In this week’s edition of Ask Dr. Mingle, Dr. Dan Mingle provides an overview of MIPS Value Pathways (MVPs) in 2023, covering the basics of how they work, eligibility, thoughts on when to convert to MVPs, and more.
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Question One: How MIPS Value Pathways (MVPs) Work
Kyle asks: “In this session of Ask Dr. Mingle, you are answering questions about MIPS Value Pathways (MVPs). Can you remind me how MVPs work?”
2023 is the first Performance Year that MIPS providers can choose to submit MVPs.
“MVP” stands for “MIPS Value Pathway,” and it’s kind of a cross between Specialty Measure Sets and Eligible Measure Applicability measure sets. Specialty Measure Sets suggest a set of measures that apply to specific specialties. EMA measure sets define measures that apply to certain clinical topics that often cross specialties.
As I look over the first 12 available MVPs, I see more emphasis on clinical topics than specialties. Even when an MVP looks to be specialty specific, it typically represents a single clinical topic addressed by that specialty.
The upshot is:
- There are likely to be multiple MVPs that apply to any particular specialty.
- Many MVPs will apply to multiple specialties contributing to care for the topic.
To submit an MVP:
- You’ll need to register for your MVP submission.
- Registration will open on April 1st every year.
- And close on November 30th.
- You can change your MVP selection any time before the end of the registration period.
- The exception is if the MVP you choose includes the option of the CAHPS survey, you have to register for the MVP and CAHPS by June 30th.
- You can’t add CAHPS as a measure after June 30th.
- You can still change your MVP selection through November 30th.
- You could abandon CAHPS if you had previously selected it.
- When you register, you will:
- Select your MVP.
- List the provider NPIs you will assign to the subgroup that takes credit for the MVP.
- Select one of the two population health measures that apply to all MVPs.
- Add any outcomes-based administrative claims measures you would like to include in your submission if available to the MVP.
- Add CAHPS, if available and you want to do it.
- When you submit your MVP:
- You’ll submit four of the available quality measures, including administrative claims if previously elected.
- And CAHPS, if previously elected.
- You’ll submit Improvement Activities from the MVP selection.
- And Promoting Interoperability for everyone in your organization.
- And CMS will calculate all applicable Cost measures for you.
- If none are applicable, CMS will redistribute those points.
Question Two: Converting to MIPS Value Pathways (MVPs) in 2023
John asks: “Should we be converting to MIPS Value Pathways (MVPs) in 2023?”
CMS has been working on MIPS Value Pathways, MVPs, for several years, and twelve of them are ready and available for use for the 2023 Performance Year.
They are available, but you aren’t required to use them.
CMS has proposed a timeline that has us ending “traditional MIPS” and switching to only MVPs by the 2028 Performance Year.
That is just a proposal and isn’t set in the rules. You can be pretty sure the switch won’t happen before 2028, but there is a big chance it could be further out.
Between now and whenever we switch over:
- You should expect MVPs to be available but optional.
- And you should expect the available MVPs to grow every year.
While you don’t have to use MVPs for 2023, it’s a great idea.
Everyone should be working on more measures than needed for a complete traditional MIPS submission. It makes sense that the extra measures you work on also introduce you to and prepare you for the “Next MIPS” that we expect to be based on MVPs.
With few exceptions, measures you would choose for any MVP are also Traditional MIPS measures. The few exceptions are so closely related to traditional MIPS measures that they are a good use of time.
An interesting temporary aspect of MVPs is that, like a traditional MIPS submission, one MVP can be used for your whole group, regardless of specialty or universal applicability to all your providers. In MIPS so far, we are accustomed to the concept of the MIPS Halo Effect. The score applies to everyone if the group meets case minimums and data completeness criteria for any measure. That is just as true for MVPs through at least the 2025 Performance Year.
Here’s my advice: For the 2023, 2024, and 2025 Performance Years, make a traditional MIPS submission and make an MVP submission and apply it to your whole group. Medicare will give you credit for the better of the two scores.
Question Three: MVP Eligibility
Jean asks: “There are twelve MIPS Value Pathways (MVPs) available for 2023. How do I know which ones I am eligible to use?”
CMS has published specifications for each MVP, and you can find the specs on the qpp.cms.gov website.
- Each MVP has a statement in the header: “Clinicians Who Practice in the Following Specialty May Want to Consider Reporting This MVP.”
- After that statement, there is a list of one or more specialties that CMS believes that particular MVP applies to.
MVP applicability is similar to individual measures in traditional MIPS, and it’s also similar to Specialty Measure Sets in traditional MIPS. Assignment to specialties is a guideline, not a requirement.
The only requirement is that each measure, to receive a score, has to meet case minimums. In most measures, that means 20 eligible patients or visits. Each measure also has to meet data completeness requirements.
From Medicare’s standpoint, it’s desirable that the measure also applies to you. If you are familiar with MIPS measure specifications, you will realize that you can have patients and visits that qualify for a measure, even if you don’t provide the care the measure is measuring.
But Medicare, for the most part, lets you judge if the measure applies to you. The closest Medicare comes to evaluating measure applicability is to assume that submission of specific measures implies that certain other measures also apply to you. CMS designed the Eligible Measure Applicability (EMA) process to implement this principle.
If you have engaged Mingle to help you with your quality submission, we analyze your claims to determine measure eligibility. With a significant degree of certainty, we can tell you upfront which measures meet case minimum standards. We can also tell you in which MVPs there are at least four measures your group can submit.
Question Four: Submitting Multiple MVPs
Greg asks: “Can my group submit more than one MVP for 2023?”
You can submit more than one MVP.
The limitation is that any particular TIN-provider can submit or be part of only one MVP.
It’s okay for a provider to have an MVP submission and a traditional MIPS submission. You’ll benefit from the best applicable score, but Medicare only accepts a single MVP for any particular provider.
If your group does one MVP, either alone or alongside a traditional MIPS submission, the MVP can apply to all of the group’s providers. But to do two MVPs, you must assign your providers to two distinct and unique subgroups, with a different MVP assigned to each subgroup. The only other requirement is that for measures chosen for each subgroup MVP, the submission has to meet case minimums and data completeness criteria.
Note that it is not a requirement that each provider assigned to each subgroup and MVP contributes patients to the measures.
And a reminder: From Medicare’s perspective, a provider is defined not only by their National Provider Identifier (NPI) but also by the TIN-NPI. Medicare defines a practice by a Tax ID Number (TIN) that bills for and collects payments for one or more TIN-provider’s services. A provider who works in multiple TIN practices has MIPS obligations and the full array of MIPS choices relative to each practice.
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As MIPS becomes more difficult, it's crucial to have a plan in place. We've made a guide that provides an overview of 2023 MIPS requirements and changes to help you and your organization find success in the 2023 Performance Year.