CMS Quality Measure Development Plan: Supporting the Transition to the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs) (DRAFT)

CMS, December 18, 2015

Building on the principles and foundation of the Affordable Care Act, the Administration announced a clear timeline for targeting 30 percent of Medicare payments tied to quality or value through alternative payment models by the end of 2016 and 50 percent by the end of 2018. These are measurable goals to move the Medicare program and our healthcare system at large toward paying providers based on quality, rather than quantity, of care.

The passage of the Medicare Access and Children’s Health Insurance Program (CHIP) Reauthorization Act of 2015 (MACRA) supports the ongoing transformation of healthcare delivery by furthering the development of new Medicare payment and delivery models for physicians and other clinicians. Section 102 of MACRA requires that the Secretary of Health and Human Services develop and post on the CMS.gov website “a draft plan for the development of quality measures” by January 1, 2016, for application under certain applicable provisions related to the new Medicare Merit-based Incentive Payment System (MIPS) and to certain Medicare alternative payment models (APMs).

Merit-Based Incentive Payment System

Measures for use in the quality performance category are a specific focus of the MDP. MIPS will build upon existing quality measure sets from the Physician Quality Reporting System (PQRS), Value-based Payment Modifier (VM), and Medicare EHR Incentive Program for Eligible Professionals (EPs), commonly referred to as Meaningful Use.

To fill identified measure and performance gap areas, CMS will expand and enhance existing measures to promote alignment and harmonization in the selection of measures and specifications, while concurrently developing new (de novo) measures according to priorities described in Section IV.

To accelerate the alignment of quality measurement and program policies, MACRA sunsets payment adjustments for PQRS, VM, and the EHR Incentive Program and establishes MIPS.

Alternative Payment Models

MACRA establishes incentive payments for EPs participating in certain types of APMs. MACRA requires quality measures used in APMs to be comparable to the quality measures used in MIPS; therefore applicability of candidate measures to support a variety of future APMs is an important element of this MDP.

From the Conclusion

CMS is committed to reducing provider burden through the use of measures aligned across federal and private-payer quality reporting programs. We stress harmonization of data elements and specifications among measure developers, whose cooperation and sharing are essential to creating aligned measures. Toward that end, we also intend to leverage the optional pre-rulemaking process and MAP review for MIPS and to participate with other stakeholders in efforts that promote measure alignment. This draft MDP acknowledges the associated challenges and identifies opportunities for measure developers to share information to reduce duplication of efforts.

CMS Quality Measure Development Plan (MDP)
– 61 pages:
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/Draft-CMS-Quality-Measure-Development-Plan-MDP.pdf

MACRA, MIPS, APMs, MDP, and request for public comment:
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Value-Based-Programs/MACRA-MIPS-and-APMs/MACRA-MIPS-and-APMs.html

Physicians celebrated the passage of the Medicare Access and Children’s Health Insurance Program (CHIP) Reauthorization Act of 2015 (MACRA) since it brought an end to the much despised SGR (Sustainable Growth Rate) method of adjusting Medicare payment rates. Though SGR was rarely implemented, it carried forward a massive deficit that would have required major reductions in Medicare payment rates. Besides, MACRA included the reauthorization of the Children’s Health Insurance Program. The trade-off, which was largely ignored, was the requirement to establish the Merit-based Incentive Payment System (MIPS) and Alternative Payment Models (APMs). CMS has now released a draft of the Quality Measure Development Plan for transitioning to MIPS and APMs.

Perhaps the main reason that physicians, who happened to be aware of MIPS and APMs, were not concerned is that they replaced the Physician Quality Reporting System (PQRS), Value-based Payment Modifier (VM), and Medicare EHR Incentive Program for Eligible Professionals (EPs), commonly referred to as Meaningful Use. Many thought that this would bring efficiency to existing programs by coordinating them under MIPS.

There are three reasons that physicians should be concerned. The first is that these programs are not simply now coordinated, they are expanded and enhanced with the development of new de novo measures. Think of what that means for new administrative burdens added to existing ones.

Second, some physicians no doubt thought that they could escape the MIPS burdens since MACRA would allow physicians to move into Alternative Payment Models (APMs) – accountable care organizations, patient centered medical homes, or whatever. Don’t celebrate yet. MACRA requires that the quality measures used in APMs to be comparable to the quality measures used in MIPS. MIPS is now an obligation no matter where you turn.

Third, and most important of all, is that the PQRS, VM, and the EHR Incentive Program were highly flawed programs adding significantly to the excessive administrative burden that characterizes the U.S. health care system, while having a relatively negligible impact on improving health care quality. The proper policy step should have been to send these programs back to the drawing boards, and then when it became obvious that there was no there there, locking them in storage forever. The worst policy decision would be to expand these programs and force them on everyone, but that is precisely what they did.

Quality is not achieved by playing the alphabet games, with nominal penalties and rewards. It is achieved by instilling efficiency and equity into our health care delivery system. A well-designed single payer system does that. A paper written by a team led by Gordon Schiff, and published in JAMA two decades ago, defines quality and describes how it can be achieved by implementing a single payer national health program:

A Better-Quality Alternative: Single-Payer National Health System Reform

JAMA, September 14, 1994, Volume 272 Copyright 1994, American Medical Association

http://www.pnhp.org/publications/a_better_quality_alternative.php