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In July, the Centers for Medicare and Medicaid Services (CMS) proposed a number of changes to its Quality Payment Program and the Merit-based Incentive Payment System (MIPS). Under existing MIPS policy, clinicians are evaluated based on performance in the four separate domains of quality, improvement activities, cost, and promoting interoperability. Stakeholders, including physicians and policy groups, have voiced concerns about MIPS as currently designed.
The most significant proposed change for 2020 is the introduction of a new “MIPS Value Pathways” (MVPs) framework that CMS intends to use to modify its approach of engaging and evaluating MIPS clinicians. In this post, we review early concepts and examples of MIPS value pathways and argue that a key, rate-limiting factor in implementing clinically meaningful MVPs is the availability of validated episodic cost measures that can be used within value pathways.