MIPS Value Pathways (MVPs): Which Path is Right for You?

CMS is opening seven new pathways for eligible clinicians to participate in the MIPS performance-based reimbursement system. Here’s a breakdown of the new options, plus tips on how you can prepare.

The Merit-based Incentive Payment System (MIPS) will enter its sixth year in 2022. CMS intends to mark the occasion by opening seven new pathways for eligible clinicians to join the program, which provides extra reimbursements for participants that hit specific performance targets in treating Medicare patients.

The seven new pathways are part of the new MIPS Value Pathways (MVPs) program that CMS unveiled in its proposed Physician Fee Schedule rule for calendar year 2022.

In the proposed Physician Fee Schedule, CMS defined MVPs as "a subset of measures and activities, established through rule making, that can be used to meet MIPS reporting requirements." Further, the MVPs framework "aims to align and connect measures and activities across the quality, cost, and improvement activities performance categories of MIPS for different specialties or condition."

What does that agency-speak mean for you, a quality leader responsible for submitting MIPS measures to CMS? Let's break it down by describing what each of the new seven pathways are, what's required of you under each of the seven pathways in terms of reporting requirements and what MVPs means for the future of MIPS. We’ll end with a list of resources for you to access to learn more about MVPs and how Medisolv can help you hit a home run with those new reporting requirements.

A look at the seven new MIPS pathways

As you know, many eligible clinicians see the MIPS program as anything from “cumbersome” to “virtually unmanageable.” With MVPs, CMS clearly wants to make it easier for providers to participate in MIPS by creating seven options, or pathways, that best match a medical specialty, medical condition or episode of care.

The seven proposed pathways are:

1. Rheumatology
2. Stroke care and prevention
3. Heart disease
4. Chronic disease management
5. Emergency medicine
6. Lower extremity joint repair
7. Anesthesia

The seven proposed pathways would take effect in 2023, giving you a full year to choose your pathway, review your pathway's reporting requirements, update your internal workflows and prepare your health IT reporting systems.

For the 2023 and 2024 performance reporting years, the seven pathways would be open to individual clinicians, single-specialty group practices, multi-specialty group practices, subgroups, and alternative payment model entities. In 2025, CMS would require multi-specialty group practices to break down into subgroups to participate in one of the seven pathways. Ultimately, CMS said it wants to shut down traditional MIPS reporting after the 2027 performance year, replacing it completely with MVPs or the APP (Alternative Payment Model Performance Pathway)

"We recognized that the transition to MVPs will take time and we'll continue to evaluate the readiness of clinicians in making this transition, while balancing our strong interest in improving measurement, making MIPS more focused on value, and providing relevant, more granular data to patients when choosing a clinician," CMS said.

MVP Measure Categories

As a quality leader for a MIPS-eligible clinician, you would submit measures in five categories. The five categories are:

MVP Layer

1. Quality
2. Improvement Activities
3. Cost

Foundational Layer (MVP-agnostic)

4. Population Health
5. Promoting Interoperability

Which measures you submit depends upon the pathway you’ve chosen.

The measures in the first three categories would be specific to your pathway. You must choose measures from a list CMS has curated that relate to your MVP. The foundational layer contains your population health and promoting interoperability measures. These measure lists are the same regardless of which MVP you’ve chosen.

MVP reporting requirements

The requirements vary by category, as you are used to with traditional MIPS.

MVP Layer

1. Quality

a. Select and submit 4 quality measures (one must be an outcome measure)

2. Improvement Activities

a. Select and submit 2 medium-weight or 1 high-weight improvement activity

3. Cost

a. CMS will calculate performance exclusively on the cost measure included in the MVP using administrative claims data

Foundational Layer (MVP-agnostic)

4. Population Health

a. Select and submit 1 population health measure (results added to the quality score)

5. Promoting Interoperability

a. Submit the 4-5 required measures (varies depending on your situation)
b. Submit your EHR’s CEHRT ID
c. Conduct a security risk analysis on your 2015 Edition CEHRT functionality on an annual basis
d. Attest to the Prevention of Information Blocking and ONC direct review.
e. Attest to the Safety Assurance Factors for EHR Resilience Guides (SAFER Guides)

MVP Example

Here is an example of how this would look.

What about future pathways?

As we mentioned earlier, CMS stated that it wants to sunset traditional MIPS reporting after the 2027 performance year and move completely to MVPs. That's great if you're done with traditional MIPS reporting and if one of the seven pathways works for you. But what if you don't see your specialty in one of those seven?

Don't worry. CMS has established a process and a set of criteria to open additional pathways before traditional MIPS reporting goes away.

"We recognize that there are many types of MVPs we need to develop and that the traditional MIPS framework is needed until we have a sufficient number of MVPs available," CMS said. "Through the MVP development work, we'll gradually implement MVPs for more specialties and subspecialties that participate in the program."

Until then, here's a short checklist of what you should do now:

• Familiarize yourself with CMS' new MVPs program including the category requirements
• Familiarize yourself with the seven proposed MVPs
• Decide whether one of the pathways is right for you
• If so, update your internal workflows to capture the specific pathway data you need
• Then update your health IT systems to report the quality measure on your pathway

With the right preparation, you can take advantage of one of the new pathways and improve both your clinical and your financial performance under MIPS and become your group's most valuable player.

Here are links to resources to help you find your pathway:

• A list of the measures by MVP type.
• Proposed Physician Fee Schedule for calendar year 2020 
• CMS fact sheet on changes to quality payment program proposed under the Physician Fee Schedule 
• CMS overview of seven proposed MVPs 
• CMS process for creating future new MVPs 
• Medisolv MIPS quality-reporting software