MIPS Value Pathways: What Rehab Therapists Need to Know About the Future of MIPS

If you’re a rehab therapist participating in the Merit-Based Incentive Payment System (MIPS) who enjoys the positive payment adjustments but is frustrated by the program’s complexity, there is a light at the end of the tunnel: CMS has rolled out MIPS Value Pathways (MVPs) in 2023 as a new, simplified reporting option. The catch? There isn’t a rehab-focused MVP available to therapists—yet. 

Come what may, MVPs have been dubbed as the future of MIPS, so it’s only a matter of time before it becomes the only reporting option available to all participating clinicians. That’s why we’ve put together a concise guide to help you get acclimated ahead of time—so you can be the real MVP. 

What are MIPS Value Pathways? 

Beginning in performance year (PY) 2023, clinicians can opt to report their MIPS data by choosing an MVP, rather than through traditional MIPS or the Alternative Payment Model (APM) Performance Pathway. The newly-implemented MVP reporting aims to make MIPS easier for clinicians by creating subsets of grouped measures and activities that are related to particular specialties. Participating providers can select an MVP from the list of 12 currently available, and then choose from the measures and activities within that MVP to report on for the year. 

MVPs were created in part to make selecting the best measures and activities for reporting less difficult for clinicians—a common complaint under traditional MIPS. The MVP program is also aimed at giving providers better and more useful performance feedback, both by grouping associated measures and activities within particular MVPs and by allowing for easier comparison between similar clinicians reporting the same MVP. 

What should rehab therapists know about MVPs?

As previously mentioned, MVP reporting remains optional for performance year 2023 for any MIPS-participating providers. And while there are 12 MVPs currently in use for the 2023 performance year, there are none currently applicable to rehab therapists. So why does this matter to rehab therapists? 

With CMS preparing to retire the traditional MIPS reporting framework in the near future—perhaps as early as 2027—current MIPS participants are going to need to be familiar with MVPs to succeed in the program. What’s more, we have it on good authority that performance year 2024 should see the introduction of a new musculoskeletal (MSK) MVP tailored to rehab therapists. (We’ll discuss that more later.) So for those rehab therapists looking to educate themselves, here’s what you need to know.

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There are a few MVP participation options. 

If you’re considering taking the leap into MVPs once there is an MSK MVP reporting option available, here are the current participation options for clinicians: 

During the registration process, individuals, groups, subgroups, and APM entities will have to choose: 

• One MVP for reporting;
• One populational health measure from the MVP foundational measures; and 
• One outcomes-based administrative claims measure.

In addition to those requirements, subgroups have to submit:

• A list of each TIN/NPI associated with the subgroup to identify each individual eligible clinician NPI in the applicable subgroup for the group TIN;
• A plain language name for the subgroup; and
• A description of the composition of the subgroup.

Once you've selected how you wish to participate and what MVP to report, pared-down requirements should make the actual reporting easier.   

MVP reporting requirements are reduced from traditional MIPS.

CMS introduced MVPs as a way to reduce the reporting burden for clinicians. In traditional MIPS, participants were required to collect and report six Quality Measures, including one outcomes measure. With MVPs, on the other hand, they only have to collect four Quality Measures—though one of those still needs to be an outcomes measure. 

The Improvement Activity requirements have also been decreased: 

Under traditional MIPS, clinicians had to report either: 

• two high-weighted activities, 
• one high-weighted activity and two medium-weighted activities, or 
• four medium-weighted activities. 

With MVPs, clinicians need only to report: 

• one high-weighted activity or 
• two medium-weighted activities.

Some things are carrying over from traditional MIPS, though. Should an MVP for rehab therapy be adopted for 2024, PTs, OTs, and SLPs would once again qualify for automatic reweighing in the Promoting Interoperability category, and would be scored in the Cost Performance category as they would be in traditional MIPS—which means that rehab therapists won’t need to worry about either should the current rules remain in place.    

What’s this new MVP for rehab therapists? 

Among the handful of MVP candidates for the 2024 performance year is Musculoskeletal Care and Rehabilitative Support, which would be the first MVP applicable to rehab therapy specialties. 

The Musculoskeletal Care and Rehabilitative Support MVP candidate has 14 Quality Measures, including five IROMS measures, as well as 11 Improvement Activities—five high-weighted, five medium-weighted, and one activity for the “Implementation of Patient-Centered Medical Home model.” You can take a look at the full breakdown of what’s included in the proposed MSK MVP on the QPP’s MVP Candidate Feedback page.   

Like the MVP program itself, the MSK MVP might take a bit of adjustment to get it to where rehab therapists want it to be. While the comment period for the MVP candidates closed on February 8, there is an opportunity to submit feedback on existing MVPs during the MVP Maintenance Process. So if you’ve got thoughts on needed changes to the MSK MVP, you’ll have another shot to share your opinion with CMS in 2024—assuming the MSK MVP candidate is adopted. 

Easier reporting and better feedback with MVPs should be a breath of fresh air for MIPS participants tired of the current program’s complexity—and an additional enticement for clinicians interested in participating. But MVPs remain a work in progress, which means that rehab therapists need to share their feedback to improve the MSK MVP—and the MVP program as a whole—before it becomes the only MIPS reporting option.