MedPAC Proposal Not Likely to Impact MIPS

Author: Andrews Dean, Consultant

This March roughly 418,000 clinicians are expected to report clinical quality metrics under the Merit-based Incentive Payment System (MIPS) for the first time. Yet, just last month the Medicare Payment Advisory Commission voted 14-2 in favor of recommending the quality reporting track be axed and replaced with a new voluntary program.

The MedPAC recommendation to cancel MIPS is something that’s been talked about since mid-2017. Industry insiders anticipated the vote, but Congress has already tipped its hat on how it feels about the proposal. It’s essentially DOA—primarily due to a lack of confidence in the replacement proposed by MedPAC, but also due to Congress’ desire to see how MIPS performs before making substantial changes to the program. While there was agreement about the need for change from MedPAC commissioners, notably absent was any support for the replacement proposal.

It’s also worth noting that this is just a recommendation from MedPAC at this point. The agency has a significant voice in healthcare initiatives, but this proposal did not receive a welcome reception when initially discussed last year. Several prominent organizations (including the American Hospital Association and the Medical Group Management Association among them) have expressed dissatisfaction with what has been interpreted as a premature effort to “repeal” MIPS and voiced disapproval of the proposed claims-based, voluntary reporting alternative.

CMS is mandated to operate MIPS in accordance with the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA). This means further modification to MIPS would have to come legislatively, and there isn’t much bi-partisan agreement on healthcare presently. While the current administration is clearly pursuing a de-regulatory agenda, there is some question on where this would land among Congressional legislative priorities. Any recommendations by MedPAC would have to survive a full legislative process, be signed into law, and then make it through the long CMS rule-making process to come to bear.

Essentially this means MIPS is here to stay for another two years, if not longer. However, CMS is expected to focus more on alternative payment model (APM) reporting tracks under MACRA’s Quality Payment Program (QPP) framework, as MIPS was always intended to be the lead-in and not a final destination for providers in value-based care. CMS just released a comprehensive list of the advanced APMs that presently meet QPP reporting criteria.

We can expect to see more changes to MIPS later this year as the 2019 QPP Interim and Final Rules are released. More focus on APMs is expected, as has always been the plan. The goal for CMS is to curb spending and discourage low-quality, high-cost care, and there must be a viable mechanism for them to achieve this. The recent MedPAC proposal for a voluntary quality program doesn’t fit that need.