Back in January of 2021 our CEO, Lauren Patrick, wrote "MVPs – Will they replace ‘traditional’ MIPS?" At that time there were a lot of questions about how CMS would implement their new reporting framework, MIPS Value Pathways (MVPs). Starting with the 2023 Program Year (PY), MIPS eligible providers have two pathways they can take to satisfy their obligations. In this blog, I will review what an MVP looks like and how you may want to implement them within your practice.
First off, if you are a visual learner, Healthmonix produced a webinar Getting Started with MIPS Value Pathways in 2023.
Let’s get my opinion on MVPs down right now. I believe that MVPs are a STEP in the right direction for quality reporting. However, I still think the Centers for Medicare & Medicaid Services (CMS) has a long way to go to provide the impact they projected back when Medicare Access and CHIP Reauthorization Act (MACRA) was signed in 2015. MVPs take care of one of my issues as it allows providers to track and report on measures that are more meaningful to their specialty. MVPs take the leg work out of measure selection (for the most part) and some of the surprises related to Traditional MIPS reporting. It also allows CMS to better compare similar providers to each other. MVPs do not make interoperability better, do not promote health equity, and will have minimal impact on reporting burden.
MVPs are very similar to Traditional MIPS. The biggest differences are listed below:
- Only four Quality measures are reported instead of six
- A Population Health measure is mandatory (although if you do not meet a case minimum, it won’t apply)
- Improvement Activities are worth double ( similar to small groups for Traditional MIPs)
- And the most confusing addition is Subgroup reporting
I will break down Subgroups more in my next article, but here is a basic overview. Subgroups are a subset of clinicians within a single Taxpayer Identification Number (TIN). Subgroups will allow TINs to split apart physicians into reporting groups allowing them to be scored separately. Some of the advantages of Subgroup reporting are separating out poor performers or high performers, taking advantage of certain measures, and most importantly simplifying multi-specialty groups. Subgroup reporting will be optional in 2023-2025 but mandatory for multi-specialty groups in 2026.
Breaking down an MVP
The Foundational Level includes Promoting Interoperability (PI) and Population Health Measures. For PI, MVP participants have the same reporting obligations as they do under Traditional MIPS. Small groups and other PI exempt groups are still eligible for their exemptions. The only difference for PI is that Subgroups are scored on their affiliated groups score.
There are also two Population Health measures of which each group needs to select one. The options are Q479 and Q484, and one must be chosen at the time of MVP registration with CMS. No submission is required as CMS will calculate these measures by administrative claims data.
Quality reporting is similar to Traditional MIPS except that each MVP has a limited number of measures to choose from, and participants only need to report on four of them. This is a great opportunity for clinicians to limit their quality burden to only measures that are close to their specialty. For example, anesthesiology has always been a very hard specialty to find six measures. Through MVP reporting, they can eliminate two of their lower scoring measures and report on their four best measures. This should have a significant impact on their score.
Each 2023 MVP has at least seven measures from which to choose. Nine of the MVPs include a mixture of Clinical Quality Measures (CQMs) and Qualified Clinical Data Registry (QCDR) measures. The other three 2023 MVPs are made up entirely of CQMs. Each MVP has at least four CQMs and are available on a registry like MIPSpro.
Improvement Activities are very similar to Traditional MIPS as well. MVP participants must report on two Medium Weighted measures or one High Weighted measure. This is the same as the current MIPS regulations for small practices. The only concern a participant might have is if the activities that are normally selected are not available under the MVP chosen.
Now that you know what an MVP is, you most likely read this article to see if an MVP is right for you. For 2023, this is an easy process. There are 12 MVPs this year (with more to follow in coming years). See our list here. Is one of these an MVP that has four quality measures you can track and report? If so, then absolutely. There is very little downside to tracking and even reporting both MVPs and Traditional MIPS at the same time. However, there is a very big upside. You can report Traditional MIPS, MVPs as a group, and MVPs as a sub-group. CMS will take the highest score you submit.
What can you do today to get started?
- Each MVP has a limited number of measures, so while reporting four is easier than six, you need to be careful about which MVP you choose.
- Determine if you want to report on an MVP as a whole, or if you want to split into sub-groups.
- Each option comes with its own complications and benefits, and not every group will come up with the same approach.
- I will review sub-groups in a follow up article this month.
- Look at what Cost measures your organization will be qualified for and understand whether that drives you away from an MVP or towards and MVP.
- Understand the impact on the staff, if any, it is to change what measures they are tracking throughout the year.
- You must register with CMS for an MVP between April 3rd and November 30th.
- You will need to register for the MVP of choice, the population health measure, and any outcomes-based claims measure needed
- You will also need to register sub-groups and the participants at this time.
- Register with MIPSpro to track and report your MVP.
Despite MVPs being new, there's no need to feel overwhelmed. Our team is here to help you get started. Contact us to learn how you can benefit from reporting in an MVP.