MedPAC Considers How to Reduce Burden of MIPS and Encourage Participation in Advanced APMs

On March 2, 2017 the Medicare Payment Advisory Commission (MedPAC) met in Washington DC and discussed alternatives to the Merit-based Incentive Payment System (MIPS), Advanced Alternative Payment Models (APMs) and ways to increase support for primary care.

At the January 2017 MedPAC meeting, several Commissioners voiced concerns with the current structure of the MIPS and Advanced APM programs.  Specifically, these Commissioners raised the following concerns:

  • MIPS is unlikely to succeed at identifying or paying for clinicians delivering high value care;
  • MIPS is administratively burdensome;
  • Advanced APMs should be made more attractive to incentivize clinicians from MIPS to Advanced APMs; and
  • Primary care needs more support.

In response to these concerns, at this recent meeting MedPAC staff presented for the Commissioners’ consideration a number of proposals to improve MIPS and Advanced APMs, and increased support for primary care.

Under an alternative MIPS proposal presented by MedPAC staff, all clinicians would contribute to a quality pool (e.g., 1% withhold). Clinicians that join an Advanced APM, would receive the withhold back. Alternatively, clinicians could elect to participate in a clinician-defined virtual group[1] or be measured in a CMS–defined referral area. These physicians would be eligible for positive or negative quality adjustments. CMS would use the same set of population-based outcome measures for all clinicians (claims-based and patient-reported) and any payment adjustment would apply to all clinicians in the same virtual group or referral area.

For the Advanced APM track, MedPAC staff presented a proposal to use the $500 million exceptional performance funds from MIPS to fund asymmetric risk corridors (i.e. higher upside than downside risk) as well as other proposals designed to encourage practices to accept risk.

MedPAC also discussed a proposal to allow primary care physicians in 2-sided risk accountable care organizations to take an upfront payment to help support care coordination. The upfront payment would be financed by reducing fee-for-service payment for each primary care visit reported by the clinician.

While no formal votes were taken on any of the proposals, Commissioners expressed general support for the proposals. There was a general consensus that CMS needs to more effectively move clinicians from MIPS into Advanced APMs, and for that to happen CMS must make Advanced APMs more attractive. Commissioners also agreed that more needs to be done to support primary care practices and small practices – a recurrent theme and priority area often identified by MedPAC.

Further refinements of these proposals will be presented at future meetings. MedPAC staff also indicated that they will be discussing broader fee schedule issues at upcoming meetings. Potential topics include: increasing focus on overpriced services, improving the process for pricing services, addressing the inadequate data used to maintain the fee schedule, revisiting prior Commission recommendations (establishing expert panel to help CMS set payment rates and collecting data from cohort of selected practices); and exploring combining CPT codes into families of codes.


Presentation slides are available here.


Click here to access the McDermottPlus MACRA Resource Center.


For more information please contact Sheila Madhani at 202-204-1459 or



[1] MedPAC is not using the term virtual group as defined in MACRA. While the term was not defined, in discussion staff indicated that a virtual group could be a hospitals system or a self-created group that could potentially cross state lines.