PT practices participating in MIPS—Medicare’s Merit-based Incentive Payment System—have probably heard talk about soon-to-come changes to the fledgling federal Quality Payment Program.
In response to feedback from MIPS early adopters who felt the system’s reporting requirements were confusing and complex, CMS announced in late 2019 that it would eventually transition to a new version of the program called “MIPS Value Pathways.”
MIPS Value Pathways, or MVPs for short, the agency said at the time, would “transform MIPS” to make participation “more cohesive and less burdensome, and more meaningful to every clinician.” The revised program would take the “siloed” activities and measures then in use for MIPS reporting, and replace them with sets of measures that better matched a clinician’s scope of practice. For physical therapists, this would mean you would no longer have to choose the measures and activities you use to report for the MIPS “Quality” and “Improvement Activities” performance categories. Instead, you would report with a single MVP tailored to the set of services a PT might normally provide for a patient with a specific clinical condition.
Starting Date Pushed Back to 2022
Medicare had originally intended to make MVPs optional beginning with the 2021 MIPS performance period, but then the pandemic arrived and they decided to put the framework on hold. At this point, barring further delays, the new program should be available to those who want to use it on January 1, 2022.
One major reason for the delay had to do with Medicare’s need for “MVP candidates.” The agency is relying on MIPS stakeholders, including clinicians and their professional associations, to propose MVPs they believe will work well for their specialties. With providers focused on meeting the challenges posed by the pandemic, it was clear they lacked the time to develop MVPs—or to prepare to use them in 2021.
For PT practices currently participating in MIPS, all of this means you should continue to do what you’ve always done for reporting. But also keep in mind that MVPs are around the corner, and that now is your chance to help shape the MIPS Value Pathways that may come into play for physical therapy.
A Chance to Contribute
If you are interested in developing MVP candidates for physical therapy, you can do so as an individual, in collaboration with other PT practices, or through a professional association like the APTA. CMS has not provided MVP-submission advice specifically pertaining to PTs, but in the CY 2021 Physician Fee Schedule final rule, it did note it was “open to considering candidate MVPs that are created utilizing the MVP development criteria, for specialties including physical and occupational therapy.”
Those criteria are available for download on the agency’s Quality Payment Program website, but in general, CMS says, candidate MVPs should:
- Utilize measures and activities across all performance categories
- Have a clearly defined intent of measurement
- Have measure and activity linkages within the MVP
- Be clinically appropriate
- Be developed collaboratively across specialties in instances where the MVP is relevant to multiple specialties
- Be comprehensive and understandable by clinicians, groups, and patients
- Incorporate the patient voice
CMS asked that MVP candidates for the 2022 performance period be submitted by the end of February 2021, but that’s not to say the MVPs you propose won’t make it into the program at some point. You can submit your candidates whenever you have them ready using the template the agency created for that purpose. And if they don’t make the final cut for the list of MIPS Value Pathways available in 2022? You can always try again with another submission—or wait and see what happens in 2023.