The Medicare Payment Advisory Commission (MedPAC) has been discussing for well over a year how to reinvent the Medicare Access and CHIP Reauthorization Act’s (MACRA) Merit-Based Incentive Payment System (MIPS). As a result the commission intends to finalize substantial MIPS program reform recommendations in January. Though MedPAC has had good reason to question MIPS, the commission’s effort is misguided. By choosing to address MIPS, MedPAC has lost the forest for the trees. MIPS does nothing to fulfill MACRA’s intent. Title I of MACRA is intended to accelerate the Centers for Medicare and Medicaid Services’ (CMS’) efforts to move Medicare Part B providers into participation in what MACRA terms Alternative Payment Models (APMs), or more specifically advanced APMs. This goal remains in the balance.
MedPAC’s Critique
Authorized in 2015, MACRA was designed to replace the 1997 Sustainable Growth Rate (SGR) formula by moving physician practices from Fee For Service (FFS) to pay for performance arrangements, or APMs. The MIPS simply replaces and consolidates three previously existing FFS payment incentive programs that date back to 2006: the Physician Quality Reporting System (PQRS); the Electronic Health Record Incentive Program (termed Meaningful Use or MU); and, the Physician Value-Based Payment Modifier program (termed VM).