We’re taking a closer look at MIPS Value Pathways (MVPs) in this week’s episode of Ask Dr. Mingle.

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Questions and Answers in this Episode

This episode features four questions from Linda, with each question pertaining to an aspect of the MIPS Value Pathways (MVPs) framework announced by CMS and its implementation for specialty practices and groups.

Question One: “For 2023, if our organization chooses to report one of the MVPs for one of our specialties and we also submit traditional MIPS as a group, will CMS grant us the higher of the two scores?”

• It’s a great idea to use MVPs early if you can. This extra time will allow you to work out the bugs and challenges in your systems to ensure you’re recording data appropriately.
• There is some risk with this strategy, though. Dr. Mingle mentions that he’s confident that CMS intends to grant the higher of the two scores to the whole group. But, this is the program’s first year, and this is the type of thing that CMS could get wrong.
  • We’ll have a clearer picture with CMS’s next round of rules. Now that the 2023 Proposed Rule is out, we’ll have a better understanding of MVPs and a chance to give our feedback to CMS.
• Linda’s organization (and anyone in a similar circumstance) has two options:
  • Submit both (MVP and Traditional MIPS) and if you suffer from the lower score, request a Targeted Review from CMS.
  • If you are a Mingle Health customer, you can prepare both submissions, and we’ll score each submission for you, so you know which is the better option for your situation.

Question Two: “What should we expect about the dynamics of mandatory subgroup reporting? We have ten specialties. It seems like a monumental burden to have to submit ten MVPs.”

• Likely, MVPs will significantly increase the burden for multi-specialty practices. But, MVPs should make things easier for single-specialty practices.
• MVPs drop the number of required quality measures from six to four. But groups with multiple specialties will probably have to submit an MVP for every individual specialty.
• Some dynamics that could reduce the impact of MVPs for multi-specialty groups:
  • Some MVPs will presumably apply to multiple specialties. If you have MVPs applicable to multiple specialties, you may be able to lump some of your specialties into a single subgroup submission.
  • A minimum number of providers will likely be required to form a subgroup. It’s improbable that a single physician in a specialty will be required to make an MVP submission.
  • There will be many specialties that don’t have a relevant MVP and many specialty providers that don’t fit their specialty MVP. In these cases, a generic MVP may be available, or these specialties could use the Traditional MIPS reporting method.

Question Three: “If we voluntarily report an MVP and submit as a group, can the MVP providers report both ways or do we have to carve them out so that they only report the MVP?”

• MVP reporting will likely apply to an entire group for the first year of MVPs (and possibly additional years, as the timelines for the start of this new framework could change).
• Again, a great strategy is to submit an MVP and Traditional MIPS in the first year and expect the best score to be applied to the group.

Question Four: “Looking at the MVP we intend to submit, we can only report three of the four MIPS CQM Quality Measures. Will we have to add the complexity and cost of a QCDR vendor to assure we can choose four MVP quality measures?”

• Things could change with subsequent rules from CMS, but it seems clear that four quality measures will be required for MVP submissions, and the measures must meet Data Completeness and Case Minimum requirements.
• If a QCDR is required to get to four measures, then a specialty group may need to engage multiple QCDRs – one for each specialty.
• Again, early engagement and planning are beneficial. The earlier you start working on your MVP submission plans and understanding your needs concerning additional QCDR reporting, the better prepared you’ll be for your submission.

Send us your value-based care questions!

Have a question for Dr. Mingle? If you’d like to ask a question about MIPS, Primary Care First, ACO quality reporting, or any other Alternative Payment Model, you can reach out to us in three ways:

• You can leave your questions in a YouTube comment under any episode of “Ask Dr. Mingle.”
• On LinkedIn, leave your questions in a comment on any of our posts.
• And you can reach out directly by sending an email to hello@minglehealth.com. Please put “Ask Dr. Mingle” in the subject line when you submit your questions via email.

Want to learn more about the MIPS program in 2022?

Click the button below to access the recording of our latest webinar - "The Hardest Year Yet: Your MIPS Success in 2022" - where Dr. Dan Mingle provides an in-depth exploration of the MIPS program this year.

Access the Webinar Recording