In November the Centers for Medicare and Medicaid Services (CMS) finalized proposals and outlined its plans to completely restructure the Merit-based Incentive Payment System (MIPS) program. This comes as no surprise, as CMS introduced the concept of MIPS Value Pathways through the rulemaking process several years earlier. CMS intends to change the program to reward high-quality patient care more effectively and increase opportunities for Advanced Alternative Payment Model (APM) participation. One of the major changes is the establishment of MIPS Value Pathways (MVPs), which are intended to lead to a more simplified MIPS clinician experience, improve value, reduce burden, and better inform patient choice in selecting clinicians.

MVPs will include:

  • Promoting operability measures
  • Population health claims-based measures
  • Quality measures
  • Cost measures
  • Improvement activities

Who will be eligible to participate in MVPs?

CY 2023 – CY 2025 MIPS Performance Period

Individual MIPS eligible clinicians, single specialty groups, multispecialty groups*, subgroups, and APM Entities.

CY 2026 MIPS Performance Period, and Future Years

Individual MIPS eligible clinicians, single specialty groups, subgroups*, and APM Entities.

*Certain clinicians will not be able to participate in MVP implementation including voluntary reporters, opt-in eligible clinicians, and virtual groups.

Highlights of the MVP Program

  • Implementation of MVPs will be delayed until the 2023 performance year.
  • Multispecialty groups will be required to form subgroups to report MVPs beginning in the 2026 performance year.
  • An introductory set of 7 MVPs will be available in performance year 2023.
  • MVP reporting requirements will be defined for the four MIPS performance categories.
  • From 2023 – 2025, voluntary subgroup reporting within MIPS will be limited to reporting through MVPs or the APP.
  • Comparative feedback will be provided along with performance feedback.
  • MVPs will gradually be implemented for all specialties and subspecialties that participate in the program.
  • Beginning in the 2023 performance year, Qualified Clinical Data Registries (QCDRs), qualified registries, and health IT vendors must support MVPs that are applicable to the MVP participants on whose behalf they submit data.
  • QCDRs, qualified registries, health IT vendors, and CMS-approved survey vendors will also be required to support subgroup reporting by performance year 2023.

Proposed MVP Implementation Timeline

CMS sought comments on the timeline for mandatory MVP reporting, upon which they have not yet made a final decision. The details below outline what was proposed. The AASM will continue to monitor future rules as CMS determines the appropriate timeline for mandatory MVP implementation.

CY 2023 MIPS Performance Period

An initial set of MVPs are available for reporting; MVP reporting is voluntary.

CY 2024 – CY 2027 MIPS Performance Periods

The existing MVP portfolio would be gradually updated to include newly developed MVPs that are available for reporting. MVP reporting is voluntary.

End of CY 2027 MIPS Performance Period and Corresponding Data Submission Period

Considered sunset of traditional MIPS.

CY 2028 MIPS Performance Period, and Future Years

Considered mandatory MVP reporting.

Proposed Subgroup MVP Implementation Timeline

CMS also proposed a separate timeline for implementation of mandatory Subgroup MVP Reporting. This timeline also has not yet been finalized, and AASM will continue to monitor future rules regarding finalization. CMS did not propose that MVP reporting is mandatory but has outlined and solicited public comments on the future timeline.

CY 2023 through CY 2025 MIPS Performance Period/2025 through 2027 MIPS payment years

Groups may voluntarily form subgroups to report MVPs.

CY 2026 MIPS Performance Period/2028 MIPS payment year, and Future Years

Multispecialty groups will be required to form subgroups in order to report MVPs.

CMS noted that the portfolio of MVPs will be expanded over several years, and traditional MIPS will remain intact until all participating specialists have relevant MVPs to report. The AASM will continue to advocate for specialty participation in developing MVPs and also will continue to advocate for the development of sleep-specific MVPs.

Members may send questions about MIPS and/or MVPs to