The Vascular Surgery MVP Feedback from the CMS public comment period has been posted to the CMS website. The SVS is very grateful for all the feedback that was given. After reviewing the MVP candidates, the feedback for the Vascular Surgery MVP was consistent with other MVP candidates and issues previously identified by CMS.
We would like to address specific items brought to our attention.
Feedback: One commenter was concerned that out of the 14 MIPS quality measures included in this MVP, 4 didn't have benchmarks which would result in 0 points, 2 could only earn 7 points, and 1 required an additional cost to implement. The commenter didn't believe this MVP was viable for practices to adopt.
SVS Response: We are aware of the issue of the lack of benchmarks for measures included in the MVP. As a result of COVID, the development of new quality measures to replace topped out or lack of benchmark measures has slowed. The SVS along with other societies have discussed this issue with CMS who have made steps to address the lack of benchmarks related to scoring. Please see the Quality Payment Program (QPP) website at qpp.cms.org for more details.
The Quality & Performance Measure Committee is currently developing 5 specific vascular quality measures that could be used in all practice settings. Unfortunately, the development process can take up to 3 years for inclusion in the QPP. The QPMC will solicit feedback through an open comment period in addition to the CMS Public Comment Period.
If you would like to participate in the development of these measures, please complete the Call for Volunteers form and identify membership for the Quality & Performance Measures Committee.
Feedback: One commenter recommended the addition of Q495: Ambulatory Palliative Care Patients’ Experience of Feeling Heard and Understood.
SVS Response: We are grateful for this suggestion. The QPMC will evaluate the inclusion of this measure in the next update cycle.
Feedback: One commenter expressed concern that this MVP includes limited electronic clinical quality measure (eCQM) options.
SVS Response: Yes, there are limited electronic clinical quality measure (eCQM) options. The SVS discussed eCQM development vs digital measure development with CMS. We were informed current CQMs will be converted to digital measures in the near future. With the current governmental environment, the SVS is monitoring federal activity to determine if there will be any changes to MVP reporting. We will adjust the quality measure development strategic plan accordingly. If there is a demand for eCQMs, please contact the SVS at SVSQuality@vascularsociety.org to discuss.