Academy’s Appeals to CMS: Fix MIPS, Reward IRIS Registry Users, Apply E/M Overhaul Fairly

The Academy is pressing the Centers for Medicare & Medicaid Services to make substantial changes to physicians’ pay for office visits, along with adjustments to its program that ties reimbursements to quality performance. 

Our comments are a response to the agency’s proposed 2020 fee schedule and other issues related to Medicare payment and the Merit-Based Incentive Payment System. 

For the fee schedule, we insist that CMS provide equity in its application of a proposed increase in E/M values by including post-operative visits and ophthalmology’s eye visit codes among the services considered for increases. 

In its proposed fee schedule, CMS floated the possibility of a similar adjustment to eye visit codes within the context of the proposed E/M increase. In our comments, the Academy responded that reciprocal increases would in fact be appropriate, which is consistent with previous CMS-driven increases to E/M. 

The E/M boost for 2021 will have a significant negative effect on ophthalmology and other surgical specialties because of budget neutrality requirements. To counteract this, we’re requesting equity for post-operative visits and eye visit codes to mitigate an overall net negative. 

For MIPS, we urge the agency to address its low-volume threshold – in which physicians who do not see a minimum number of Medicare patients are exempt in the program – while giving more credit to the Academy’s IRIS^® Registry and reinstating the small-practice bonus to the MIPS final score. The low-volume threshold currently exempts more than 60% of all practitioners.