March MedPAC Report Indicates Immediate Elimination of MIPS
The Medicare Payment Advisory Commission (MedPAC) recently published its March report. Within the report, one section addressed the failing MIPS (merit-based incentive payment system). MedPAC offered a different route for determining quality which was based on group data versus individual clinician data.
The March 2018 MedPAC report shared the cost associated with MIPS from both the provider and Medicare's perspective. I had no idea the level of cost for providers to participate, nor the huge cost Medicare has for benchmarking and determining whether an incentive payment or a penalty occurs. One thing not mentioned, if MIPS is considered budget neutral, was the Centers for Medicare and Medicaid (CMS) cost to evaluate the data included in the "budget neutral" description?
MedPAC advised immediately eliminating MIPS. The suggestion was to simplify the process to only focus on patient outcomes, patient experience and cost. The proposed solution was called a Voluntary Value Program (VVP). Remember, for now physical therapists, occupational therapists and speech-language pathologists are not included in MIPS. Although they are not, I tend to think that it is good to stay informed about what is going on with Medicare to be able try to anticipate upcoming changes that affect us.
VVP focuses on the health of the population and includes all the clinicians across time and settings. Apparently clinicians would not be reporting quality: CMS would derive measures from claims data and surveys. From a rehabilitation perspective, can you hear me groan? Claims data isn't enough to determine patient outcomes/quality from a rehabilitation perspective. Will the survey developed capture change to adequately differentiate quality from poorer results?
The VVP proposal includes the concept of a "centrally administered survey information to calculate performance." I don't know about each of you, but do you want your payment based on some measure that you are not aware? And, besides that, do you want the government to be the one responsible for obtaining survey results? I mean, when will the government administer the survey? Weeks after a claim is submitted? For every beneficiary receiving services? To every beneficiary at certain points during the year? MedPAC was quite vague, so maybe I am misunderstanding the proposal.
I can appreciate the idea of aggregated data and clinicians being in grouped data for quality determination purposes. As a single clinician, we don't have enough Medicare patients to determine quality. And, that being said, we treat a multitude of diagnoses which reduces the ability to determine quality even more. The minimum number MedPAC shared included 700 beneficiaries (to get 300 responses) to determine patient experience. I know I don't have that kind of volume. What I don't understand, for small practices, how can those in small practices join together? The tax identification numbers will all be different. Hospital situations are different - they have a whole system and multiple sites, so that data could easily be grouped under one umbrella.
The VVP example for clinical quality included readmissions, mortality, inpatient hospital use and emergency department use. These quality indicators do not define quality for rehabilitation providers.
From my perspective, it seems the majority of quality indicators will actually be derived from claims data. It also doesn't seem that the concept of "episode of care" is the focus, but instead the idea that patients need to be managed so that hospital generated claims do not happen.
For now, it seems we just sit tight and wait to see what will happen with MIPS. If you are interested in reading the full report, you can find it here.