WASHINGTON – Population-level outcomes measures are the key focus of a proposed program to replace the Merit-Based Incentive Payment System (MIPS) track in the Medicare Quality Payment Program.
The proposal, under consideration by the Medicare Payment Advisory Commission, also would forgo patient-level outcomes measures, practice-improvement measures, and all measures of the meaningful use of electronic health records.
The goal is to lessen the reporting burden on physicians.
The Centers for Medicare & Medicaid Services is estimating that the reporting burden for the MIPS program is $1 billion in 2017 alone, MedPAC staff member Kate Blonairz said at a Dec. 7 MedPAC meeting.
The decision to move to outcomes also would take away any reporting on process measures, leaving physicians with more freedom to choose how they reach the outcomes.
Certain previously discussed provisions remain in the proposal, such as withholding a percentage of Medicare fee-for-service payments for clinicians who are not part of an advanced Alternative Payment Model (APM) practice, and giving them the opportunity to earn the funds back via the new Voluntary Value Program (VVP).
The proposal also would remove certain income and beneficiary thresholds in the APM track to expand eligibility and improve retention.
The proposal, which is slated to be refined a little more before being voted on in a January meeting, continued to receive near consensus support from MedPAC commissioners, but concerns were raised.
In particular, the move to a population-based reporting scheme as the way to track and reward performance creates a scaling problem, noted Commissioner David Nerenz, PhD, of the Henry Ford Health System of Detroit.
Virtual reporting groups would be created, and the physicians would be rewarded or penalized based on the numbers reported by that group. However, to get meaningful differences in the reported populations outcomes, Dr. Nerenz noted that the groups will have to be very large.
For example, to detect a 13% difference in readmission rates, you would need 200 cases for each group, he pointed out.
“If I have 200 cases, I can detect a difference of 13% and 0 or I can detect a difference between 13% and 26%, but I sure as heck can’t detect a difference, say, between 13% and 16%,” Dr. Nerenz said, noting that if he wanted to get the difference between 13% and 16%, he would need approximately 7,000 discharges in each group.
The size of the virtual groups, the kinds of outcomes measures, and other fine details would be left to the Centers for Medicare & Medicaid Services to decide via rule making under the current MedPAC proposal.
Commissioner Alice Coombs, MD, of South Shore Hospital, Weymouth, Mass., continued to voice her objection to even the idea of repealing MIPS, noting that the APM reporting model might not line up with value-based purchasing, and process measures would still be in play for APMs; some process measures are actually good in improving quality of care, she argued.
Rita Redberg, MD, of the University of California, San Francisco, called for speedy action on the proposal.
“The time to get rid of MIPS is now because ... as I listen to people, the only thing people say is, well, they have already started getting ready for MIPS,” Dr. Redberg said. “It is not a good reason to continue a terrible system, but the longer it goes on, the more we will hear that.”