CMS is opening eight episode-based cost measures, including the Cataract Cost measure, for public comment and reevaluation. Feedback and comments are due by May 28, 2022 at 11:59 pm ET.

Background

In 2019, the first eight episode-based cost measures (listed below) were added to MIPS. For those eligible for at least one of the 23 episode-based cost measures, the total per capita cost measure, or the medicare spending per beneficiary cost measure, the Cost category now constitutes 30% of the MIPS Final Score. As such, these measures can have a substantial impact on MIPS payment adjustments. 

Every three years, episode-based cost measures undergo a comprehensive reevaluation. As the first eight episode-based cost measures have now been in MIPS for three years, the following measures are now open for public comment:

• Routine Cataract Removal with Intraocular Lens Implantation
• Knee Arthroplasty
• Elective Outpatient Percutaneous Coronary Intervention (PCI)
• Intracranial Hemorrhage or Cerebral Infarction
• Simple Pneumonia with Hospitalization
• ST-Elevation Myocardial Infarction (STEMI) with Percutaneous Coronary Intervention (PCI)
• Screening/Surveillance Colonoscopy
• Revascularization for Lower Extremity Chronic Critical Limb Ischemia
  
  

Comprehensive Reevaluation Process

During comprehensive reevaluation, CMS will:

• Collect stakeholder feedback through a public comment process,
• Conduct additional information gathering and testing to determine the scope of reevaluation, and
• Reconvene Clinician Workgroups, as needed, to discuss stakeholder feedback and other updates.
  
  

Make Your Voice Heard

If you are eligible for or have been measured on any of the eight episode-based cost measures that are undergoing reevaluation, this is your opportunity to make your voice heard.

You can submit feedback through this online survey through the end of the public comment period (May 28, 2022 at 11:59 pm ET). You can also attach a PDF or Word document with your comments. 

In their call for public comment, CMS has listed specific questions, in addition to allowing for general comments, for the Cataract Cost measure (bottom of pg. 9) and the Colonoscopy Cost measure (bottom of pg. 11).

Next Steps

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• Let us know if you have any specific feedback on the Cataract Cost measure that you would like us to consider when crafting our comments.

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