Study Finds MIPS Scores Don’t Reflect True Quality Performance

A recent study out of the Weill Cornell Medical College questions whether the Merit-Based Incentive Payment System (MIPS) accurately captures the quality of care delivered by primary care physicians.

Published in JAMA in December, the cross-sectional observational study of over 80,200 primary care physicians found that MIPS scores were inconsistently related to performance on both process and outcome measures. Physicians treating more medically complex and socially vulnerable patients were also more like to receive low MIPS scores even when they provided relatively high-quality care, according to the study.

MIPS is a mandatory reimbursement program for Medicare providers, including physicians, physician assistants, and nurse practitioners, as long as they bill enough for Part B-covered professional services and see enough Part B patients based on Medicare-set levels. Nearly 1 million providers participate in MIPS every year.

Medicare reimburses providers in MIPS based on their performance across four categories: Quality, Promoting Interoperability, Improvement Activities, and Cost. However, critics of the largest value-based payment program to date have questioned whether the measures used to judge and pay providers are relevant. Some stakeholders have also complained about the administrative burden of MIPS participation.

The JAMA study underscores a disconnect between the measures MIPS uses to judge quality of care and the care actually delivered to patients. For example, for some measures, physicians with the lowest MIPS scores—those subject to financial penalties—had better performance relative to physicians with the highest MIPS scores, who were eligible for “exceptional performance” bonuses.

“The findings support concerns that program performance may not accurately capture the quality of care that physicians provide but rather that quality of care is related to the characteristics of patients they care for and the ability of their organizations to report data,” states the JAMA study.

“Primary care physicians with low MIPS scores tended to see more clinically and socially complex patients than physicians with high MIPS scores; they were also more likely to work in small and independent practices. Importantly, the study did not find evidence that physicians with low MIPS scores provided consistently worse care.”

Researchers point to a clinician’s ability to select the measures they report to MIPS as a possible reason for the high level of discordance between physician MIPS scores and performance on patient outcomes. Other possible explanations include invalid measures, skewed weight distribution of the performance categories, and the program’s tendency to reward clinicians who are better at collecting and reporting data.

CMS has addressed some MIPS concerns, particularly around measure selection. The agency is implementing common sets of measures based on a clinician’s specialty. These MIPS Value Pathways will have subsets of measures and activities that will meet most program requirements.

However, further work will need to be done to ensure that MIPS penalties do not exacerbate health inequities.

“[F]inancial penalties for poor program performance are scheduled to increase in the coming years; this may impose an undue financial burden on safety-net organizations, given the finding that physicians with low MIPS scores, but strong clinical performance, were more likely to care for socially vulnerable patients,” the study states.