MIPS Value Pathways: Pros and Cons for Emergency Medicine Physicians

July 17, 2023 - A new option under CMS' Merit-Based Payment Incentive System (MIPS) aims to streamline reporting requirements and align quality measures with specific specialties. However, emergency physicians and other specialists should do their due diligence before jumping on the latest trend.

MIPS Value Pathways (MVPs) are a new reporting option launched in the 2023 performance year. But this new method has pros and cons, and there is limited data to determine whether this option can actually maximize MIPS reimbursement.

"A good example is the Emergency Medicine value pathway," says Dr. Andrea Brault, President and CEO at Brault Practice Solutions. "At face value, this MVP looks like a much simpler reporting option. But, as with all things, the devil is in the details."

What are the MIPS MVPs? 

CMS designed MVPs to deliver "a more connected assessment of quality of care" by tailoring quality measures and activities to a particular specialty, medical condition, or patient population. There are currently 12 MVP options, including one specific to emergency medicine.

CMS is gradually shifting to this tailored approach in an effort to simplify the MIPS reporting process and enhance performance feedback. Ultimately, the federal agency expects to sunset traditional MIPS reporting through future rulemaking, replacing it with options more like the MVPs today.

Traditionally, emergency physicians have reported MIPS data through a Qualified Registry (QR) using the free CMS quality measures in the public domain. Or through a Qualified Clinical Data Registry (QCDR) that allows physicians to pay for access to specialized quality measures. Now, the emergency medicine MVP aims to provide a hybrid approach that includes other added benefits.

Emergency Medicine MVP: The Pros

"The main selling point of an MVP is that it can reduce the administrative burden of MIPS reporting while also limiting a physician’s exposure to certain risks," says Dr. Brault.

For example, traditional MIPS requires a physician to report their top six quality measures, while MVPs only require four quality measures to be submitted. MVPs also offer protection from population health measures that are automatically added to a physician’s Quality category score – by requiring only one population health measure, compared to the four measures that can be automatically assigned under traditional MIPS.

MVPs can also offer similar protection in the Cost category. There are 25 possible cost measures under traditional MIPS, while some MVPs can be limited to just a single cost measure (e.g., emergency medicine).

These are significant benefits considering the Cost and Quality categories account for at least 60 percent of the MIPS final score (85 percent of the MIPS final score in emergency medicine).

"However, the actual risk of these auto-attributed measures is difficult to assess," cautions Dr. Brault. "CMS has only recently started to expand the universe of population health and cost measures. So, there isn't much data to determine whether they have any material impact on the final MIPS score."

Emergency Medicine MVP: The cons

What may be the MVPs greatest advantage could also be their biggest downfall for physicians.

"The biggest risk with MVPs is that you're limited to a smaller pool of available quality measures, which can limit your scoring potential," explains Dr. Brault. "So, while submitting only four quality measures through an MVP may seem advantageous, that might not always be a good thing. The ones you're left with might not be your best measures, or they could already be topped out."

When a quality measure reaches a national median of at least 95 percent compliance, CMS considers the measure to be "topped out." And, when a measure has been topped out for at least two years, CMS begins to cap its score at 7 points (compared to a 10-point maximum for other measures) – a subtle nuance that can significantly impact your MIPS final score.

"The emergency medicine MVP offers a mix of topped-out CMS measures with low-scoring potential and specialized QCDR measures with high-scoring potential. So, it's a bit of a give and take," says Dr. Brault.

There’s also an MVP registration cost and potential added fees for accessing the specialized QCDR measures, which can start to change the ROI calculation for some physicians.

One size doesn't fit all. So, it's important to weigh your options. 

Physicians should weigh the benefits and risks of reporting MIPS data through an MVP, with consideration for their specific circumstances and resources.

"We're still very much in the early stages of this streamlined approach, especially for emergency medicine," says Dr. Brault. "So, it's worth keeping it on your radar, but the true benefits are yet to be seen."

Fortunately, physicians can register for an MVP and still decide to opt-out before the reporting period ends. However, if they opt-out of the MVP, they would still be required to submit MIPS data through one of the other reporting alternatives.

"The good news is that there are options available," says Dr. Brault. "But these options can also require significant planning and resources. So, it's important to start this consideration process early and allow time for setup and coordination between the physicians, hospital, and data partners."

MIPS will continue to shape the landscape of Medicare reimbursement, and failing to act is no longer an option.

"Now is the time to start planning for the 2024 performance year," explains Dr. Brault. "Especially for those who delayed their MIPS planning during the public health emergency."

Many emergency physicians were granted a MIPS exception for Extreme and Uncontrollable Circumstances (EUC) during the COVID-19 pandemic, which protected them from penalties and allowed them to opt out of MIPS reporting.

However, this exemption is not expected to be an option for the 2024 performance year. And many physicians will now have to face the full impact of MIPS – which can result in a bonus payment or penalty assessment of up to 9 percent of their annual Medicare reimbursement.

The MIPS program is designed to penalize the lower-performing half of participants while the top half receives a bonus check. "There's a lot at stake, especially for emergency departments where a big swing in Medicare payments can have significant downstream effects on staffing levels and available resources," explains Dr. Brault.

"Physician reimbursement under Medicare has continued to decrease, with an additional three-percent cut expected in 2024," adds Dr. Brault. "So, the MIPS program can be an important tool to regain some of those losses. But MIPS has the potential to cut both ways – and the difference often comes down to proper planning."

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ABOUT BRAULT PRACTICE SOLUTIONS

Brault is a revenue cycle and practice management organization that partners with hospitals and independent physician groups. Their intelligent practice solutions include coding and billing, MIPS optimization, provider documentation training, and practice management. Learn more at www.Brault.us