CMS Proposes New MIPS Framework for 2020

The Centers for Medicare & Medicaid Services (CMS) is proposing major policy changes to the Medicare Physician Fee Schedule and Quality Payment Program, with the overarching goal to further reduce clinician burden.

At the core of the proposed policy changes, the agency announced on July 29, is a desire to improve the Quality Payment Program (QPP) under MACRA (the Medicare Access and CHIP Reauthorization Act of 2015) by streamlining the program’s requirements. The proposal calls for a simpler way for clinicians to participate in CMS’ pay-for-performance program, the Merit-based Incentive Payment System (MIPS), which is one of two payment tracks within the QPP.

This new framework, called the MIPS Value Pathways (MVPs), beginning in the 2021 performance period, would move MIPS from its current state, which requires clinicians to report on many measures across the multiple performance categories, such as Quality, Cost, Promoting Interoperability and Improvement Activities, to a system in which clinicians will report much less, CMS officials contend.

Under MVPs, clinicians would report on a smaller set of measures that are specialty-specific, outcome-based, and more closely aligned to Alternative Payment Models (APMs). MVPs will connect activities and measures from the four existing MIPS performance categories that are relevant to the population they are caring for a specialty or medical condition, according to CMS.

Per the proposal, “MVPs would utilize sets of measures and activities that incorporate a foundation of promoting interoperability and administrative claims-based population health measures and layered with specialty/condition specific clinical quality measures to create both more uniformity and simplicity in measure reporting. The MVP framework will also connect quality, cost, and improvement activities performance categories to drive toward value; integrate the voice of patients; and reduce clinician barriers to movement into Advanced APMs.”

The QPP, which started on Jan. 1, 2017 with a “pick-your-pace” program year—which essentially enabled clinicians to avoid payment penalties as long as they submitted at least the minimum amount of quality data—has since ramped up the requirements for participating clinicians. At the same time, CMS continues to exempt certain clinicians who don’t meet a low-volume Medicare threshold. There doesn’t appear to be any changes to the low-volume threshold for 2020 in the new proposal.

The proposed rule also suggests changes to how the four performance categories will be weighted for performance years 2020 through 2022 (payment years 2022 through 2024), which can be seen in the table below from the proposed document.