The Medical Group Management Association (MGMA), American Medical Association (AMA) and the American College of Physicians (ACP) are asking for changes to the Merit-based Incentive Payment System (MIPS). A wide group of stakeholders want the quality reporting period reduced to 90 days, while the ACP released a study determining many MIPS measures aren’t valid.
MIPS-eligible clinicians in 2018 are required to report quality measures for the full year, up from 90 days in the payment program’s “pick your pace” first year. The MGMA and others have criticized CMS for taking until April 8 to notify clinicians whether they need to participate in MIPS. In its letter to CMS Administrator Seema Verma, the group said it has heard the agency won’t update its interactive website for MIPS with more recent changes to the program until the summer.
When combined with the myriad of changes to the program in its full year under the Trump administration—like making far more clinicians exempt if they don’t serve enough Medicare patients—the 49 groups signing the letter said allowing for a minimum data collection period of 90 days, rather than 365 days, would address concerns about the burden of quality reporting and allow time to incorporate feedback from MIPS’ first year.
“We believe a minimum 90-day reporting period is consistent with CMS’s efforts to reduce clinician burden and to put patients over paperwork,” the letter stated.
The letter argued there is precedent for retroactively reducing reporting requirements as CMS did so in the Meaningful Use program in 2015 and 2016. However, CMS had also heard calls for a 90-day reporting period from MGMA and similar groups in crafting the 2018 MIPS rule and ignored their pleas.
ACP was among the groups signing the letter, but it brought up more fundamental concerns with MIPS in a study published in the New England Journal of Medicine. Researchers led by Catherine McLean, MD, PhD, chief value officer at New York’s Hospital for Special Surgery, judged the validity of 86 MIPS measures relevant to internal medicine based on five domains: importance, appropriateness, clinical evidence, specifications, and feasibility and applicability.
McLean and her coauthors found only 32 of the 86 measures to be valid, with 24 to be of “uncertainty validity and 30 labeled not valid, with 19 of those judged to have “insufficient evidence to support them.”
“The fact that only 37 percent of measures proposed for a national value-based purchasing program were found to be valid with a standardized method has implications for physician-level performance measurement,” McLean and her coauthors wrote. “The use of flawed measures is not only frustrating to physicians but also potentially harmful to patients. Moreover, such activities introduce inefficiencies and administrative costs into a health system widely regarded as too expensive.”
These inconsistencies, ACP said, should be addressed both by standardizing how to judge quality measures’ validity as well as taking a “time out” to reassess how physician performance is measured.
Both of these efforts add to the growing threats to MIPS. The program has been recommended for elimination by the Medicare Payment Advisory Commission (MedPAC) for several reasons, including increasing the burden of clinicians while too easily allow clinicians to pick only the measures which will guarantee higher scores—which, as the commission said, would impede the transition to value-based care.
Many of the same groups which signed the letter to CMS do want to see the program changed, but don’t back MedPAC’s recommendation to scrap it altogether. Anders Gilberg, MGMA’s senior vice president of government affairs, told HealthExec in March the MedPAC report was an “indictment of MIPS as implemented,” but disagreed with the idea that it couldn’t be improved. Reducing the quality reporting period to 90 days, he added, would be one immediate steps CMS could take to reduce clinician burden.