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

QPP entered its seventh year in 2024. Traditionally, organizations could report to CMS under the MIPS (Merit-based Incentive Payment System) framework. This program was started as a way to streamline reporting requirements for clinicians and provide the public with visibility into clinician performance.

One of the biggest shortfalls of the program is that it lumped all of the specialists into a group, and the usual MIPS measures were almost never reported for the specialists within a group. The MVP reporting framework changes that.

MVP is short for MIPS Value Pathways. It is the newest way to meet your QPP reporting requirements. It is organized by specialty and contains measures relevant to that specialty group.

CMS introduced MVPs in the 2022 Physician Fee Schedule (PFS) final rule, 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 conditions."

How the MIPS Value Pathways Workload is Different (and Harder)

While traditional MIPS reporting is a lot of work, it looks like child’s play next to the MVP reporting requirements.

Keep in mind, the whole point of MVP reporting is to start measuring the performance of specialists within your practice, such as rheumatologists and neurologists, who have, under traditional MIPS, been allowed to fly under the radar and reap the rewards (or penalties) of practice-wide measures that are largely irrelevant to them.

The MVP framework’s use of specialty-focused “pathways”—of which there are currently 16—changes all of that. Each pathway that your practice reports on will require its own subgroup of clinicians, its own measures, and its own submission.

The Workload Burden: Traditional MIPS vs MVPs

Below is an example of a real-life Medisolv client that we are using for illustration of MVP complexity. Note that this isn’t a very big group. Even in this small example, the one group goes from doing one submission and tracking 14 eCQMs to doing six subgroup submissions and tracking 24 measures of various collection types.

A look at the 2024 Available MVPs

You can register for one or more of the MVPs between April 1-November 30, 2024. Below are the 16 finalized available MVP options for 2024. Medisolv is supporting the top four MVPs in 2024, which means we can submit these on your behalf. Medisolv will eventually be supporting all MVPs so let us know which ones you want to report next year.

Medisolv Supported MVPs

1. Adopting Best Practices and Promoting Patient Safety within Emergency Medicine
   Emergency Medicine, Nurse practitioners, Physician assistants

2. Advancing Cancer Care
   Oncology, Hematology, Nurse practitioners, Physician assistants

3. Focusing on Women's Health (NEW)
   Gynecology, Obstetrics, Urogynecology, Certified nurse-midwives, Nurse practitioners, Physician assistants
   
4. Value in Primary Care (Formerly Promoting Wellness and Optimizing Chronic Disease Management)
   Preventive medicine, Internal medicine, Family medicine, Geriatrics, Cardiology, Nurse practitioners, Physician assistants
   

Additional MVPs

1. Advancing Care for Heart Disease
   Cardiology, Electrophysiology, Internal Medicine, Family Medicine, Nurse practitioners, Physician assistants
   

2. Advancing Rheumatology Patient Care
   Rheumatology, Nurse practitioners, Physician assistants

3. Coordinating Stroke Care to Promote Prevention and Cultivate Positive Outcomes
   Neurology, Neurosurgical, Vascular Surgery, Nurse practitioners, Physician assistants

4. Improving Care for Lower Extremity Joint Repair
   Orthopedic Surgery

5. Musculoskeletal Care and Rehabilitative Support (NEW)
   Chiropractic, Physiatry, Physical therapy, Occupational therapy, Nurse practitioners, Physician assistants

6. Optimal Care for Kidney Health
   Nephrology, Nurse practitioners, Physician assistants

7. Optimal Care for Patients with Episodic Neurological Conditions
   Neurology, Nurse practitioners, Physician assistants

8. Patient Safety and Support of Positive Experiences with Anesthesia
   Anesthesiology, Nurses anesthetist, Anesthesiology physician assistant

9. Prevention and Treatment of Infection Disorders Including Hepatitis C and HIV (NEW)
   Infectious disease, Immunology, Nurse practitioners, Physicians assistants
10. Quality of Care for Ear, Nose and Throat Disorders (NEW)
    Otolaryngology, Audiologists, Nurse practitioners, physician assistants
11. Quality of Care in Mental Health and Substance Use Disorders (NEW)
    Mental/behavioral health, Psychiatry, Clinical social workers, nurse practitioners, Physician assistants

12. Supportive Care for Neurodegenerative Conditions
    Neurology, Nurse practitioners, Physician assistants

The pathways are available in 2024. You should use the full year to choose your pathway, review your pathway’s reporting requirements, update your internal workflows, and prepare your health IT reporting systems.

In 2024, the 16 pathways are open to individual clinicians, single-specialty group practices, multi-specialty group practices, subgroups, and alternative payment model entities. In 2026, if you choose to participate in MVPs, CMS will require multi-specialty group practices to report on all specialists within your TIN. Which means each specialty would form a subgroup and that sub-group must have a separate submission.  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

Unlike Traditional MIPS, your organization must submit measures in five categories (instead of four). 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 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 four quality measures (one must be an outcome measure)

2. Improvement Activities

a. Select and submit two medium-weight or one high-weight improvement activity

3. Cost

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

Foundational Layer (MVP-agnostic)

4. Population Health

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

5. Promoting Interoperability

a. Submit the four to five 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. This is the Adopting Best Practices and Promoting Patient Safety within Emergency Medicine MVP.

What about future pathways?

As we mentioned earlier, CMS stated that it wants to sunset traditional MIPS reporting sometime in the near future and move completely to MVPs. That’s great if you’re done with Traditional MIPS reporting and if one of the 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' MVPs program including the category requirements
• Familiarize yourself with the 16 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 financial performance under MIPS.

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

• A list of all available MVPs on QPP's website
• Medisolv's MVP Reporting Bundle (Requirements eBook, Excel workbook with every MVP)
• Medisolv's MVP Selection Worksheet
• CMS process for creating future new MVPs 
• Medisolv's MVP Reporting Package