This week, ASCRS and the Alliance of Specialty Medicine met with Demetrios Kouzoukas, principal deputy administrator and director of the Center for Medicare at CMS, to discuss regulatory policy priorities for 2019. In the meeting, we continued to advocate for our shared priorities of preserving Medicare fee-for-service and reducing regulatory burden. ASCRS specifically urged CMS to continue to work with the medical community to streamline and simplify MIPS to ensure its long-term viability for physicians remaining in traditional fee-for-service. We reminded CMS that there are currently few specialty-specific alternative payment models (APMs)—and none for ophthalmology—and specialists have very few opportunities to join current models, such as accountable care organizations (ACOs), since they are primary care-focused. Furthermore, we pointed out that MIPS allows specialists, such as ophthalmologists, to report on clinically relevant measures, and most APMs do not include any measures for specialists.
In addition, the Alliance reiterated our concerns with the Administration’s recent policy shifts to allow step therapy in Medicare Advantage (MA) and Part D. We asked that a memo released in August 2018 that allowed step therapy in MA for Part B drugs administered in the office beginning January 1, 2019, be revoked, and reiterated that we opposed proposals in the recent Part D proposed rule that would codify step therapy in MA for Part B drugs and expand its use in Part D. In addition, we continued to press for relief from the burden related to prior authorization and asked CMS to require plans to use standardized and electronic processes to grant authorization. The Alliance will follow up on this meeting with a letter to CMS providing details on the issues discussed. We will keep you updated.