Evaluating the current state of quality measure reporting in the merit-based incentive payment system

The Merit-Based Incentive Payment System (MIPS) requires physicians to report quality measures along with supplementary metrics that are used to determine an annual percentage adjustment to physician Medicare Part B payments. Unfortunately, during the early years of the MIPS program (2017 to 2020), physicians in non-primary care specialties have had few quality measures to choose from. This has resulted in a disadvantage for physicians of non-primary care specialties to receive a positive Medicare part B adjustment. The aim of this study is to determine if significant variation still exists in the number and characteristics of quality measures in the MIPS program across specialties from 2021 to 2024.

This longitudinal quality improvement study uses Centers for Medicare and Medicaid Services (CMS) Quality Payment Program (QPP) public use file data from 2021 to 2024 to collect descriptive statistics about the number and characteristics of MIPS measures and Qualified Clinical Data Registry (QCDR) measures available for reporting within the Traditional MIPS reporting pathway. Primary outcomes included the number of measure-and-collection-type combinations, number of unique MIPS measures, number of QCDRs, and number of QCDR measures available for reporting within each medical specialty. Secondary outcomes included quality measure characteristics such as each measure's Donabedian class, topped out status, and capped status. All outcomes were established prior to data collection.

The average number of unique quality measures and measure-and-collection-type combinations available for reporting by non-primary care specialties is significantly lower than that for primary care specialties (p < 0.001, p < 0.001, respectively). Process measures outnumber outcome and structure measures within all specialties except neurosurgery, orthopedic surgery, and vascular surgery. A large percentage (40.9%) of all measure-and-collection-type combinations in 2024 are topped out and therefore fail to stratify physician performance effectively.

In this longitudinal study of MIPS and QCDR quality measures, results show that significant variability still exists in the number of quality measures available for reporting in 2024, with non-primary care specialties having the lowest number of reportable measures. Policymakers should ensure that future modifications to the MIPS program provide equal opportunity for physicians to achieve a positive Medicare Part B payment adjustment.