Watchdog outlines Merit-based Incentive Payment System concerns among radiology and other specialties

Some providers question whether the Merit-based Incentive Payment System program is improving the quality of patient care or outcomes, according to a new watchdog report released Oct. 1.

The U.S. Government Accountability Office recently analyzed performance data from 2017-2019 and interviewed officials from both the Centers for Medicare & Medicaid Services and 11 organizations representing MIPS-eligible specialty providers. Those included figures from diagnostic radiology along with cardiology, emergency medicine, pathology and internal medicine among others.

Eight of the 11 interviewed expressed doubts about the effectiveness of the initiative.

“Stakeholders stated that the design of the MIPS program may incentivize reporting over quality improvement, and thus, MIPS scores did not necessarily reflect the quality of care provided, but rather how well providers were complying with the reporting requirements of the program,” the report noted. “Some stakeholders said that to maximize payment adjustments, providers may choose to report on performance measures on which they are performing well or that are easy to achieve, rather than measures in areas where they may need improvement or that are clinically relevant.”

This may explain why performance scores were generally high, the GAO noted, with at least 93% earning a small positive-payment adjustment in 2017-2019. The largest landed at 1.88% while median final scores were well above the performance threshold across each of the three years. Between 72%-84% of MIPS participants earned an “exceptional” performance bonus during that span.

Congress authorized MIPS under the Medicare Access and CHIP Reauthorization Act of 2015, hoping to reward value, rather than complexity and volume of services. The system incentivizes physicians and other providers through payment adjustments based on their performance. All told, about 950,000 providers were MIPS-eligible participants in 2019, the GAO noted.

Among other concerns, 10 of the 11 stakeholders said that CMS’ feedback on providers’ scores and performance was not timely or meaningful. Some also believe certain quality measurements assess activities that are irrelevant for some specialties, and that the process for developing new metrics can be “time consuming and expensive.” Another eight stakeholders said participating in MIPS produces a low return on investment, with miniscule payment adjustments compared to the high administrative costs incurred.

On the positive side, 2 of 11 interviewees cited the MIPS low-volume threshold as a strength, reducing participation burden for smaller practices with lesser Medicare tallies. Two stakeholders also highlighted bonuses for small practices and treating complex patients, which increased scores for otherwise disadvantage providers. Three of 11 respondents commended the performance-category exemption, allowing participants to reduce excess burden.

“For example, some providers, such as radiologists and pathologists, automatically qualify for the ‘promoting interoperability hardship’ exception, and thus, are exempt from that category,” the report noted. “CMS acknowledged that the exception was beneficial for certain providers who lack the ability to (1) affect their practices’ health information technology decisions or (2) have the face-to-face patient interactions required for many of the measures in the promoting interoperability category,” it added later.

In diagnostic radiology, the median final score landed at 92.56 in 2017, climbing to 100 in 2018, and 95.04 in 2019. More than 77% of radiology MIPS participants logged scores with a positive adjustment and exceptional performance bonus in 2017, moving up to 90% the following year, and nearly 89% by 2019. Median associated payment adjustments for the specialty were as low as 1.45% and high as 1.68% during the study period.

You can find the full Government Accountability Office report here.

Marty Stempniak

Marty Stempniak has covered healthcare since 2012, with his byline appearing in the American Hospital Association's member magazine, Modern Healthcare and McKnight's. Prior to that, he wrote about village government and local business for his hometown newspaper in Oak Park, Illinois. He won a Peter Lisagor and Gold EXCEL awards in 2017 for his coverage of the opioid epidemic. 

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