The Academy is asking the Centers for Medicare & Medicaid Services to press forward with proposed policy changes that can improve ophthalmologists’ ability to succeed in quality programs. In our response to the draft 2018 Medicare physician fee schedule rule, we pointed out ways to give regulatory relief to physicians, while fully using our IRIS® Registry in Medicare’s new physician payment system.
The comments respond to CMS’ proposed rule, released in June. Before the agency finalizes the policy, we’re seeking several key changes.
Amend legacy quality programs for 2018 payments
The Academy wants CMS to move forward with its proposed changes to legacy programs like the value-based modifier. These are changes that the Academy helped secure during our months-long regulatory relief campaign. These would reduce penalties, as well as requirements, in the following ways:
- Hold harmless from value-based modifier penalties all providers who satisfy proposed, reduced Physician Quality Reporting System requirements;
- Cut downward adjustments in half:
- Reduce penalties for small practices (fewer than nine physicians) to 1 percent for the value-based modifier;
- Reduce penalties for practices with more than nine providers to 2 percent for the value-based modifier.
Shield Part B drug payments from Quality Payment Program penalties
We believe Congress did not mean for CMS to apply penalties and bonuses to Part B drug reimbursements to physicians. We want CMS to reevaluate its interpretation of the statute.
If the agency presses forward with this policy, it would be a significant departure from how it has done business to date. Penalties applied to this area could inadvertently hurt our patients’ access to quality eye care in every community across the United States. The Academy believes a reduction in drug reimbursements could compel physicians to cease providing necessary-but-expensive treatments.
Expand MIPS recognition of IRIS Registry participation
The Merit-Based Incentive Payment System provides ample ways for ophthalmologists to succeed via the Academy’s IRIS Registry — if only CMS will allow it. The Academy wants CMS to give participants in ophthalmology’s clinical data registry full credit in MIPS’ electronic health record component. We also asked that participants earn at least half of the points you need to succeed in the quality category.
We also urged CMS to lift caps on the number of measures we can develop for the IRIS Registry. This will help ensure that CMS measures our profession on activities that are relevant to what we do.
Revise the Quality Payment Program
In addition to enabling greater recognition of IRIS Registry participation, we want CMS to take additional steps to improve its Medicare physician payment system. This includes adjustments to quality measures. The agency should also continue to refine MIPS’ cost category by leaving it at zero weight for at least another year. Anything higher than zero is unfair to ophthalmologists and other specialists.
Simplify Medicare Advantage’s prior-authorization
We believe prior authorizations currently put massive burdens on physicians. This costs you quality time with your patients — nationally, at least $23 billion annually. The Centers for Medicare & Medicaid Services can start with several minor changes related to how Medicare Advantage plans use prior authorization, it could significantly reduce the administrative burden on practicing physicians.
CMS will consider the Academy’s comments before it finalizes its fee schedule in November. In the meantime, we’re also pursuing several legislative solutions to the issues we’ve raised.