PHILADELPHIA—As part of an ACR Convergence Expert Roundtable on Sunday, Nov. 13, William Harvey, MD, MSc, associate professor of medicine at Tufts University, Boston, and chief medical informatics officer at Tufts Medicine, Boston, discussed a new iteration of Medicare’s Merit-Based Incentive Payment System (MIPS), the MIPS Value Pathways (MVPs). He shared how and why rheumatologists may want to implement it next year, potentially using the ACR’s Rheumatology Informatics System for Effectiveness (RISE) registry.
Dr. Harvey
In 2017, the Centers for Medicare & Medicaid Services (CMS) introduced MIPS as a part of its Quality Payment Program. MIPS was created as a way to pay clinicians partly based on the quality of their services and not just under a strict fee-for-services model. Under this model, final reimbursement was partly dependent on how well participants had met certain prespecified goals.
MIPS Value Pathways
Beginning in 2023, physicians can opt to use MVPs rather than existing MIPS requirements to submit their information via MIPS.
MVPs were designed as an evolution of MIPS, Dr. Harvey explained. Using MVPs, clinicians can report on fewer measures and activities compared to those required by standard MIPS criteria. The idea is that reported measures would be more focused and meaningful in terms of specific specialties. MVPs were intended to “reduce complexity, remove clinician burden and foster a more cohesive patient experience,” Dr. Harvey reported. “That all sounds great, but as is often the case with the government, the devil is a bit in the details.”
This November, the CMS finalized the 12 different MVPs in which clinicians can opt to participate, including the rheumatology MVP. “We made a conscious decision at the ACR that, rather than have somebody else dictate what measures are going to be relevant to us, we worked to build our own MIPS value pathway,” Dr. Harvey said. “This MIPS pathway was designed by the ACR and is supported by a lot of the things the ACR does, such as the RISE registry.”
Reporting with MVPs
MVPs retain the same four MIPS categories of reporting: Quality, Improvement Activities, Promoting Interoperability and Cost. Each category contains multiple measures, and physicians can choose which they will report.
For example, to meet the Quality category, four different measures must be selected, including at least one outcome measure. Examples include: meeting serum urate targets for gout, performing disease activity measurement in patients with psoriatic arthritis and assessing functional status in rheumatoid arthritis. Dr. Harvey noted that the reporting system has some flexibility; for example, if a physician reports more than four different Quality measures, the CMS will use the best four when calculating reimbursement.
The ACR created several of the outcome measures, which they submitted to the CMS for approval. Said Dr. Harvey, “We take the things that are routinely done [in rheumatology practices], we measure them and get you credit for it. We’re trying not to have you report on things like diabetes that wouldn’t fit with your practice.”
Many physicians, especially those who are part of a larger multi-specialty group or health system, may already be meeting several of the criteria in the Promoting Interoperability category, such as performing e-prescribing, using prescription drug monitoring programs and utilizing immunization registries, Dr. Harvey pointed out.
In the Improvement category, which measures activities that improve clinical practice, one must pick two medium or one highly weighted activity. These include activities related to tobacco cessation, telehealth services, electronic health records and capturing patient outcomes, better engagement of patients through patient portals and others. Dr. Harvey noted that here too, many practices already perform some of these activities.
Dr. Harvey explained that the Cost category is the most complex, as it is based on a very complex formula that involves risk adjustments. However, clinicians do not need to do anything to submit, because the CMS will automatically calculate this based on the medical claims it receives.
A new component is that clinicians must also pick a population health measure when they register for an MVP. The CMS will automatically calculate this based on administrative claims data. This involves either a measure related to 30-day hospital readmission or a measure of hospital admission rates for patients with multiple chronic conditions.
How & Why to Try the Rheumatology MVP
For clinicians unsure about whether to try the MVP in 2023, Dr. Harvey suggested considering several factors. For example, some might already be tracking the performance of quality measures that are measured as part of an MVP and know they are performing well in these measures. For such clinicians, a transition to an MVP in 2023 might be beneficial. He added, “There might be some bugs, because it is a new program, and this is the first year it is being implemented. But if you are forward thinking, I encourage you to get in early on this.”
Participants can also take advantage of the free RISE registry, the largest electronic health record-enabled rheumatology registry in the U.S. Clinicians can connect their electronic health records systems to RISE to reliably and consistently track the quality of the care that they provide. Dr. Harvey added, “It supports all the submissions of MIPS that are required, and we created the rheumatology MVP with the use of RISE in mind. You just do your daily work, and the RISE registry keeps track of everything for you.”
For details on calculating the various criteria, some of which are complex and subtle, Dr. Harvey recommended looking at the rheumatology MVP toolkit provided online by the CMS. Understanding the details of these criteria can help clinicians decide which ones make the most sense to track. As of this writing, however, the CMS has not updated the toolkit to reflect the most recent changes to MVPs; these updates are expected in the next several weeks.
Previously, the CMS announced it is considering making MVPs the mandatory mode of MIPS participation. However, it has not officially announced when and if submitting under the traditional MIPS program might be fully phased out. At least for the present, physicians can choose to report through MVPs or traditional MIPS. Clinicians can also opt to report their data via both traditional MIPS and the rheumatology MVP, and the CMS will calculate reimbursement based on the method that provides a more favorable outcome for the medical provider.
Any rheumatologist with questions or concerns about implementing an MVP via the RISE registry can contact [email protected] for support. Those wishing to participate in the MVP program in the coming year need to register between April 1 and Nov. 30, 2023.
Ruth Jessen Hickman, MD, is a graduate of the Indiana University School of Medicine. She is a freelance medical and science writer living in Bloomington, Ind.
