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  • The Evolving CMS Policy on MIPS Value Pathways

    This content is excerpted from EyeNet’s MIPS 2022: A Primer and Reference; also see the Academy’s MIPS hub page.

    Since 2017, there have been two ways to participate in Medicare’s Quality Payment Program: 1) via MIPS or 2) as part of an advanced alternative payment model (APM). But in recent years, CMS has made clear that its goal is to sunset “traditional MIPS” and shift clinicians into APMs or into the nascent MIPS value pathways (MVPs). What would that mean for ophthalmologists?

    The CMS rationale for MVPs. When CMS initially designed MIPS, it included hundreds of quality measures and more than 90 improvement activities. The goal was to give clinicians flexibility so they could chart their own individualized route through MIPS. During the years that followed, practices have worked hard to master the nuances of MIPS, and the Academy and other professional associations have developed tools and resources to help their members succeed. Despite this, CMS decided that it needed to overhaul the MIPS rules. The agency worried that the plethora of options was overwhelming for practices and made it hard for payers and patients to compare clinicians’ performance. This is the agency’s rationale for proposing a new framework based around MVPs.

    What is an MVP? MVPs will each have a specific focus, which could be based on a specialty, a medical condition, or a particular population of patients. Each MVP will include a small number of complementary quality measures, improvement activities, and cost measures that are relevant to that focus. All MVPs will also include a uniform set of promoting interoperability measures and, if feasible, administrative claims-based measures devoted to population health.

    From many options to too few. Ophthalmologists currently do not have an MVP developed for them and do not fit into most APMs. They would therefore be left facing penalties if CMS ends traditional MIPS. Unfortunately, CMS has been unclear on how its plans to sunset traditional MIPS would accommodate clinicians who do not have MVPs or APMs available to them.

    The current CMS approach overlooks ophthalmology’s diverse subspecialties. CMS has been exploring concepts for an ophthalmology MVP. CMS staff have sought collaboration with ophthalmic societies on these concepts and asked for feedback. But when it comes to MVPs, CMS maintains that less is more. This minimalist approach leads to broad, sweeping MVPs that won’t be applicable to all the subspecialties within a diverse field such as ophthalmology.

    One MVP cannot possibly be applicable to all ophthalmologists. CMS wants to avoid having multiple MVPs per specialty. This is a problem for ophthalmology, which consists of multiple subspecialties with minimal overlap. Many of the quality measures included in a single, sweeping MVP could not be reported by all ophthalmologists and would fail to accurately compare clinicians from different subspecialties. Focusing on procedures or conditions that are relevant to specific subspecialists is the only way to equitably compare clinicians. Additionally, ophthalmologists who don’t perform cataract surgery regularly are not eligible for the cost measure that is most relevant to eye care.

    For ophthalmology, a move to MVPs imposes burdens with no apparent benefit. Currently, the IRIS Registry provides Academy members with an effective pathway to succeed at MIPS. A shift to an unrefined MVP program would increase provider burden with no demonstrated benefit over traditional MIPS. CMS must clarify the benefit to ophthalmologists and their patients before sunsetting traditional MIPS.

    MVPs won’t help ophthalmology transition to APMs. In the longer term, CMS may eliminate the MIPS program altogether and encourage—or perhaps mandate—clinicians to participate in APMs. If that’s the agency’s intention, any overhaul of the MIPS rules should provide clinicians with a bridge to the APM program. But a switch from traditional MIPS to MVPs won’t help to prepare clinicians for APMs, as the MVPs don’t allow clinicians to become familiar with the requirements of any given APM.

    What’s next? The Academy continues to press CMS on the importance of building ophthalmology-focused MVPs. CMS will launch seven MVPs in 2023, but none of them is relevant to ophthalmology. In 2023, clinicians will have the choice of using either traditional MIPS or an MVP, but CMS has noted that it is not feasible to maintain both traditional MIPS and MVP reporting methods indefinitely, due to “the operational burden, complexity, and costs associated with simultaneously maintaining both versions of the program.”

    More will be learned when CMS announces its MIPS proposals for 2023, which will probably be published in July.

    Ongoing advocacy. The Academy, along with other societies and coalitions, has continued to raise concerns about MIPS, MVPs, and APMs with CMS. For the latest developments, check your email each Thursday for Washington Report Express.

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