CMS proposes to launch MIPS Value Pathways (MVPs) reporting in 2023. This new framework aims to reduce reporting burden and make MIPS more meaningful for participants. While its introduction has been delayed due to the Covid-19 pandemic, the 2022 proposal restarts momentum towards its implementation.
MVP reporting is proposed to be optional in 2023. On the surface, some elements of the MVP framework may seem similar to traditional MIPS. But looking deeper into MVP policies reveals several complexities. Clinicians will face many decisions about whether—and if so, how—they should participate. Some of those choices include:
- Whether to voluntarily participate in MVP reporting or maintain traditional MIPS strategy;
- When to begin MVP reporting if choosing to participate before it is required;
- Which MVP to report; and
- Within each MVP, which measures to report.
Ultimately, MVP strategy will depend on a multitude of factors unique to each participant. Clinicians will need to consider their population health and value-based care strategies, alignment initiatives, data capabilities, reporting resources, and more when deciding how to prepare for the transition to MVPs.
Phasing MVPs in—and traditional MIPS out
The transition from traditional MIPS to MVPs will happen over several years. Clinicians can start with voluntary reporting through the seven MVPs proposed for 2023. CMS will add more MVP options in future years, aiming to establish a wide range to cover all clinicians by 2028. At that point, CMS will consider sunsetting traditional MIPs and making MVP reporting mandatory.
CMS also intends to phase in MVP reporting at the subgroup level for multi-specialty groups. In 2023 and 2024, multi-specialty groups can participate in MVPs at the group or subgroup level. But starting with 2025, multi-specialty groups will be required to report at the subgroup level if choosing to participate in MVPs.
The timeline below includes additional detail on proposed MVP implementation.