Penalized by PQRS? AOA needs your input

Penalized by PQRS? AOA needs your input

Doctors notified of a 2017 Physician Quality Reporting System (PQRS) payment penalty should review PQRS feedback reports for errors that may prompt further review, while AOA examines the scope of penalties linked to overly burdensome requirements.

Informal review requests must be submitted prior to Nov. 30, 2016.

In October, the Centers for Medicare & Medicaid Services (CMS) began mailing penalty letters to physicians notifying them of a 2 percent payment penalty that will be assessed on their upcoming 2017 Medicare Part B claims. This penalty is based on whether doctors successfully or unsuccessfully participated in the 2015 Medicare quality reporting program, PQRS.  

Only doctors subject to the payment penalty will receive these letters; however, it's important for all doctors to review their 2015 PQRS Feedback Reports immediately and file a CMS "Informal Review" request should the data appear inaccurate.  

In a departure from previous years, 2015 marked the first time CMS required doctors to report on nine PQRS measures for 50 percent of their applicable Medicare patients. This was a drastic increase from only three measures required just one year prior. At the time, AOA strongly advocated against such a high reporting threshold and argued that these requirements were not aligned with the patient care provided by doctors of optometry. Currently, AOA is assessing how many doctors of optometry will be impacted by the 2017 payment penalty, and will consider how best to use this information to advocate to CMS and Congress.  

"With our health care reporting standards and reimbursement evolving every day, it is imperative that doctors of optometry are positioned for success and not subject to measures that do not apply to the important care we deliver every day," says Andrea P. Thau, O.D., AOA president. "The AOA will review the information we secure from our members and take appropriate action."   If members were notified of a payment penalty and they attempted to participate in PQRS in 2015, they should contact the AOA's Associate Director of Coding & Regulatory Policy, Kara Webb, at  

How to access feedback reports, appeal payment penalties

Doctors looking to access their 2015 PQRS feedback report can do so by visiting

  • Select "log in to CMS Secure Portal," accept the Terms and Conditions and enter your Enterprise Identity Management (EIDM) User ID and password to log in.
  • If you do not have an EIDM User ID and password, you can register here.
  • Select the "PV-PQRS" tab, and the "Feedback Reports" option.

If you don't have an EIDM User ID and password, you can register at the link above.

Additional instructions for obtaining an EIDM account are available in CMS' Quick Reference Guide for Accessing 2015 PQRS Feedback Reports. If doctors believe the 2017 payment penalty was incorrectly assessed, they may request a CMS Informal Review of their PQRS reporting performance. To request an Informal Review, doctors must:

  1. Visit the Physician and Other Health Care Professionals Quality Reporting Portal.
  2. Select "Communication Support Page" under "Related Links" in the upper left navigation pane.
  3. Select "Informal Review Request" in the drop-down menu, and choose the appropriate option.

An Informal Review request must be submitted prior to Nov. 30, 2016.

CMS offers a "2017 Negative Payment Adjustment - Informal Review Made Simple" fact sheet to help guide doctors through the process. More information is available at CMS' PQRS Analysis and Payment webpage.  

AOA members can contact Kara Webb at with any questions regarding the process. 

November 3, 2016

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