and Vice President Marjorie Rallins, DPM. “We work hand-in-hand with our members, other interested parties and CMS throughout the regulatory process to help ensure all sides understand each other so quality systems can do their most important job – improve patient care and health outcomes.”

At a February 4 PCPI Webinar, Dr. Rallins and other PCPI staff outlined a couple of steps organizations can take to smooth the transition to MVPs:

  • Talk to CMS. “While the agency will develop MVPs with or without input from specialties, regulators have expressed openness to clarifying conceptual approaches and development issues as they relate to specific circumstances,” Dr. Rallins said. In particular, CMS may be willing to help think through how pathways might be applied by specialty, care domain or from a continuum of care perspective. This should help dispel some of the confusion around what, exactly, MVPs can and should look like. CMS may also be able to clarify what organizations must do to pass the required pre-implementation audit of any proposed MVP pathway in specific circumstances.
  • Let PCPI help. PCPI is a leading expert and thought leader in performance and quality measurement. Last year PCPI submitted 15 measures to NQF for endorsement including nine registry and two Qualified Clinical Data Registry (QCDR) measures, maintaining PCPI’s longstanding position as the single most experienced clinician-level measure developer.  PCPI has built its advocacy program on the foundation of being the premier convener of measure developers and registries.  We aim to work with you to connect the disparate pieces of MIPS to create a cohesive program that works for measure developers and stewards instead of against them.

Beyond helping individual stakeholders develop MVPs, PCPI also has an important role in coordinating development efforts across specialties and sub-specialties – a central overall goal of the MVP program that just 17 percent of respondents reported undertaking. PCPI also plans to help stakeholders and CMS pilot MVPs, and monitor their ongoing performance.

Still, meeting CMS’ ambitious timeline for MVP implementation will be a huge challenge, especially given the paucity of specific guidance. In the coming months PCPI plans to listen and learn from stakeholder and CMS experience, and spread learnings and best practices as broadly as possible.

We hope you’ll stay with us on this knowledge journey. Next up is a February 26 PCPI webinar on Registry Diversification, and the April 28 PCPI/AMA QCDR Conference. And check this space for additional MVP programming.

Together we can help make achieving MVP status an accomplishment to prize rather than a punishment to endure.


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