MIPS repeal? MedPAC urges scrapping MIPS in favor of tracking more meaningful outcomes

October 6th, 2017 / By L. Gordon Moore, MD

“The Medicare Payment Advisory Commission is pushing for the immediate repeal and replacement of a Medicare payment system that aims to improve the quality of patient care.” – Modern Healthcare October 5, 2017

MedPAC commissioners are signaling that we’re on the wrong track when it comes to quality measurement in health care. In fact, this nonpartisan agency that provides analysis and policy advice to Congress on the Medicare program is recommending that MIPS be repealed. The Modern Healthcare article cites a number of reasons for MedPAC’s recommendations:

  • MIPS reporting is too costly. CMS estimates $1 billion overall costs of MIPS reporting while MIPS incentive payments are capped at $500 million.
  • MIPS quality measures focus on process—did the physician order the diabetes test on time—rather than patient outcomes.
  • MIPS allows physicians to choose six measures and to self-report—likely leading to high performance by most if not all reporting physicians.

The dominant model of quality measurement in health care in the U.S. conflates front-line health professional activities with overall healthcare delivery performance. In the former, doctors and nurses identify and close gaps in care and use evidence to guide decision making. In the latter we look for the impact of a coherent and effective system of care.

The premise that the “gaps in care improvement” leads to population outcomes is problematic. Here are just a few of many challenges that stem from conflating front-line gap closure with population outcomes:

  • Improving the cadence of diabetes testing does not necessarily lead to improving the lives of people with diabetes.[1]
  • Technologies to support this model of quality measurement are forcing doctors and nurses to spend an intolerable amount of time entering data and less time actually delivering care.[2]
  • Performance on a handful of process metrics does not predict an effective system of care delivery that changes outcomes for populations.[3]

Now we have a terrific opportunity.  It is past time to shift our focus to outcome measures that matter. We can accurately track performance on total cost of care delivery, rates of potentially preventable hospital admission, ED visits, readmission and more.  These rates can all be risk-adjusted to account for variations in illness burden, age, sex among different delivery systems. And all of these measures can be drawn from claims—thus eliminating onerous reporting requirements and giving health professionals more time to focus on the needs of their patients.

L. Gordon Moore, MD, is senior medical director for Populations and Payment Solutions at 3M Health Information Systems.

Learn about the evolution of bundled payment mechanisms.


[1] Starfield, B. “Threads and Yarns: Weaving the Tapestry of Comorbidity.” The Annals of Family Medicine 4, no. 2 (March 1, 2006): 101–3. doi:10.1370/afm.524.

[2] Arndt, Brian G., John W. Beasley, Michelle D. Watkinson, Jonathan L. Temte, Wen-Jan Tuan, Christine A. Sinsky, and Valerie J. Gilchrist. “Tethered to the EHR: Primary Care Physician Workload Assessment Using EHR Event Log Data and Time-Motion Observations.” Annals of Family Medicine 15, no. 5 (September 2017): 419–26. doi:10.1370/afm.2121.

[3] Friedberg MW, Schneider EC, Rosenthal MB, Volpp KG, and Werner RM. “Association between Participation in a Multipayer Medical Home Intervention and Changes in Quality, Utilization, and Costs of Care.” JAMA 311, no. 8 (February 26, 2014): 815–25. doi:10.1001/jama.2014.353.