By Georgina Perry, CPA, CMPE
CMS has offered some form of “pay for reporting” and value based incentive to medical providers for many years. Ten years ago, providers were juggling requirements, reviewing hundreds of measure details and weighing submission options for PQRS, MU, VBM and eRx. Currently, the relevant portions of past programs have been combined into what is currently known as the Quality Payment Program (QPP). CMS has stated they aim to reduce reporting burdens and to make data collection more meaningful to participants. In an effort to reach those goals, programs continue to evolve. The most recent evolution being the MIPS Value Pathways (MVP).
Beginning with the 2023 performance year, MVP is the newest reporting option within the Merit-based Incentive Payment System of the QPP. Each MVP is focused on a specific medical condition or specialty. Providers may participate as individuals, groups (ie. Report under the same tax id), APM Entity or subgroup (ie. A subset of providers within one practice reporting collectively on the same MVP). The subgroup will be required for multispecialty practices reporting via MVP beginning in 2026 performance year. The timeline for sun setting traditional MIPS has not been finalized but will occur sometime in the future.
MVP require fewer quality measures and improvement activities than traditional MIPS. However, the full promoting interoperability measure set as in traditional MIPS will be required in MVP. CMS will continue to collect and calculate the cost performance and population health measures.
Pre-registration is required for reporting MVP. For 2023, the registration period is April 3, 2023 through November 30, 2023. Changes may be made to the registration through November 30, 2023. The pre-registration requires participants to declare they will report as individual, group, subgroup or APM Entity. MVP participants will also need to select the MVP and population health measure during pre-registration.
Currently, the following 12 MVPs and suggested aligned specialty are approved for 2023:
- Adopting Best Practice and Promoting Patient Safety within Emergency Medicine – Emergency Medicine
- Advancing Cancer Care – Oncology, Hematology
- Advancing Care for Heart Disease – Cardiology, Internal Medicine, Family Medicine
- Advancing Rheumatology Patient Care – Rheumatology
- Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes – Neurology, Neurosurgical, Vascular Surgery
- Improving Care for Lower Extremity Joint Repair – Orthopedic Surgery
- Optimal Care for Kidney Health – Nephrology
- Optimal Care for Patients with Episodic Neurological Conditions – Neurology
- Optimizing Chronic Disease Management – Cardiology, Internal Medicine, Family Medicine
- Patient Safety and Support of Positive Experiences with Anesthesia – Anesthesiology
- Promoting Wellness – Preventative Medicine, Internal Medicine, Family Medicine and Geriatrics
- Supportive Care for Neurodegenerative Conditions - Neurology
The MVP under consideration for 2024 are in the areas of women’s health, otolaryngology, prevention and treatment of infectious disorders, musculoskeletal care, mental health and substance use disorder. The details of the 2024 MVPs have not been finalized yet. To review the details of the 2024 proposed MVP for 2024 go to https://qpp.cms.gov/mips/candidate-feedback.
Georgina Perry is the Director of Physician Services for Carr, Riggs & Ingram. She provides operational consulting to small to medium-sized medical practices of any specialization.