January 27, 2025
Last week, the Post-Acute and Long-Term Care Medical Association (PALTmed), along with a coalition of medical organizations led by the American Medical Association (AMA), sent a letter to Jeff Wu, the acting administrator of CMS. The letter addresses concerns and recommendations regarding the 2026 proposed and existing Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs).
The organizations propose an alternative MVP framework that focuses on grouping measures for chronic health conditions, episodes of care, and major procedures within broad specialty MVPs. They argue that this approach would better align hospital Value-Based Purchasing programs with MIPS and provide more meaningful quality and cost comparison information for patients. The coalition urges CMS to adopt their recommendations in the 2026 Medicare Physician Fee Schedule proposed rule.
Key recommendations include:
- Focusing on clinically meaningful measures for both patients and physicians.
- Aligning quality and cost measures to assess the value of physician care.
- Ensuring a viable path forward for specialty-led Qualified Clinical Data Registry (QCDR) measures.
- Improving scoring and benchmark methodology to incentivize reporting on new and existing quality measures.
- Providing a transition path from MIPS to Alternative Payment Models.
- Allowing optional MVP participation and subgroup reporting.
The letter also highlights the need for more relevant MVP quality measures for various acute and chronic conditions and criticizes the use of the Total Per Capita Cost (TPCC) measure, which the coalition argues does not accurately assess the costs related to physician care.
The coalition emphasizes the importance of a collaborative MVP and measure consideration process with physicians to ensure the successful implementation of the Quality Payment Program (QPP) and ultimately drive better care and value for patients.
