Beginning in 2023, physicians will have the option to report under the Medicare Quality Payment Program (QPP) using MIPS Value Pathways (MVP) in lieu of the traditional reporting methods. MIPS, the Medicare Incentive-based Payment System, started gathering performance reports in 2017 and in 2019 the first Medicare payment adjustments were made based on that 2017 reporting. Eventually traditional MIPS reporting will be phased out, but the Centers for Medicare and Medicaid Services (CMS) has not proposed a timeline for doing so.

Which MVPs are Available?

There are seven (7) MVPs that were finalized in the 2022 Medicare Physician Fee Schedule (MPFS) Final Rule, and there are five (5) more proposed in the 2023 MPFS. The finalized MVPs are as follows, along with the CMS description of the specialties most likely to use them:

None of the approved MVPs will apply to radiology.

The MVPs proposed to be added, if finalized by CMS, will be effective for 2023. They are:

After reviewing the details, the only proposed pathway we found that might be useful for radiology is Optimal Care for Patients with Episodic Neurological Conditions.

How do MVPs work?

MVPs are a subset of previously defined measures and activities that were used under traditional MIPS, but they have been grouped for a specific disease or specialty. According to CMS, “the goal is to move away from siloed reporting of measures and activities towards focused sets of measures and activities that are more meaningful to a clinician’s practice, specialty, or public health priority.” Accordingly, the MVP framework will “align and connect measures and activities across the quality, cost, and improvement activities performance categories.” The MVPs include the Promoting Interoperability performance category and population health claims-based measures as foundational elements.

The measures and activities that will be reported under MVPs will consist of limited, connected, complementary measures and activities that are defined for that particular pathway. Thus, practices using the MVP framework will no longer be able to report on individual measures of their own choosing.

What are the participation options?

For the 2023 – 2025 performance years, a participant is defined as:

• An individual clinician
• A single- or multi-specialty group
• A subgroup
• An Alternative Payment Model (APM) entity

An MVP participant can only participate in a single MVP for each reporting period. However, an individual clinician can participate in multiple MVPs by reporting as part of a group for one pathway and as part of a subgroup for a different pathway. Beginning in the 2026 performance year, multispecialty groups will be required to form subgroups for MVP participation.

A subgroup is defined as one or more MIPS-eligible clinicians within a group practice. CMS has proposed that the Provider Enrollment, Chain, and Ownership System (PECOS) be used as the determinant of the specialty type for a single- or multi-specialty group.

Participants will be required to register their reporting status between April 1 and November 30 of each performance year. At the time of registration, a participant will select:

• The MVP they intend to report;
• One population health measure included in the MVP; and
• Any outcomes-based administrative claims measure on which the MVP participant intends to be scored, if available within the MVP.

Each subgroup will also be required to:

• Identify the MVP on which the subgroup will report, including the population health measure and any administrative measure on which the subgroup intends to be scored.
• Identify the clinicians in the subgroup by Taxpayer Identification Number (TIN) and National Provider Identifier (NPI)
• Provide a plain language name for the subgroup for public reporting purposes.

A participant will not be allowed to submit or make changes to the MVP they have selected after the November 30 close of the registration period, and they will not be allowed to report on an MVP for which they did not register.

Scoring

Scoring will be similar to that used in traditional MIPS, using the same performance category weights that exist for 2022 reporting. The MIPS reweighting policies will be continued, as well. However, Improvement Activities will be assigned 20 points for each medium-weighted activity and 40 points for each high-weighted activity.

A MIPS eligible clinician will receive the highest final score that can be attributed to their TIN/NPI combination from any reporting option (including traditional MIPS, APP reporting, or MVP reporting) or participation option (individual, group, subgroup or APM entity).

Conclusion

While it seems unlikely that radiology practices will initially be able to participate meaningfully in MVPs, this framework is the future of the Quality Payment Program. CMS will be developing additional MVPs each year in order to accommodate as many clinicians and specialties as possible, until traditional MIPS is fully phased out. Practices should become familiar with this new framework and continue to monitor the progress of MIPS Value Pathways so they are ready to make the switch when the time comes. Subscribe to this blog to keep abreast of the latest developments in the QPP and in other areas that will help maximize your practice’s reimbursement.

Erin Stephens, CPC, CIRCC  is the Sr. Client Manager, Education at Healthcare Administrative Partners. 

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