Concerned About PQRS Penalties?

2015 Program Year   The AOA has heard from hundreds of doctors of optometry that expended time and resources to participate in PQRS in 2015, only to find in late 2016 that they did not meet all the requirements and would face a 2% payment penalty in 2017.  The AOA brought our concerns with the 2015 PQRS program year directly to the Centers for Medicare & Medicaid Services (CMS), but the agency has remained firm in their position on the penalties.  The AOA plans to engage the incoming administration, Members of Congress and CMS officials regarding our serious concerns with the financial penalties that are a result of a program that was flawed from the start.  

2016 Program Year   As AOA previously reported, CMS has indicated that the changes to ICD-10 codes in 2016 will impact their ability to properly assess whether doctors have met PQRS reporting requirements in 2016. CMS has specifically noted that many of the measures impacted are related to eye disease.  To determine whether ICD-10 codes have impacted a doctor's ability to successfully participate in PQRS in 2016, CMS has only provided general guidance indicating they will "review the submissions to determine which the group practices and EPs were negatively impacted by the ICD-10-CM coding changes. The group practices and EPs  affected by the impact of the ICD-10-CM code updates will be removed from the PQRS payment adjustment prior to the release of feedback reports." Read the CMS FAQs here:  The AOA will continue to work with CMS to ensure fair and appropriate assessment of successful PQRS participation.  

2017 Program Year    Beginning in 2017, doctors who meet the low volume exclusion for the Merit-Based Incentive Payment System are no longer required to report on quality measures.  CMS has indicated that this month they plan to provide more information to doctors on whether they have met the exclusion for the 2017 program year.  Doctors who are required to participate in MIPS should review the AOA's MIPS resources available at:  and our MIPS Roadmap.  Additionally, on January 26 at 8pm Eastern Time, the AOA will host a webinar: "The Merit Based Incentive Payment System (MIPS) for Non-EHR Users" This webinar will assist doctors who are not using electronic health records (EHRs) in their practices navigate the new Merit-Based Incentive Payment System during the 2017 MIPS Transition Year. The webinar will be presented by Dr. Rebecca Wartman. Register here: For those unable to attend the webinar, it will be recorded and posted to the AOA's website at: