ASCRS•ASOA and Medical Community Advocacy Prompts CMS to Propose Reducing 2016 PQRS and VBPM Reporting Requirements to Enable More Physicians and Practices to Avoid Penalties in 2018

ASCRS•ASOA and medical community advocacy has garnered significant proposals from CMS aimed at reducing the regulatory burden on physicians, practices, and ASCs. The 2018 Medicare Physician Fee Schedule (MPFS) and 2018 ASC Payment proposed rules each include several proposals that will help physicians avoid penalties in 2018 and reduce administrative burden.

Key Changes to 2016 PQRS and VBPM to Impact 2018 Payment

The 2018 MPFS proposed rule modifies the reporting requirements for 2016 PQRS to make it easier to avoid both the 2018 2% PQRS and 2% or 4% (depending on practice size) VBPM penalties. These proposed changes are a direct result of ASCRS•ASOA and medical community advocacy to reduce provider burden and realign the requirements of these programs in their last year with requirements finalized for the 2017 performance year and 2019 payment year of MIPS.

Specifically, CMS is proposing to change the 2016 (for 2018 payment) PQRS program policy that requires reporting of 9 measures across 3 National Quality Strategy domains to require only reporting of 6 measures to avoid the PQRS penalty. CMS also proposes that physicians who submit electronic quality measures through EHR or QCDR (such as IRIS) will also satisfy the electronic clinical quality measure requirement of Meaningful use by successfully reporting 6 measures. 

Since the VBPM determinations are dependent on PQRS reporting, changing the PQRS requirements will also provide relief under the VBPM. For the VBPM, CMS proposes to:

  • Reduce the automatic downward payment adjustment for not meeting minimum quality reporting requirements from -4% to -2% for groups of ten or more clinicians, and from -2% to -1% for physician and non-physician solo practitioners and groups of two to nine clinicians;
  • Hold harmless all physician groups and solo practitioners who met minimum quality reporting requirements from downward payment adjustments for performance under quality tiering for the last year of the program; and
  • Align the maximum upward adjustment amount to 2 times the adjustment factor for all physician groups and solo practitioners. 

Reduced ASC Reporting Burden

In the ASC payment rule, CMS also proposes to delay the implementation of the Consumer Assessment of Health Care Providers and Systems (CAHPS) Outpatient and ASC Survey for CY 2018 data collection. ASCRS•ASOA and the ophthalmic community opposed the inclusion of the CAHPS survey measures in the 2017 final rule as the surveys are an administrative burden and costly. CMS proposes to remove three measures from the ASC Quality Reporting System: ASC-5, ASC-6, and ASC-7. CMS is also proposing to add three new measures, including ASC-16: Toxic Anterior Segment Syndrome (TASS), which ASCRS was involved in developing and supported.

Opportunities for Further Regulatory Relief

CMS included requests for information in each of the proposed rules seeking comment from stakeholders on "positive solutions to better achieve transparency, flexibility, program simplification, and innovation." ASCRS will be providing comments on steps CMS can take to achieve this goal and strengthen the doctor–patient relationship. CMS expects to use the information collected to develop policies related to the fee schedule in future years.

Patient Relationship Modifiers

As required by MACRA, CMS is also proposing a list of patient relationship modifiers to assist in patient attribution for cost measures. Physicians will be required to begin using the modifiers January 1, 2018.

Both proposed rules include a 60-day comment period, and ASCRS•ASOA will be providing comments. We will continue to review the rules and provide additional information in upcoming issues of Washington Watch Weekly. If you have questions, please contact Allison Madson, manager of regulatory affairs, at amadson@ascrs.org or 703-591-2220.