MIPS Value Pathways

By: Barbara Rubel, MBA, FRBMA
Senior Vice President, Marketing & Client Servies

Feedback Leads to Changes

CMS continues to receive feedback from clinicians and stakeholders about the complexity of the Merit-based Incentive Payment System (MIPS) and has acknowledged the program is burdensome, makes it difficult to compare clinicians’ performance, and lacks patient-focused measures.  Much of the focus has been on what the clinician did or did not do and not on patient outcomes, patient experiences, or patient satisfaction.  Efforts have been made to address these concerns and to streamline the program; however, CMS is now focusing on more substantive changes.

Shift to MIPS Value Pathways

CMS intends to shift the MIPS program to a subset of measures and activities called MIPS Value Pathways (MVPs).   MVPs will be an aligned set of measures that are more relevant to a clinician’s scope of practice, that are more meaningful to patient care, and that include measures that focus on population health, care coordination, and patient-reported outcomes, experience, and satisfaction.    

Approved MVPs for 2023

CMS has finalized seven MVPs in the 2022 Medicare Physician Fee Schedule and clinicians may report through both MIPS and MVPs and CMS will take the higher of the two scores.

The seven MVPs that have been approved for 2023 are in rheumatology, stroke care and prevention, heart disease, chronic disease management, lower extremity joint repair (e.g. knee replacement), emergency medicine, and anesthesia. Also included in this Final Rule is CMS’ request for comments on removing the “traditional” MIPS program at the end of the 2027 performance and data submission periods. 

What a shift to MVPs hopes to accomplish:

Streamlines the MIPS categories
(Quality, Improvement Activities, Cost)

Reduces freedom of choice
(potentially alleviates “burden” of choosing measures)

Allows for comparability of like-providers


Steers providers towards adopting Advanced Alternative Payment Models


A new reporting option available beginning in 2023

Proposed to be mandatory by 2027 (complete phase-out of “Traditional MIPS”)

MIPS Today Versus MVPs Tomorrow

A deeper dive into what MIPS looks like today versus what MVPs may look like tomorrow yields the following:

  • Today, the number of reporting entities under MIPS is one per Tax Identification number (TIN).

  • Tomorrow, under MVPs, there may be three reporting entities (or more, if you have radiation therapy): one for diagnostic radiology, one for interventional radiology, and for groups who employ physician extenders, one for physician assistants/nurse practitioners or other specialists.
  • Today, a minimum of six quality measures must be reported and clinicians may choose from a list of over 200 measures.

  • Tomorrow, under MVPs, the minimum requirement is four measures, so for single specialty groups, the reporting requirement decreases from six to four measures.

    • However, for groups with diagnostic radiologists, interventional radiologists, and physician extenders, four measures per subspecialty must be reported and the reporting requirement increases from six to 12 measures.

    • In addition, the number of measures from which to choose decreases from over 200 measures to 10.
  • Today, clinicians must report on either two medium-weighted or one high-weighted improvement activity to fulfill the requirement and there is a lengthy list of activities from which to choose.

  • Tomorrow, under MVPs, clinicians must report on either two medium-weighted or one high-weighted improvement activity; however, the list from which to choose decreases to 10 improvement activities.

    • Groups with diagnostic radiologists, interventional radiologists, and physician extenders must each report on either two medium-weighted or one high-weighted improvement activity which increase the total to between three and six.
  • Promoting Interoperability and Cost are still question marks under MVPs.

    • Will CMS assess eligibility at the subgroup level? YES, this will not be evaluated or reported at the subgroup level.

    • Will new Cost measures be developed for MVPs that impact radiology? Possibly.

According to CMS, “The goal is to move away from siloed reporting of measures and activities towards focused sets of measures and activities that are more meaningful to a clinician’s practice, specialty, or public health priority.” 

Barbara Rubel MBA, FRBMA Senior Vice President, Marketing & Client Services

Barbara Rubel MBA, FRBMA
Senior Vice President, Marketing & Client Services

Barbara has been a leader with MSN Client Services since 1998. Her extensive background in strategic planning, market research, healthcare marketing and managed care negotiations provides a wealth of information to support MSN Clients.

Barbara has also been highly involved in industry organizations, serving as President of the Radiology Business Management Association (RBMA), the Georgia RBMA, and the Florida RBMA. In addition, she chaired the influential RBMA Federal Affairs Committee and the RBMA Technology Task force and was a member of the RBMA Data Committee. Her work on behalf of radiology has earned her the RBMA Special Recognition Award (2010), the RBMA Global Achievement Award (2013), and she is a Fellow of the RBMA.