How will this change the reporting process? Clinicians will no longer be required to select quality measures and improvement activities from a massive list of options. Instead, CMS will assign (or make available) a small list of MVPs to groups or clinicians, based on the provider’s specialty or patient panel. Clinicians will be trading choice and flexibility for a more standardized approach. All measures within an MVP are required.
CMS included four examples of possible MVPs in the Proposed Rule, including:
- Preventive health
- Diabetes prevention and treatment
- Major surgery
- General ophthalmology
Each includes four to five quality measures and two to three improvement activities. It is likely CMS will follow the same formula for other specialty-specific MVPs.
Can groups still participate together? Like the current MIPS program, group reporting will continue as an option for providers within a single TIN. For single-specialty groups, the transition will be relatively seamless, as a single MVP will likely apply to all members of the group. For multispecialty groups, however, CMS will likely require the group to report multiple MVPs. The logistics of that approach are not well defined, so look for more clarification on this during the next 18 months.
How will this change the way clinicians are scored? One of CMS’s guiding principles for MVPs is that they “should include measures and activities that would result in providing comparative performance data that is valuable to patients and caregivers in evaluating clinician performance and making choices about their care.” A chief complaint against MIPS as currently constructed is that there is no way to effectively compare performance across providers, because there is so much variability in what measures are reported. MVPs should address that by narrowing the scope of reporting. As a result, it is fair to expect a wider range of performance across any one MVP, and more variation across providers.
What is the timing for MVPs? CMS is proposing a transitional rollout of MVPs in 2021; it is expected that at least some MVPs will be defined and available for reporting. If a clinician does not have an applicable MVP by 2021, they would continue reporting MIPS as they currently do. In the Proposed Rule and various fact sheets, CMS refers to a 3- to 5-year complete transition period, during which MVPs will be modified and added.
The agency will accept comments through September 27. Any interested party may submit comments electronically via www.regulations.gov, referencing CMS-1715-P. The 2020 Final Rule will be published by the end of the year, likely before Thanksgiving.