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- CMS Reviewing Pathology MVP Comments
The Centers for Medicare and Medicaid Services (CMS) is reviewing comments submitted by the CAP on a candidate Pathology MIPS Value Pathway (MVP) developed by CMS. MVPs are a new part of the Merit-Based Incentive Payment System (MIPS) that aims to group meaningful Improvement Activities, quality, and cost measures together in a defined framework that allows more relevant comparisons between clinicians.
The CAP submitted comments on the specific candidate on January 24. In the latest comments, the CAP raised concerns with quality measures developed by a billing company, MSN Healthcare Solutions. The comments also raise concerns about the lack of relevant Improvement Activities for pathologists. Furthermore, since all MVPs must include a cost measure, CMS has added a general cost measure to this MVP. However, CMS is aware that this cost measure is not attributed to pathologists and has indicated that developing a cost measure for pathology is a priority. If CMS intends to move forward with this MVP, it will appear as part of the 2026 Quality Payment Program proposed rule in the summer of 2025.
The CAP has been engaging with CMS to influence the composition of a Pathology MVP to ensure it is meaningful for pathologists. The CAP will continue meeting with CMS regarding this MVP and advocating to influence the scope and timing of such a cost measure if it were to be developed.