Impact Insights

2022 PFS Proposed Rule Part 2: MIPS Value Pathways (MVPs) Proposals

This month, CMS released the 2022 Physician Fee Schedule (PFS) Proposed Rule, which also governs the Quality Payment Program (QPP) for healthcare providers. Check out our high-level overview here and Part 1 about Traditional MIPS Program Proposals. This blog digs into MIPS Value Pathways (MVP) Proposals and upcoming content will continue to explain individual sections of the rule.

MIPS Value Pathways (MVPs) Proposals

Coming to MIPS in 2023!

As mentioned in our introductory blog post to the 2022 PFS Proposed Rule, MVPs represent a fundamental shift in the MIPS program and how we think about MIPS (and eventually leading to the sunset of “traditional” MIPS sometime after the end of the 2027 performance and data submission periods (with specifics to be finalized in future rulemaking). With this rule, CMS has made clear its intentions to focus the future of MIPS on development and implementation of MVPs.

What’s different about MVPs is that they’re customized for specific practice and clinician types. Rather than a “one-size-fits-all” program, where Eligible Clinicians (ECs) have to sift through hundreds of potential quality measures looking for a good fit, MVPs focus on sets or groups of requirements that are preselected to be both meaningful to practitioners as well as specifically targeted to improve patient outcomes.

MVPs are designed to bring together the four activities and measures associated with traditional MIPS scoring (quality, cost, PI, IA) yet also align specific measures so that the MVP itself becomes more relevant to a specialty, medical condition, or episode of care.

To accomplish this, MVPs pair foundational elements (Promoting Interoperability and population health claims-based measures) along with relevant measures and activities for the quality, cost, and improvement activities performance categories.

MVP Guiding Principles

  • Consist of limited, connected, complementary sets of measures and activities that are meaningful to clinicians.
  • Include measures and activities resulting in comparative performance data that is valuable to patients and caregivers in evaluating clinician performance and making decisions about their care.
  • Include measures selected using the Meaningful Measures approach and, wherever possible, include the patient voice.
  • Reduce barriers to Alternative Payment Model (APM) participation by including measures that are part of APMs, and by linking cost and quality measurement.
  • Support the transition to digital quality measures.

MVP Proposed Changes for 2022

Beginning with the 2022 performance year/2024 payment year, the following changes to MVPs are proposed:

  • MVPs must include at least one outcome measure that is relevant to the MVP topic, so MVP Participants are measured on outcomes that are meaningful to the care they provide.
  • Each MVP that is applicable to more than one clinician specialty should include at least one outcome measure that is relevant to each clinician specialty included.
  • In instances when outcome measures are not available, each MVP must include at least one high-priority measure that is relevant to the MVP topic, so MVP Participants are measured on high-priority measures that are meaningful to the care they provide.
  • Allow the inclusion of outcomes-based administrative claims measures within the quality component of an MVP.
  • Each MVP must include at least one high-priority measure that is relevant to each clinician specialty included.
  • To be included in an MVP, a qualified clinical data registry (QCDR) measure must be fully tested.

MVP Timeline

PY 2023: CMS is proposing to begin transitioning to MVPs in the 2023 MIPS performance year (a delay from CMS’ original timeframe of 2021, later moved to 2022, and now 2023). Note that QCDRs, Qualified Registries, and Health IT vendors along with CAHPS for MIPS survey vendors must be prepared to support MVPs by the 2023 performance year, as well.

PY 2023 and 2024: MVP Participants are defined as individual clinicians, single specialty groups, multispecialty groups, subgroups, and APM entities that are assessed on an MVP for all MIPS performance categories.

PY 2025: Multispecialty groups will be required to form subgroups in order to report MVPs.

PY 2027: Sunset of traditional MIPS sometime after the end of the 2027 performance and data submission periods. (Final timeline for sunset of MIPS pending future rulemaking)

Proposed MVPs

Seven MVPs are proposed to be available beginning with the 2023 performance year:

1) Rheumatology
2) Stroke Care and Prevention
3) Heart Disease
4) Chronic Disease Management
5) Emergency Medicine
6) Lower Extremity Joint Repair
7) Anesthesia

CMS reinforces that the traditional MIPS framework will remain in place as they gradually implement MVPs for more specialties and subspecialties until a sufficient number of MVPs is available to sustain the program for all MVP Participants.

MVP Participant Registration

Prospective MVP Participants must register for each MVP (and as a subgroup if applicable) between April 1 and November 30 of the performance year (or a later date as specified by CMS). Participants would not be allowed to report on an MVP unless they have registered for that MVP.

To report the CAHPS for MIPS Survey associated with an MVP, CMS is proposing that a group, subgroup, or APM entity complete their MVP registration by June 30 of the performance year (which would align with the CAHPS for MIPS Survey registration deadline).

Once registered, MVP Participants would not be able to make changes to their selected MVP after the close of the registration period (November 30 of the performance year) nor submit for another MVP.

To register, MVP Participants must:

  • Select the MVP they intend to report.
  • Select one population health measure included in the MVP.
  • Select any outcomes-based administrative claims measure on which the MVP Participant intends to be scored (if available within the MVP).

To participate as a subgroup, each subgroup must:

  • Select the MVP the subgroup will report.
  • Select one population health measure included in the MVP.
  • Select any outcomes-based administrative claims measure on which the subgroup intends to be scored, if available).
  • Identify the clinicians in the subgroup by Taxpayer Identification Number (TIN) / National Provider Identifier (NPI).
  • Provide a plain language name for the subgroup for purposes of public reporting.

MVP Reporting Requirements

Foundational Layer

1) Population Health Measures
▪ Participants would select one population health measure, with these results added to the quality score.
▪ For the 2023 performance year, two population health measures are proposed to be available for selection:
– Hospital-Wide, 30-day, All-Cause Unplanned Readmission (HWR) Rate
– Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions

2) Promoting Interoperability (PI) Performance Category
▪ Participants would report on the same PI measures required under traditional MIPS (unless they qualified for automatic reweighting or had an approved hardship exception).
▪ Subgroups would submit PI data at the group level, not the subgroup level.

Quality Performance Category

▪ Participants would select four of the available quality measures.
One measure must be an outcome measure (or a high-priority measure if an outcome measure isn’t available or applicable). This can include an outcome measure calculated by CMS through administrative claims (if available in the MVP).

Improvement Activities (IA) Performance Category

Participants would select:
▪ Two medium-weighted improvement activities
Or: One high-weighted improvement activity
Or: Participate in a certified Patient-Centered Medical Home or comparable specialty practice participant (if available in the MVP).

Cost Performance Category

CMS calculates this measure utilizing administrative claims data from the cost measures that are included in the MVP. (Note that MVP Participants do not need to independently submit data on cost measures).

Subgroups

Subgroups are a new concept for MVPs, designed to offer more granularity for MVP Participants and providing patients and clinicians with information that is more clinically meaningful.

A subgroup is defined as “a subset of a group which contains at least one MIPS eligible clinician and is identified by a combination of the group TIN, the subgroup identifier, and each eligible clinician’s NPI.”

Subgroup reporting be voluntary for the 2023 and 2024 performance years.

▪ For these first years of reporting, subgroup reporting is limited only to clinicians reporting through MVPs or APP.
▪ Voluntary reporters, opt-in eligible clinicians, and virtual groups will not be able to report to MIPS through an MVP for the 2023 performance year.

Subgroup Characteristics

▪ Subgroups would inherit the eligibility and special status determinations of the affiliated group (identified by TIN).
▪ To participate as a subgroup, the TIN would have to exceed the low-volume threshold at the group level.
▪ The subgroup would inherit any special statuses held by the group, even if the subgroup composition would not meet the criteria.

MVP Scoring

CMS intends scoring for MVPs to parallel traditional MIPS scoring (e.g., similar performance category weights, etc.) with the exception of some nuances with respect to reweighting policies.

Foundational Layer

1) Population Health Measures
▪ Population health measures are included as part of the Quality score.
▪ Exclusions for lack of benchmark or not meeting case minimums (note that outcomes based administrative claims measures would receive a zero score (rather than being excluded) in these instances).
▪ Subgroups would receive the group score if the measure doesn’t have a benchmark or meet case minimums.

2) Promoting Interoperability (PI) Performance Category
▪ PI will be scored in alignment with traditional MIPS scoring.
▪ Subgroup performance will be assessed at the group level (Subgroups will receive the affiliated group’s PI score.)

Quality Performance Category

Remove the 3-point floor for quality scoring for 2023 PY.
– Measures without a benchmark or that don’t meet case minimum would earn zero points.
– Exception for small practices (which would earn 3 points in these cases).
– Measures that can be scored against a benchmark would earn 1-10 points.
▪ For new measures without a benchmark:
– Implement a 5-point floor for the first two performance years (i.e., scoring would be from 5 to 10 points for PY 2023 and PY 2024).
Bonus points not awarded for high priority or using end-to-end electronic reporting measures.
▪ If more than the 4 required measures are reported, CMS will score the four highest scores.
▪ If any required measures are not reported, MVP Participants will receive zero points for those measures.
▪ Subgroup performance will be assessed at the subgroup level.

Improvement Activities (IA) Performance Category

▪ High-weighted IAs are worth 40 points
▪ Medium-weighted IAs are worth 20 points
▪ Subgroup performance will be assessed at the subgroup level

Cost Performance Category

▪ Only cost measures included in the MVP will be scored
▪ Subgroup performance will be assessed at the subgroup level

Scoring Hierarchy

▪ Each MIPS Eligible Clinician (EC) would receive the highest score from among:

ANY reporting option:
– Traditional MIPS
– APM Performance Pathway (APP)
– MIPS Value Pathways (MVP)

ANY participation option:
– Individual
– Group
– Subgroup
– APM Entity
– (But *NOT* Virtual Group, which will always receive the Virtual Group’s final score)

Performance Feedback and Public Reporting

Public reporting of new Improvement Activities (IA) and Promoting Interoperability (PI) measures reported via MVPs are proposed to be delayed by one year (public reporting will begin with PY 2024).
▪ Subgroup scores will be reported separately from group scores.
▪ Performance feedback methodologies will be developed to compare clinicians reporting on the same MVP.

Up Next: 2022 PFS Proposed Rule Part 3: APM Performance Pathway (APP) and Advanced APM Proposals

Helpful Links

CMS PFS Homepage:

https://www.cms.gov/Medicare/Medicare-Fee-for-Service-Payment/PhysicianFeeSched

CMS Proposed Rule Page:

https://www.cms.gov/medicaremedicare-fee-service-paymentphysicianfeeschedpfs-federal-regulation-notices/cms-1751-p

PDF of Proposed Rule (1,747 pages):

https://public-inspection.federalregister.gov/2021-14973.pdf

Federal Register Proposed Rule Page:

https://www.federalregister.gov/public-inspection/2021-14973/medicare-program-cy-2022-payment-policies-under-the-physician-fee-schedule-and-other-changes-to-part

CMS Fact Sheet:

https://www.cms.gov/newsroom/fact-sheets/calendar-year-cy-2022-medicare-physician-fee-schedule-proposed-rule

QPP MIPS Value Pathways Page:

https://qpp.cms.gov/mips/mips-value-pathways