New proposal would retroactively change reporting requirement from nine measures to six.

AOA’s multi-pronged advocacy leads to CMS reconsideration of penalties for quality data reporting

Following sustained and significant action by the AOA, relief may be on the way for doctors of optometry who may have failed to meet 2016 requirements under the Physician Quality Reporting System (PQRS).

"AOA will always fight to ensure that our doctors are on a level playing field with the opportunity to succeed under CMS programs."

Through direct outreach to the Centers for Medicare & Medicaid Services (CMS) administrator, by engaging members of congress and by raising concerns with CMS program requirements to the U.S. Department of Health and Human Services Secretary Dr. Tom Price, the AOA put a spotlight on the unreasonable quality reporting requirements from 2015 and 2016. The AOA argued that the PQRS requirements of the past two years were unworkable for thousands of physicians.

CMS has now proposed to retroactively change the 2016 program requirements and reduce the number of measures doctors of optometry were required to report under the PQRS program in 2016, dropping the number from nine to six measurements. The AOA engaged CMS immediately upon hearing from doctors of optometry last fall who received notices that they would be receiving a 2 percent penalty for not complying with the 2015 reporting requirements. PQRS program requirements were consistent in 2015 and 2016. Because of that, the AOA was concerned that doctors facing penalties this year would again be penalized in 2018.

PQRS, a Medicare claims-based incentive program for doctors, is designed to yield data that CMS can publicly share with consumers on its Physician Compare website. Doctors who don't participate in the program or fail to report the data face the cut in their reimbursement for services from CMS.

"We are proposing these changes based on stakeholder feedback and to better align with the MIPS (Merit-based Incentive Payment System) data submission requirements for the quality performance category," CMS announced July 13.

CMS' reconsideration is a victory for patients and doctors of optometry who were being unfairly penalized, says Christopher J. Quinn, O.D., AOA president.

"CMS has put forth a reasonable proposal that addresses some of our concerns," Dr. Quinn says. "AOA will always fight to ensure that our doctors are on a level playing field with the opportunity to succeed under CMS programs. The policies of the past were misguided and AOA sought to bring attention to that fact. 

"This should have a positive impact and reduce the number of our doctors who are penalized in 2018 based on 2016 participation," he adds. "CMS hasn't done anything yet about the 2015 reporting year and the penalties that are currently in place for 2017, but this policy change would provide some relief for our doctors next year. We will continue to work on the penalties related to the 2015 program year."

What doctors of optometry should know

The AOA recommends that doctors of optometry review their PQRS feedback reports for accuracy. CMS will make available 2016 PQRS feedback reports later this year. By reviewing those reports, doctors will be able to ascertain whether they have successfully reported 6 measures and will avoid a payment penalty in 2018. More information on PQRS feedback reports is available here.

Doctors also should know that reporting for the 2017 MIPS program year ends Dec. 31. That data will determine 2019 payments.

AOA members with questions regarding the process can contact Kara Webb, AOA associate director of coding & regulatory policy, at

July 25, 2017

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