Ophthalmologists who have at least 10 attributed cataract episodes in the performance period between June 1, 2016, and May 31, 2017, are now able to download a draft feedback report on an episode-based cost measure for cataract surgery currently being developed for inclusion in the Cost category of MIPS. As we have previously reported, the Cost category will not be included in the 2017 MIPS final score, and CMS proposes the same for 2018. Therefore, these reports are for information only and to test the measures. The reports are available for review in the CMS Enterprise Portal, similar to QRUR and PQRS reports. See below for full download instructions.
CMS will be holding two national provider calls to review these episode measures on:
Please note, the same content will be included in each call.
You can provide feedback on the draft reports through a confidential online survey until Nov. 15, 2017. ASCRS will also be submitting comments.
If you need assistance interpreting your report, please contact Allison Madson, manager of regulatory affairs, at firstname.lastname@example.org or call the MACRA hotline at 703-383-5724 to schedule a call.
As we alerted you last week, ASCRS has been participating in the development of the cataract episode measure by serving on a CMS-appointed technical expert panel (TEP). We have long been critical of CMS’ existing cost measures—first finalized as part of the Value-Based Payment Modifier (VBPM) and then continued in the Cost category of MIPS—since the measures are primary care-based, use a flawed attribution methodology, and are not risk adjusted. As directed by the MACRA statute, CMS must develop episode-based measures for MIPS that will be more relevant to specialty care. These episode-based measures will be used in addition to the existing measures. CMS is beginning the process by developing and testing eight episode measures, including cataract surgery.
In the development of the new cataract episode measure being tested, ASCRS and our physician representative on the TEP have sought to influence the process so that physicians performing cataract surgery will know which patients are attributed to them, and understand which costs are included in the measure.
Following that advocacy, the new measure currently only includes routine cataract surgery (66984) and excludes patients with significant ocular comorbidities using PQRS measure exclusionary criteria. Most significantly, the measure breaks cataract surgeries into several sub-groups, facility type ASC vs. HOPD, co-managed and not co-managed, and bilateral vs. unilateral, to ensure physicians are not being evaluated on factors outside of their control.
Please keep in mind that these measures are still in draft form and may change following this test phase. If you did not receive a report, a mock report is available for review on CMS’ website.
How to download your report:
The field test reports will be distributed through the CMS Enterprise Portal, which CMS has used in the past for distributing Quality and Resource Use Reports. CMS has published an Access Guide for downloading the field test reports.
While we expect most ASCRS members will receive a report, physicians who did not bill 66984 under Medicare Part B between the test dates or did not have enough attributed episodes will not receive a report. If you do not receive a report, CMS is making resources, including a mock report, available on its website for review and comment.
If you have additional questions, please contact Allison Madson, manager of regulatory affairs, at email@example.com or 703-591-2220.