MIPS Value Pathways

By Allison Evans, Assistant Managing Editor, September 1, 2022

In 2017, CMS launched the Quality Payment Program, which created two payment pathways for physicians: alternative payment models (APMs) and the Merit-based Incentive Payment (MIPS) program. While the goal of rewarding high-quality health care is a worthy one, the current program remains complex and burdensome for many physicians.

According to CMS, “We have heard from clinicians and stakeholders that MIPS remains overly complex. We have attempted to address some of these concerns during the last few years by reviewing MIPS and removing unnecessary elements to help streamline program requirements and reduce clinician burden.”

In the 2020 Physician Fee Schedule Final Rule, CMS finalized MIPS Value Pathways (MVPs) as a reporting framework that was meant to begin in the 2021 performance year and would gradually be expanded to replace the current MIPS program. The pandemic and subsequent public health emergency delayed the first layer of MVP implementation until 2023.

With 2023 in sight, dermatologists may be wondering what this new quality program is and how it will affect their practice. Academy member and staff experts discuss MVPs — the knowns, the unknowns, and how the Academy has already been working with CMS to ensure a smooth transition for dermatologists over the next several years.

What are MVPs?

“From what we know from CMS, the goal of MVPs is to map out a new framework intended to streamline MIPS by connecting activities and measures across the MIPS categories of quality, cost, and improvement activities for different specialties or conditions,” said Laura Vera, MSW, the Academy’s associate director of quality innovation. There is also a foundation layer that will be comprised of promoting interoperability measures and a population health measure calculated from claims-based measures, she added.

Each MVP contains activities and measures that will tie into a specialty, medical condition, or episode of care with the goal of providing more meaningful feedback to clinicians and more value to patients, said Margo J. Reeder, MD, FAAD, chair of the Academy’s MIPS Value Pathways Committee. MVPs will be an attempt to move away from siloed reporting of measures and activities toward focused sets of measures and activities that are more meaningful to a clinician’s practice, specialty, or public health priority.

“Currently, we might have a quality measure on psoriasis and an improvement activity on telehealth services,” Dr. Reeder said. “Clinicians may be reporting on unrelated diseases or episodes of care. It may make more sense to report in a coordinated manner.”

At least one cost measure will need to be included in the MVP, Vera said. “Cost measures can be included by the specialty that submit the MVP that aligns with the MVP focus area. If a physician is unable to meet the cost measure, the MVP will be re-weighted to quality.”

For the 2022 reporting year, the specialty has its first CMS-approved cost measure: melanoma resection. Having this cost measure may be useful in a future dermatology MVP, Vera explained, although topics and conditions for dermatology MVPs have not been decided (Learn more about the new cost measure).

CMS has stated that it is attempting to reduce clinician burden with this new iteration of quality reporting. Vera added that MVPs may reduce the reporting burden by requiring fewer measures to be reported as well as having fewer measures and activities to pick from. Although it may also be a double-edged sword as it may unintentionally make it harder for some dermatologists to choose measures relevant to their practice, explained Marta J. Van Beek, MD, MPH, FAAD, deputy chair of the Academy’s MIPS Value Pathways Committee.

Optional 2023 start

Beginning in 2023, eligible clinicians may choose to report through one of 12 CMS-approved MVPs (rheumatology, stroke care and prevention, heart disease, chronic disease management, emergency medicine, lower extremity joint repair, anesthesia, advancing cancer care, kidney health, episodic neurological conditions, neurodegenerative conditions, and promoting wellness). There are currently no MVPs developed for dermatology, although the Academy’s MIPS Value Pathways Committee will be working on developing an MVP as they work with CMS to learn more about the process and expectations.

“The current MVPs are not dermatology-specific, and we recommend dermatologists continue with traditional MIPS reporting until they are comfortable with an MVP that fits their practice and patient population,” Vera said.

“The current MVPs are not dermatology-specific, and we recommend dermatologists continue with traditional MIPS reporting until they are comfortable with an MVP that fits their practice and patient population.”

The Academy has advocated to maintain the traditional MIPS program, even after adequate MVPs are available. Although CMS intends for MVPs to become the only method to participate in MIPS in the future, CMS has not finalized a timeline for sunsetting traditional MIPS. Multispecialty groups will be required to form subgroups to report MVPs beginning in the 2026 performance year.

“MVPs will be slowly rolled out to the specialty,” Dr. Reeder said. CMS has noted that MVPs will be expanded over several years and that traditional MIPS will remain intact until all participating specialists have relevant MVPs to report.

AAD quality measures

Quality measures are constantly cycling in and out as measures top out and are retired by CMS. “Quality measures have been around a long time, and historically, they’ve not been focused on quality as much as box checking. To combat this, the Academy has been working hard to create quality measures that are meaningful and feasible in a busy practice,” Dr. Van Beek said.

“The Academy creates meaningful, dermatology-specific measures that are rigorously tested to best demonstrate the value of dermatologic care while also driving improvements in patient outcomes,” Vera said. “AAD measures will be used in the MVPs we develop. Through measure development, the Academy plays a significant role in ensuring the availability of quality measures that are truly meaningful to members.”

The Academy has spent years developing quality measures on topics that are relevant to dermatologists, including skin cancer, psoriasis, disease severity, surgical dermatology, Dr. Reeder said. “We’re really proud of the measures we have and want these measures to be applied to future MVPs.”

Dr. Van Beek noted that all MVPs will have to be reported through a qualified clinical data registry (QCDR). “The only way we’ve been able to develop meaningful dermatology quality measures and have them certified by CMS is because we have DataDerm™, the Academy’s clinical data registry.”

A new committee

“The Academy has empaneled a new MVP Committee that will report to the Board of Directors and is working hard to determine the potential impact of MVPs to members. The MVP Committee is made up of various committees, councils, and task force leadership to represent advocacy, payment, DataDerm, measurement, and quality efforts at the Academy,” Vera said. “Bringing together experts in all areas throughout the Academy will allow for a dermatology-specific MVP to be developed.”

“We’ve met with CMS to discuss our concerns and requested clarity on expectations regarding MVPs,” Vera said. “We’ve also met with other societies to hear about their experiences with MVP development. We need to lead the development of dermatology MVPs — or CMS will,” she added.

MVP development

“The AADA will be pushing for an MVP that would not penalize those of us who treat severe diseases,” Dr. Van Beek said. “We know it’s more expensive to treat severe psoriasis than it is mild psoriasis. Since cost is part of MVPs, we want to make sure that there’s proper risk adjustment, so a physician is scored accurately regardless of the disease severity of the population they treat. We want fair parameters to make sure that no one is adversely affected for doing the right thing.”

“I think we’ll have to spend time with broad topics in dermatology,” Dr. Reeder said, “similarly to how we developed quality measures. We will have to try to make the dermatology MVP as relevant to as many practicing dermatologists as possible.”

“One of the ways that AAD members can be involved in this process is by participating in DataDerm. Real-world practice data helps us understand the type of patients physicians are seeing, account for the most common treatments for particular conditions, and determine whether something is a reasonable quality metric in a busy practice,” Dr. Van Beek explained. “The more data we have, the better we will be at developing measures that are meaningful and less burdensome.”

At the table

The Academy has been heavily involved early in the regulatory process, including participating in CMS listening sessions on what MIPS Value Pathways should look like for practicing physicians, Dr. Van Beek said. The Academy is also part of a collaborative with the AMA to ensure they understand what CMS is looking to implement while providing feedback about what is feasible and practical for physicians, she said.

“CMS wants to work collaboratively with us so that these MVPs make sense for dermatologists and are clinically relevant to the work that we do,” Dr. Reeder added.

“The Academy has always been very involved at trying to stay one step ahead of what has been coming down the pike for payment policy reform,” Dr. Van Beek said. MVPs are still in their infancy with much to be elucidated by CMS, particularly for specialties and physicians that do not have an applicable MVP in 2023.

The Academy is at the table and will get answers so that it can guide members when the time comes, she said. “We don’t want checkboxes for the sake of checkboxes. The activities and measures we are required to report on should fit into the regular flow of clinical care. Anything extra should prove to be meaningful to both patients and physicians as far as improving quality.”

“The Academy has been involved with MVPs and has been providing feedback to CMS ever since ‘MVPs’ was first uttered — and while there are still a lot of unknowns, we will continue to have your back as the process unfolds,” Dr. Van Beek emphasized.

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