Medicare Compliance & Reimbursement

If you meet the low-volume threshold to participate in the Merit-Based Incentive Payment System (MIPS) for the 2023 performance year, you may want to consider the MIPS Value Pathways (MVPs) option — while it’s still voluntary to do so.

Reminder: The MACRA-mandated Quality Payment Program (QPP) was designed to promote value-based, cost-effective care. Participating providers are incentivized with performance-based payment adjustments for services rendered to Medicare beneficiaries. If these MIPS-eligible clinicians necessary measure and activity requirements for a performance year in a timely manner, they receive a positive adjustment to their Medicare payments. If they don’t meet the program requirements, they can expect a negative adjustment.

If you’re considering the switch to MVPs for 2023, check out these seven key points.

1. MVP reporting isn’t required … yet. Originally, traditional MIPS and Alternative Payment Models (APMs) were the available tracks for participation in the QPP, but the CY 2022 Medicare Physician Fee Schedule final rule added MVPs as a voluntary reporting option starting in 2023.

The Centers for Medicare & Medicaid Services (CMS), however, intends to eventually replace traditional MIPS with MVPs down the line. “Starting in 2026, any multispecialty groups intending to report MVPs will be required to report as subgroups,” QPP guidance says. “CMS plans to sunset traditional MIPS in the future, at which point MVPs will become mandatory unless the clinician is eligible to report the [APM Performance Pathway] APP.”

2. MVPs focus on specialty and condition. MVPs give providers a more differentiated approach to administering and attesting to quality care “offer[ing] clinicians a subset of measures and activities relevant to a specialty or medical condition,” the 2023 MVPs Implementation Guide says. The primary reasoning behind MVPs is to offer providers a way to showcase coordinated, connected care that allows for more meaningful reporting.

3. There are five reporting options. If you plan on submitting measures for PY 2023, there are five different provider types: individual MIPS-eligible clinician; single specialty group; multispecialty group; subgroup; and APM entity.

“Single specialty group is defined as a group that consists of one specialty type as determined by Medicare Part B claims” while a “multispecialty group is defined as a group that consists of two or more specialty types determined by Medicare Part B claims,” according to the 2023 MVPs Implementation Guide. “A subgroup is a subset of clinicians within a group (identified by a single Taxpayer Identification Number, or TIN) which contains at least 2 clinicians, 1 of whom is an individually eligible MIPS eligible clinician,” the guidance notes.

4. Some provider types require an LVT. Just like traditional MIPS, eligible single and group providers will need to meet the low-volume threshold (LVT) to participate in MVPs. In order to be eligible, clinicians must provide fee schedule-approved covered professional services during both 12-month segments. CMS looks to see if you meet all three of these LVT standards during those MIPS determination periods:

• Bill $90,000 in Part B allowed charges;
• Administer care to at least 200 Part B beneficiaries; and
• Provide at least 200 covered fee-schedule services to Part B patients.

But, here’s where it gets tricky. Affiliated groups who want to participate as MVP subgroups must “exceed” the LVT at the group level and “will also inherit any special statuses (e.g., hospital-based or non-patient facing) assigned to their affiliated group,” MVP guidance says. However, these same subgroups’ LVT or special status won’t factor into the MVP evaluation at the subgroup level, rather the affiliated inherited group’s eligibility and special statuses will, the guide explains.

Remember, APM entities don’t need to meet LVTs for traditional MIPS or MVPs. Check your MIPS or MVPs eligibility at https://qpp.cms.gov/participation-lookup.

5. MVP reporting requires registration. MVPs do offer greater quality reporting flexibility and specialty options — but getting started is more complicated than traditional MIPS and there is much to do before you can even report.

First, after figuring out if you meet the MVP participation requirements, you then must register, which is different from traditional MIPS. Plus, you need to have all your ducks in a row before beginning the registration process. For example, eligible clinicians are required to have the following materials and data already collected for registration, according to QPP guidance:

• A designated QPP security official for your organization to complete the MVP registration;
• The list of MVPs you intend to report;
• The outcomes-based administrative claim(s) you plan to include as part of your four quality measures;
• The CAHPS for MIPS survey you plan to include as part of your four quality measures;
• The population health measure you want to be evaluated on by CMS; and
• The participation type you are registering under and all additional administrative information related to that.

Timeline: As you compile the necessary elements for MVPs, know that CMS has a registration window that runs from April 3 to Nov. 30, 2023. Register at https://qpp.cms.gov/mips/mvps/ prepare-for-mvp-registration.

6. CMS requires fewer MVPs measures for PY 2023. If you intend to report MVPs for the 2023 performance year, you’ll be able to “select, collect, and report on a reduced number of quality measures and improvement activities (as compared to traditional MIPS),” but you’ll need to report the entire Promoting Interoperability measure set, the guide continues. CMS will collect and evaluate your cost and population health measures for you for PY 2023.

7. Review the PY 2023 available MVP measures. Before you go all in and register for MVPs, you should investigate the 12 MVPs, which were finalized under the Medicare Physician Fee Schedule. On the QPP website and in the MVP Implementation Guide appendices, CMS offers “details about the quality measures, improvement activities, and cost measures available in each MVP, along with the Promoting Interoperability measures and population health measures included in the foundational layer of every MVP,” guidance reminds.

If you cannot find an MVP that meets your specialty or the condition you want to report, you can always submit measures for traditional MIPS or the APP. Find the PY 2023 MVPs at https://qpp.cms.gov/mips/explore-mips-value-pathways.