CMS Proposes New MIPS Value Pathways in 2020 Physician Fee Schedule Update

On July 29, the Centers for Medicare & Medicaid Services (CMS) released its proposed changes to the Physician Fee Schedule (PFS) in the Calendar Year 2020 Revisions to Payment Policies under the Physician Fee Schedule and Other Changes to Part B Payment Policies Notice of Proposed Rulemaking (NPRM). The NPRM outlines several major updates to policy, payment and quality provisions set to begin on January 1, 2020.

In addition to annual updates of PFS rates, CMS is proposing significant changes to improve the Quality Payment Program (QPP) by streamlining the program’s requirements with the goal of reducing clinician burden. These proposed changes include a new, simple way for clinicians to participate in the Merit-based Incentive Payment System (MIPS). This new framework called the MIPS Value Pathways (MVPs), beginning in the 2021 Performance Period, would move MIPS from its current state, which requires clinicians to report on many measures across the multiple performance categories, such as Quality, Cost, Promoting Interoperability and Improvement Activities, to a system in which clinicians will report fewer measures.

CMS notes that MVPs would allow CMS to provide more data and feedback to clinicians, resulting in the greater ability to send and receive data and ultimately help clinicians quickly identify strengths in performance as well as opportunities for continuous improvement in order to deliver the best patient outcomes. Starting in 2021, CMS is proposing eligible clinicians (ECs) report on a smaller set of measures (MVPs) based on specialty and outcomes in alignment with new alternative payment models (APMs) and the Medicare Shared Savings Program.

MVPs will also incorporate a foundation of promoting interoperability and administrative claims-based population health measures, layered with specialty/condition specific clinical quality measures. ECs will be measured on a unified set of measures and activities around a clinician condition or specialty, built on a base of population health measures, which would be included in virtually all of the MVPs.

CMS is seeking feedback via an official Request for Information on the MIPS Value Pathways. The RFI feedback will allow CMS to provide additional details of the methodology in 2020’s PFS rulemaking cycle. CMS is seeking comments on the best ways to identify which MVPs should be reported by multispecialty groups and how to balance the need for information at the individual clinician level with the burden of reporting.

CMS Guiding Principles on MVPs

CMS presented the following guiding principles it will use to define MVPs:

• MVPs should consist of limited sets of measures and activities that are meaningful to clinicians, which will reduce or eliminate clinician burden related to selection of measures and activities, simplify scoring and lead to sufficient comparative data.
• MVPs 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.
• MVPs should include measures that encourage performance improvements in high priority areas and reduce barriers to APM participation by including measures that are part of APMs where feasible, and by linking cost and quality measurement.
• CMS is proposing to require that beginning with the 2020 Call for measures process, MIPS quality measure stewards must link their MIPS quality measures to existing and related cost measures and improvement activities, as applicable and feasible.
• Initially, CMS proposes that every MVP will have a uniform set or Promoting Interoperability measures consistent with current Promoting Interoperability MIPS performance measures.

In addition, CMS is proposing to pay for care management services, create stricter standards for Quality Clinical Data Registry reported measures for MIPS and adjust the MIPS scoring to put more emphasis on cost reduction, savings and Improvement Activities while reducing the impact of quality performance on the final score.

Additional Proposed Changes Related to Review and Verification of Documentation, and Telehealth Services

In line with the Patients over Paperwork Initiative, CMS acknowledged that regulatory requirements create undue burden related to the documentation of clinical encounters. To reduce burden, CMS is proposing broad modifications to documentation policies so that physicians, physician assistants, nurse practitioners, clinical nurse specialists, certified nurse-midwives could review and verify (sign and date), rather than re-documenting, notes made in the medical record by other physicians, residents, nurses, students, or other members of the medical team. Concerns related to documentation in this context is a major component of the dialogue related to reducing clinician burden.

Proposed Changes to Opioid Disorder Treatment Services and Medicare Telehealth Services

As it relates to Medicare coverage for opioid use disorder treatment services furnished by opioid treatment programs (OTPs), CMS is proposing to take the following actions to meet the statutory requirements of the Substance Use-Disorder Prevention Opioid Recovery and Treatment for Patients and Communities (SUPPORT) Act.

• Definitions of OTP and Opioid Use Disorder (OUD) treatment services
• Enrollment policies for OTPs
• Methodology and estimated bundled payment rates for OTPs that vary by the medication used to treat OUD and service intensity, and by full and partial weeks
• Adjustments to the bundled payment rates for geography and annual updates
• Flexibility to deliver the counseling and therapy services described in the bundled payments via two-way interactive audio-video communication technology as clinically appropriate
• Zero beneficiary copayment for a time limited duration

Additionally, for calendar year 2020, CMS is proposing to add a number of codes for telehealth services that would allow for bundled payment for OUD treatment.

HIMSS is currently analyzing the health information and technology implications of this proposed rule and intends to submit formal comments prior to the September 27, 2019, deadline. For more information on this proposed rule, you can refer directly to the official CMS prepared a fact sheet titled Proposed Policy, Payment, and Quality Provisions Changes to the Medicare Physician Fee Schedule for Calendar Year 2020.