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CMS Distributes Cost Measure Field Test Reports; ASCRS Advocacy Prompts Modifications to Total Per Capita Cost of Care Measure that Should Exclude Most Ophthalmologists from Attribution

This week, CMS began field testing new and modified Cost measures, including several new non-ophthalmic episode-based measures and modified Total Per Capita Cost (TCC) and Medicare Spending Per Beneficiary (MSPB) measures. ASCRS has been serving on a technical expert panel (TEP) tasked with developing and updating cost measures and advocated for changes to the attribution methodology to ensure that ophthalmologists and other specialists are not attributed the TCC measure that is primary care-based. Currently, patients are attributed to physicians in the TCC measure through a flawed two-step process. First, if the patient sees a primary care physician during the performance period, they are attributed to that physician. If they do not see a primary care physician, then the patient is attributed to the physician who provided the plurality of E/M services for that patient, which could be an ophthalmologist. We have long argued that since this measure is primary care-based, and ophthalmologists have no ability to influence the cost of care provided by other physicians, they should not be attributed the measure. Based on our advocacy on the TEP, the measure will still use the two-step attribution, but exclude physicians from attribution if they provide other non-primary care services, such as ophthalmic services.

Ophthalmologists can confirm that they are not attributed the TCC measure by visiting their CMS Enterprise Portal. The MSPB measure should also not be attributed to ophthalmologists, since it is inpatient-based. If you have questions, or need assistance, please contact Allison Madson, manager of regulatory affairs, at or 703-591-2220.

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