After repeated entreaties urging the Centers for Medicare & Medicaid Services (CMS) to correct issues in its Merit-Based Incentive Payment System (MIPS) diabetes cost measure methodology, the Academy and others from the ophthalmic community successfully clarified our concerns with the Center for Clinical Standards and Quality team and its measure development contractor, Acumen.
We were able to help CMS understand that ophthalmologists typically practice in a single specialty group and are not responsible for managing diabetes care.
CMS committed to fixing the group attribution in its calculation of 2023 cost measure performance and plans to improve transparency by sharing details on the revised measure publicly. While the agency did not commit to fixing the problem in 2022 performance scores, it assured us it would discuss its options internally.
The Academy has heard from members that in their final score preview for the 2022 MIPS performance year, CMS has incorrectly applied the cost measure for managing patients with diabetes to some ophthalmologists who participate in MIPS as a group.
Working with the American Society of Retina Specialists (ASRS) and American Society of Cataract and Refractive Surgery (ASCRS), we raised the issue in a joint letter on Jun. 28.
Our meeting Wednesday was a culmination of efforts to engage CMS and we were pleased that Michelle Schreiber, MD, deputy director for Quality & Value, attended the meeting. While CMS is considering how to address 2022 scores, Dr. Schreiber encourages ophthalmologists being scored on the diabetes cost measure to file a targeted review. CMS plans to take another look at the targeted reviews that have been submitted related to this particular cost measure, including the ones that have been denied.
The Academy continues to press CMS to also correct problems related to the cataract cost measure. CMS has alerted us that it has updated the patient level data files to remove duplicates, but we remain concerned about the effectiveness of this process, due to the lack of transparency from the agency regarding its efforts. We are in the process of scheduling a meeting with CMS to discuss these concerns.
If you see these issues or believe another error has been made in your MIPS score, submit a request for a targeted review by 8 p.m. ET Monday, Oct. 9. The Academy has developed suggested language for you to use in your targeted review, depending which cost measure you believe has been incorrectly calculated for you or your group. Tailor these templates to your specific practice and situation.
Here is the draft language:
Diabetes Cost Measure
Cataract Cost Measure