ASA Response to CMS MIPS Value Pathways (MVP) Town Hall

On January 14, 2021, the American Society of Anesthesiologists submitted formal comments to the Centers for Medicare and Medicaid Services (CMS) following the Merit-based Incentive Programs (MIPS) Value Pathways (MVPs) Town Hall session held on January 7, 2021. During this Town Hall CMS solicited comments from attendees regarding the MVP subgroup reporting implementation, MVP design and MVP reporting requirements and scoring. 

ASA’s response focused primarily on:

• Urging CMS to reconsider the subgroup reporting mechanism and develop a process that both encourages MVP reporting and reduced group reporting burden. With the additional information provided leading up to this Town Hall, the implementation of subgroup reporting as-is would lead to increased burden on practices who may be required to report both traditional MIPS and via subgroup reporting. 
• ASA supported the continuation of non-patient facing exemptions for MVPs. This will allow physician anesthesiologists to participate without the potential repercussions of being scored on a performance category that would not otherwise apply. 
• ASA supported and encouraged CMS to consider incentives such as awarding additional MIPS points and/or preferential scoring to encourage MVP use by practices. However, CMS should test and publish different scoring methods to ensure a sense of fairness and accuracy in how ECs and groups are assessed.

ASA will continue the conversation with CMS to support a collaborative approach to the implementation of MVPs for the 2022 Performance Year. 

For additional information on MVPs and a link to all topics covered during the Town Hall please visit the Quality Payment Program Resource Library.  

For further information, please contact the ASA Department of Quality and Regulatory Affairs at [email protected].