In comments on the CY 2018 Medicare Physician Fee Schedule (MPFS) proposed rule, ASCRS, joined by the Outpatient Ophthalmic Surgery Society (OOSS), thanked CMS for proposals that would reduce reporting requirements for 2016 PQRS and the Value-Based Payment Modifier (VBPM) to avoid 2018 penalties, and requests the agency modify their proposals further to ensure more physicians avoid penalties. CMS is proposing to reduce the required number of measures submitted for 2016 PQRS from nine to six, and not require participants to meet certain domains or submit a cross-cutting measure. However, we recommend CMS hold any physician who attempted to submit any data in 2016 harmless from the PQRS penalty. CMS is also proposing to hold physicians harmless from downward payment adjustments from 2016 VBPM quality tiering, if they satisfy the requirements for PQRS. ASCRS and OOSS support that proposal and reiterated that CMS should consider any physician who attempted to submit quality data in 2016 as satisfying PQRS, and therefore not subject to downward payment adjustments from quality tiering under the VBPM. We also recommended CMS create an “administrative burden” hardship exemption for 2016 Meaningful Use. We thanked CMS for its efforts to reduce the regulatory burden on physicians and practices as they transition to the new MIPS program.
In regard to other provisions of the proposed rule, we offered our support for CMS’ proposal to accept most RUC recommendations for code revaluations. In addition, we supported CMS’ proposal to make reporting patient relationship modifiers voluntary in 2018 and requested CMS provide additional information on how they will be included in cost measure attribution. Finally, we requested that CMS rethink its policy to collect post-operative visit data on certain high-volume 10- and 90-day global codes in certain states.
ASCRS is also joining in comments on the proposed rule with the Alliance of Specialty Medicine. The final rule is expected in late October or early November. We will keep you updated.