Even though CMS already has released its proposal for the Quality Payment Program (QPP) and MIPS for performance year 2020, there are still several months left in 2019, so ASCRS ASOA members should take the opportunity to ensure they are well-versed in the program elements for this year that impact 2021 payments. Specifically, we recommend practices download our members-only guide to the cataract episode-based cost measure that is new in the Cost category of MIPS for 2019.
The new measure includes the total cost of providing cataract surgery, and the guide includes information on the measure attribution, included services and drugs, and scoring, as well as insights and FAQs to help practices understand the measure. Additional information on the Cost category, which counts for 15% of the final MIPS score for this year, is available in the ASCRS ASOA MACRA Center.
As a reminder, the cataract episode measure includes all costs of care related to cataract surgery 60 days prior to and 90 days following the procedure. It includes the cost of pre-op testing, the surgeon’s professional fee, the facility fee, anesthesia, and any separately billable post-operative care, such as additional procedures related to complications. Importantly, it also includes some separately payable Part B drugs, including one administered during the surgical procedure and paid on pass-through, Omidria, when billed with HCPCS Code C9447.
ASCRS ASOA opposes the inclusion of any pass-through drug in the episode measure because it defeats the purpose of pass-through, which is to introduce certain high-cost new and innovative drugs to the marketplace and provide unbiased utilization data to CMS for adjusting the facility fee when the drug is no longer on pass-through. ASCRS ASOA is advocating to remove any pass-through drug from the episode measure and met directly with CMS today about this issue.
Patients are only attributed to the measure if they are Medicare Part B beneficiaries and undergo uncomplicated cataract surgery (CPT 66984). No other cataract surgeries, such as complex surgery (CPT 66982), are included in the measure. In addition, any patient with a significant ocular co-morbidity, such as glaucoma or macular degeneration, is excluded. The full list of excluded diagnoses is identical to the quality measure 191, Cataract Surgery: 20/40 or Better Visual Acuity 90 Days Following Cataract Surgery, and is included in the new guide on this measure. To be scored on this measure, the surgeon must have at least 10 attributed cases.
Finally, the measure is subgrouped to ensure that only like surgeries are compared to like. Specifically, the cost of surgeries performed in ASCs are compared only to other surgeries performed in ASCs, while those in HOPDs are compared to others in the same setting. In addition, the measure compares separately patients who had one eye operated on, as opposed to both eyes within the same global period. The score of the measure is determined by comparing the surgeon’s costs to an expected national average.
If you have questions or need additional assistance, please call the ASCRS ASOA MACRA Hotline at 703-383-5724 or email Allison Madson, manager of regulatory affairs, at firstname.lastname@example.org.