MGMA urges CMS to adopt alternative MVP framework (January 24, 2025)

January 24, 2025 

The Honorable Jeff Wu
Acting Administrator
Center for Medicare & Medicaid Services
U.S. Department of Health and Human Services
7500 Security Boulevard
Baltimore, MD 21244

Re: 2026 Proposed Candidate MVPs and Existing MVP Maintenance Feedback Period

Dear Acting Administrator Wu,

On behalf of the undersigned organizations, we are writing to recommend vital improvements to the existing and candidate Merit-based Incentive Payment System (MIPS) Value Pathways (MVPs). We collectively developed a robust alternative MVP framework focused on grouping MVP measures for chronic health conditions, episodes of care, and major procedures within the broad specialty MVPs that the Centers for Medicare & Medicaid Services (CMS) believes are necessary. Our recommendations would also create better alignment between the hospital Value Based Purchasing programs and MIPS and provide more meaningful quality and cost comparison information for patients. Unfortunately, the previous administration implemented MVPs that do not meet their potential to improve value for Medicare patients. We strongly urge CMS to take a fresh look at our alternative MVP framework and adopt our recommendations outlined below in the 2026 Medicare Physician Fee Schedule proposed rule.

On December 11, 2024, CMS released the 2026 Candidate MVPs as well as opened solicitation for feedback on the existing MVPs in the Quality Payment Program (QPP) with comments closing on January 24, 2025. Physicians initially supported the MVP concept for its promise to create more alignment of quality and cost measures and reduce burden in MIPS, but the reality has fallen short. Since the inception of the MVP concept, the AMA and the national medical specialty societies have frequently and actively tried to engage with CMS to provide constructive feedback on how to improve MVPs. These improvements could meet a crucial need to make the QPP more meaningful for patient care and physician participation less burdensome and costly. However, we are once again disappointed with the lack of transparency in developing the candidate MVPs, limited timeline to respond, and absence of much needed changes to MVPs.The lack of responsiveness is further concerning given that CMS continues to signal that it plans to sunset traditional MIPS starting with the 2029 performance year/2031MIPS payment year and make MVPs mandatory. MVPs must remain optional, and subgroup reporting must be optional even for MVP participants. CMS should not further burden practices with a regulatory requirement outside the bounds of the statute that requires them to participate in a certain way or report on a program structure that does not make clinical sense.

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