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MIPS Value Pathways (MVPs): Should I Start Now?


If you’ve been following the rollout of the MIPS Value Pathways (MVP) reporting framework closely, you’ve probably noticed that CMS has been playing coy with one critical piece of information: the official sunset date of traditional MIPS.

Dig back far enough—all the way back to the 2022 Medicare Physician Fee Schedule Proposed Rule—and you’ll see CMS’s original timeline, which indicated 2027 as the “considered” final year for MIPS and 2028 as the first year of mandatory MVP reporting.

Implementation Timeline

MVP Implementation Timeline

Proposal: 

CY 2023 MIPS Performance Period

As proposed at 414.1365(a), an initial set of MVPs are available for reporting; MVP reporting is voluntary.

For Future Consideration:

CY 2024-CY 2027 MIPS Performance Periods

The existing MVP portfolio would be gradually updated to include newly developed MVPs that are available for reporting. MVP reporting is voluntary.

End of CY 2027 MIPS Performance Period and Corresponding Data Submission Period

Considered sunset of traditional MIPS.

CY 2028 MIPS Performance Period, and Future Years

Considered mandatory MVP reporting.

Table Source: 2022 MPFS Proposed Rule

Since then, CMS has been decidedly more vague, citing only that it “aims to sunset traditional MIPS in a future year.” But if you look at the latest visual timeline that CMS has published, that “future year” still looks a lot like 2027.

MIPS-MVP-Transition

Image Source: CMS QPP Website

“So, what’s the point of all this timeline sleuthing?,” you may be asking. It’s simple: we don’t want CMS’s vagueness to lull you into a false sense of security. The transition to the MIPS Value Pathways framework is coming one way or another, and it will require a shockingly vast amount of work for your practice to get there and stay there.

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

Traditional MIPS

MVP

Practice reports as 1 group under 1 TIN

Practice is divided into multiple subgroups based on specialty under 1 TIN. Each subgroup will report one MVP as a subgroup.

1 group submission for your entire TIN

1 submission per MVP/subgroup within your TIN

Submit your 6 best-performing quality measures

Submit your 4 best-performing quality measures per each MVP/subgroup submission

A limited set of established practice-wide quality measures to choose from (most of which you’re probably already tracking)

A vast selection of new MVP/subgroup-specific measures to choose from (most of which you’ve probably never tracked before)

Four categories: Quality, Improvement Activities (IA), Promoting Interoperability (PI), and Cost

Five categories: Quality, Improvement Activities (IA), Promoting Interoperability (PI), Cost, and Population Health

Single-group reporting for IA and Cost categories

MVP/subgroup-specific reporting for IA and Cost categories


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.

Splitting-out-TIN

It’s a head-spinning amount of work, to say the least. But don’t hit the panic button just yet. There’s a way you can use these next few years very wisely. Let’s break it down.

The Medisolv 5-Year Transition Plan for MVP Success

If Medisolv had one quality reporting mantra, it might be “just say yes to voluntary reporting!” Based on the assumption that CMS will sunset traditional MIPS at the end of 2027, our recommendation for the MVP framework is no different.

But in order to begin voluntary reporting, there is one other important deadline we need to point out. In 2026, subgroup reporting will be mandatory for any multi-specialty practice that intends to report MVPs that year. (The CMS visual timeline we mentioned above can help you keep track of it all.)

Our 5-year transition plan for MVP success accounts for this deadline, and much more. In fact, if you follow this plan, you should be so in control of your MVPs that you’re able to make calculated moves within each pathway to optimize your performance. Here’s how to get there.

Year 1 (2024) - Start With 1 MVP

Ease into the framework by testing 1 MVP this year. This will allow you to get familiar with the requirements and processes involved in MVP reporting and identify any challenges or gaps in your data collection and clinical workflows.

Medisolv recommends starting with the Value in Primary Care MVP because it’s very similar to traditional MIPS and includes quality measures identical or similar to those you most likely already have in place, like Diabetes: Hemoglobin A1c and Screening for Depression.

Keep in mind that there is an annual MVP registration process, and you must register to report by November 30th of this year. However, you do have two safety nets in place to protect you after you register: you can choose to back out of MVP reporting (provided you do so by the same November 30th deadline) or you can submit under a second reporting framework (e.g., Traditional MIPS) and CMS will honor whichever score is better.

Year 2 (2025) – Test Drive 2-3 Less-Familiar MVPs

Once you have that first MVP under your belt, we recommend adding 2 to 3 more MVPs to your program. This will allow you to test drive the process of setting up and tracking quality measures that are unfamiliar territory for your practice. It will also give you a broader base of data to work with so you can begin to identify trends and patterns in your performance. We recommend strategically selecting the MVPs that you know will be most challenging and/or essential to your success come 2028.

Year 3 (2026) – Fully Assign All Subgroups

It’s time to activate all your subgroups because...well, CMS is making you do it! This is the year that subgroup reporting becomes required as part of your voluntary MVP process. This means each eligible clinician in your practice must be accounted for and assigned into a relevant subgroup, and each subgroup must submit its relevant MVP.

Each clinician can only participate in one subgroup per practice. However, clinicians who wish to report multiple MVPs can do so by also reporting at the individual, group, or APM level. CMS has outlined a number of hypothetical scenarios at the bottom of this page to help you understand all the participation options. Be sure to subscribe to Medisolv’s Education Center as we plan to provide more guidance on these alternate participation options in the near future.

Year 4 (2027) – Optimize Your Subgroups

Now that you’re firing on all MVP cylinders, it’s time to fine-tune your performance. The first, and obvious, step is to identify your low-performing measures within each MVP and create quality improvement initiatives around them.

But what you may not realize is that you can also experiment with moving clinicians from one subgroup to another to see how it impacts your results on any given MVP. Is internal medicine specialist Dr. Smith dragging down your performance in the Advancing Care for Heart Disease MVP? Try moving her to the Value in Primary Care MVP to see what happens. CMS is intentionally broad in defining which types of specialists should align with which MVPs because they want to encourage learning and experimentation.

Year 5 (2028) – Transition to Mandatory Reporting with Confidence

By now you’ve gotten enough reps in with the MVP framework that handling CMS’s transition to mandatory reporting should be a relative breeze. Use this time to further optimize your measure performance and refine your sub-groups. If you think you’re ready, add more quality measures to certain MVPs so that you have more, and possibly better, results to choose from come submission time.

Last but not least, pat yourself on the back for being such a well-prepared quality leader. Because of your hard work and commitment, your practice is more than ready for MVP success.

Need Help Getting Started?

Medisolv is here to help you on your MVP journey. We currently support the following MVPs and are intending to add more each year. Use our contact form to let us know which MVPs you’d like to see next, or to get help launching your practice’s MVP program. 

  1. Adopting Best Practices and Promoting Patient Safety within Emergency Medicine
    Emergency Medicine, Nurse practitioners, Physician assistants
  2. Advancing Care for Heart Disease
    Cardiology, Internal Medicine, Family Medicine, Nurse practitioners, Physician assistants
  3. Focusing on Women's Health
    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

More Medisolv Resources for Your MVP Success


 

Medisolv Can Help

This is a big year for Quality. Medisolv can help you along the way. Along with award-winning software, you receive a Clinical Quality Advisor that helps you with all of your technical and clinical needs.

We consistently hear from our clients that the biggest differentiator between Medisolv and other vendors is the level of one-on-one support. Especially if you use an EHR vendor right now, you’ll notice a huge difference.

  • We help troubleshoot technical and clinical issues to improve your measures.
  • We keep you on track for your submission deadlines and ensure you don’t miss critical dates.
  • We help you select and set up measures that make sense based on your hospital’s situation.
  • You receive one Clinical Quality Advisor that you can call anytime with questions or concerns. 

Contact us today.

 

 

Erin Heilman

Erin Heilman is the Vice President of Marketing for Medisolv, Inc.

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