MIPS And The Burden Of Performance Measurement
Physician practices face an enormous administrative and financial burden just to report on health care performance measures. This burden predates MACRA, and the legislation actually streamlines some of the reporting burden by combining three previously separate reporting requirements (Physician Quality Reporting System, Value-Based Payment Modifier, and Meaningful Use) into MIPS. However, physicians and their staff currently spend, on average, 785.2 hours ($40,069 per physician) annually simply tracking and reporting quality measures for Medicare, Medicaid, and private health insurers.
In spite of the substantial time diverted from patient care and the money ($15.4 billion – roughly the amount of government spending each year on graduate medical education) that could be used for other purposes, most physicians feel that the current measures do not help them improve the care they provide. According to an October 2016 analysis of the current misalignment of health quality measures, the Government Accountability Office concluded that: “Although hundreds of quality measures have been developed, relatively few are measures that payers, providers, and other stakeholders agree to adopt, because few are viewed as leading to meaningful improvements in quality.”
Making this huge investment in measure reporting with very little return in quality improvement is wholly inconsistent with the goal of value-based health care. Furthermore, while MIPS is essentially a complex pay-for-performance system that will reward or penalize physicians based on their performance on a range of measures, analyses of pay-for-performance payments systems have shown that they have had little effect on improving the quality of care over the past decade. Recognizing that most physicians, especially those in smaller, independent practices were not ready for MIPS and would likely be penalized, the Centers for Medicare and Medicaid Services (CMS) correctly provided for maximum flexibility for 2017, as noted above. However, when full implementation takes effect, success in MIPS is more likely to reflect the size and resources of the physician’s practice than the value of the care provided. Furthermore, public reporting of an individual physician’s MIPS performance will have not only a financial impact but may affect professional reputation and employability as well.