Fewer doctors of optometry required to participate in QPP.

CMS’ final rule changes MIPS requirements, fee schedule

Medicare finalized its 2018 Physician Fee Schedule (PFS) and updates to the 2018 Quality Payment Program (QPP) Final Rules with several notable changes to the way doctors of optometry participate in current and outgoing quality reporting programs.

“AOA will continue to advocate with Congress and CMS to ensure doctors of optometry are appropriately reimbursed for the care they provide.”

Issued by the Centers for Medicare & Medicaid Services (CMS) on Nov. 2, the PFS final rule updates policies affecting payment rates for Medicare services furnished during the 2018 calendar year and complete reporting under the former Physician Quality Reporting System (PQRS). The 2018 Updates to the QPP hones the ways in which doctors participate in QPPs. Within these two final rules are a number of provisions and AOA-advocated proposals that directly affect doctors of optometry in the coming year.

2018 QPP participation

CMS granted Medicare providers flexibility in tailoring their QPP participation for 2017, and given that it was the new program's first year, leeway will continue into 2018 as CMS works to develop program requirements that take into account the challenges some small practices face in participating in Medicare quality programs.

Finalizing a proposal to raise the low-volume threshold for 2018, CMS will not require QPP participation from any provider with Medicare Part B allowed charges less than or equal to $90,000, or any provider who sees 200 or fewer Part B-enrolled Medicare beneficiaries. CMS estimates this new bar means only 4,793 doctors of optometry will be required to participate in MIPS in 2018.

"While this news will be welcomed by some, it also is important to note that by being exempt from Medicare quality programs, doctors will not receive any increases in Medicare reimbursement in the coming years," noted Christopher J. Quinn, O.D., AOA president. "AOA will continue to advocate with Congress and CMS to ensure doctors of optometry are appropriately reimbursed for the care they provide."

Doctors participating in 2018 MIPS should note that CMS finalized changes that increase reporting requirements and alter performance category weights to include:

  • Quality weighted at 50 percent of score, increased reporting to 60 percent of patients
  • Cost weighted at 10 percent of score
  • Clinical Practice Improvement Activities (CPIA) weighted at 15 percent of score
  • Advancing Care Information (ACI) weighted at 25 percent of score

Additionally, Quality and Cost performance periods were set to 12 months, while ACI and CPIA performance periods will be 90 days or more. CMS also revised its proposed approach to ACI bonuses and responded to AOA concerns-providing up to a 10-percentage-point bonus for reporting to any type of registry-whereas, CMS had proposed to only make those bonus points available for doctors reporting to an immunization registry.

Finally, CMS declined a proposal that would allow doctors to opt-in for voluntary reporting in 2018. It's an issue that CMS must address in future rulemaking, and an option that AOA will continue to advocate for.

PQRS reporting, penalties

The 2018 PFS final rule answered several lingering questions when it came to PQRS performance that AOA had sought to resolve for the profession. CMS finalized an AOA-supported proposal to revise the previously finalized satisfactory reporting criteria for the 2016 PQRS reporting period to lower the requirement from nine measures across three National Quality Strategy (NQS) domains, to only 6 measures with no domain or cross-cutting measure requirement. Additionally, CMS finalized the AOA-supported proposal not to proceed with public reporting of PQRS participation status and value modifier cost and quality tiers in 2018.

That said, CMS decided against changing the 2015 PQRS requirements or penalties that many providers were assessed in 2017. The AOA strongly advocated against these 2015 PQRS requirements for doctors to report on nine measures for 50 percent of their applicable Medicare patients due, in part, to the drastic increase-from 3 to 9-in measures from the year prior, and considering the measures didn't align with the patient care provided by doctors of optometry.

Other PFS changes

Upon AOA recommendation, CMS will not apply the standard preservice clinical labor time of 0 minutes for 0-day and 10-day global codes. CMS did not make any final determinations regarding changes to the E/M guidelines.

Finally, it's estimated that CMS will pay doctors of optometry approximately $1.26 billion in 2018, up from the nearly $1.21 billion in 2017.

Click here to review the 2018 Medicare PFS Final Rule in full. Click here to review the QPP Final Rule in full.

November 14, 2017

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