Why MIPS should be replaced

In an article for Health Affairs, a group of fellows at the Brookings Institution made the case for replacing the Merit-based Incentive Payment System (MIPS) with “stronger incentives” to move into alternative payment models (APMs).

Matthew Fiedler, PhD, and his colleagues argued MIPS fails to achieve the Medicare Access and CHIP Reauthorization Act (MACRA)’s goal of reducing administrative burden by replacing previous value-based purchasing programs. Additionally, they wrote that the existing MIPS performance categories won’t improve quality and efficiency of patient care thanks to allowing clinicians to choose the measures and activities on which they’re judged.

At the same time, there will be significant costs for providers to comply with MIPS: $694 million for the 2018 performance year, according to Fiedler and his coauthors. Essentially, it’s a program no one will be satisfied with.

“This unfavorable cost-benefit profile justifies major changes to MIPS, and we would discourage Congress from merely tinkering around the edges,” they wrote. “MIPS’s design surely could be improved; however, many of MIPS’s shortcomings are likely unavoidable in a system that seeks to measure overall quality and cost performance at the level of each individual clinician or practice and then adjust fee-for-service payment rates on that basis.”

The Medicare Payment Advisory Commission (MedPAC) has recommended Congress repeal MIPS and replace it with what it calls the Voluntary Value Program (VVP). The Brookings fellow have their own suggestions, like adding extra incentives to advanced APM participation as well as bonuses and penalties for “clearly-defined, high-value” activities like using a certified electronic health record and reporting to clinical data registries.

Even though MIPS is only in its first year of full reporting, the Brookings fellows argued the program is already showing it won’t achieve its objections and replacing it should be considered immediately.

“We recognize that Congress may be tempted to wait for several years of experience under MIPS before considering major changes like these, but that would be a mistake. Forging agreement on a system to succeed MIPS will take time and effort. That work should begin as soon as possible,” Fielder and his coauthors wrote.