AOA to CMS: Significant changes needed to MIPS proposed structure

July 11, 2016
AOA offers feedback on MIPS proposed rule.

A proposed rule implementing the Medicare Access and CHIP Reauthorization Act (MACRA) could be improved for the benefit of patients and physicians, AOA says, noting changes to key provisions.

The proposed rule, published May 9, incorporates new and existing quality payment programs—such as the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier and meaningful use programs—into one Merit-based Incentive Payment System (MIPS). In response, AOA submitted formal comments to communicate the need for more simplification and flexibility so that the MIPS program becomes a tool for quality improvement, rather than just another regulatory hurdle for doctors.

These comments express concern for potentially disruptive, burdensome or unwieldy policies, support greater flexibility, and reinforce optometry's access to patients. Based on the proposed rule, here are several positions AOA has taken:

  • What we know: The Centers for Medicare & Medicaid Services (CMS) proposed an exclusion from MIPS performance measurement (and the resulting bonuses and penalties) for doctors with billing charges of less than $10,000 in Medicare reimbursement and who see fewer than 100 patients. This exclusion would apply to about half of the 35,000 doctors of optometry who are enrolled as physicians in Medicare to provide medical eye care.
    What we're fighting for: AOA is advocating for doctors' exclusion based on one of these two criteria, rather than both. Also, AOA is advocating for doctors nearing retirement to be excluded from MIPS.

  • What we know: CMS intends to begin measuring doctors' performance through MIPS in 2017 with payment incentives and penalties beginning in 2019.
    What we're fighting for: AOA is advocating for a delay in this implementation date to allow doctors more time to become familiar with the new program requirements.

  • What we know: CMS intends to provide some flexibility to the Advancing Care Information (currently known as meaningful use) portion of doctors' four performance categories. However, CMS has proposed that doctors report on many of the same measures and objectives that currently exist under the EHR Incentive Program and maintains the structure of requiring very prescriptive actions be taken using EHRs.
    What we're fighting for: AOA is advocating for greater flexibility in meeting this performance category and recommends allowing doctors to choose from several EHR functions so that doctors are performing the measures that would have the greatest impact on their patients.

  • What we know: CMS proposed fewer quality measures that doctors must report (six). The available measures for doctors of optometry to report will be similar to those found in PQRS.
    What we're fighting for: AOA is advocating to lower the percentage of patients for which these measures are required to be reported. CMS has proposed that doctors report on 90% of their applicable patients for each of the six required quality measures. AOA argues this is far too high.

  • What we know: CMS outlined several Clinical Practice Improvement activities (CPIAs) that relate to the use of Qualified Clinical Data Registries (QCDRs), such as AOA MORE (Measures and Outcomes Registry for Eyecare). Doctors can select activities that match their practices' goals from a list of more than 90 options, rewarding care coordination, beneficiary engagement and patient safety.
    What we're fighting for: AOA is advocating for CMS to allow for specialties, such as optometry, to develop specialty-specific CPIAs and to leverage the power of AOA MORE in a way that is most useful to doctors of optometry and their patients.

The comment period concluded June 27 with more than 2,500 comments received, while a final rule could come later in the months ahead. 

MACRA was created to push the needle toward high-quality, high-value care. Depending on how well physicians perform under MACRA, CMS will start increasing or decreasing Medicare payments up to 4% in January 2020. The potential maximum incentive or penalty will increase each year from 2019 to 2022 and will cap at 9% in 2022 and going forward. Top performers may be rewarded with incentives above the maximum set rate. CMS intends to begin MIPS reporting in 2017.

AOA's continued advocacy, support

Beyond this comment letter, AOA will continue its advocacy for greater simplicity and flexibility in MIPS, including the push for more regulatory reform, guidance and legislation that will help members not only avoid penalties and earn higher payments, but also improve the quality and efficiency of their practices.

The AOA also will provide resources and tools to help doctors of optometry comply with MIPS. As CMS finalizes the proposed rules, AOA will begin a campaign to inform members of the MIPS requirements and how those requirements specifically impact optometry. In the meantime, AOA is working to use its current resources and programs, such as AOA MORE, to make compliance easier for members.

AOA MORE critical to doctors' successful participation

It is clear from this proposed rule that streamlined, quality reporting is a major emphasis of MACRA, and the use of QCDRs could help doctors to meet certain program requirements. This, in turn, reinforces the value of AOA's newest member benefit. Earlier this year, AOA MORE received CMS' QCDR designation for the 2016 PQRS year—a distinction that makes AOA MORE increasingly more valuable to doctors of optometry under MIPS. MACRA and the new proposed rule give special consideration to QCDRs and encourage their use as a way to increase reimbursement and reduce reporting burdens.

To be successful in MIPS, it's vitally important for doctors to implement a high-quality EHR, and AOA also strongly recommends doctors' participation in AOA MORE.

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