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Calling All Ophthalmologists: Make Your Voices Heard By May 28th


CMS MIPS cost

The Centers for Medicare & Medicaid Services (CMS) is requesting comment on a Merit-Based Incentive Payment System (MIPS) Cost measure reevaluation that could have a big and negative impact on ophthalmology practices that perform any cataract surgeries. 

MarsdenAdvisors is advocating for our ophthalmology clients and has submitted comments on the reevaluation. But one voice alone will not have the same impact as many, so we have developed a simple comment drafting tool and we encourage all ophthalmologists to use this tool and to submit comments on these potential changes to help make our voices heard. 

The deadline for comment submission is May 28th, 2022 at 11:59 PM ET.

In this article, we will review the potential changes and their impact, and how to join the fight against troublesome changes by making your voice heard

For background on this reevaluation, check out our recent article, CMS Evaluating Cataract Cost Measure.

Cataract Cost Measure Reevaluation Impacts on Ophthalmology

In CMS’ Call for Public Comment for Cost Measure Reevaluation, CMS discusses overarching changes to how the Cataract Cost measure functions. These changes could lead to inappropriately low Cost scores for ophthalmologists. As the Cost category is worth 30% of your MIPS Final Score, a low Cost score could, on its own, cause your MIPS score to fall below the threshold to avoid a penalty.

CMS is considering changes that would have the following impacts:

  • More ophthalmologists, including non-cataract specialists, will get scored on Cost
    • All you need to do is 10 qualifying cataract surgeries during the performance year to be captured by this measure.
    • CMS is considering expanding the list of qualifying CPT codes and eliminating important exclusions. This change would increase the percentage of cataract surgeries that qualify for this measure.
    • In turn, this would lead to practices getting picked up on this measure that should be excluded (e.g., retinal specialists who complete cataract removals as part of more complex procedures). 
    • Practices that perform a low volume of cataract surgeries will get picked up because of the inclusion of complex cases. Because these practices are low volume, one costly complex case could cause their Cost score to plummet.
  • Costs for cataract surgeries would look higher
    • CMS is asking for feedback on what additional care costs should be captured to reflect care in complex cataract cases.
  • Ophthalmologists would be penalized for high pharmaceutical prices
    • CMS is discussing the inclusion of additional drug costs, such as Dexycu and Dextenza, as well as Part D drugs. 
    • Part D drug costs, which are highly variable and determined by market forces, could negatively impact Cost scores, even though they are outside of physician control. 
    • Significant time and resources would have to be spent on investigating individual patients' Part D plans to assess costs and benefits of medications. 
  • Patients would see higher barriers to care
    • Small and rural ophthalmology practices often operate on smaller financial margins. 
    • A large MIPS penalty due to inappropriate cases being captured in this Cost measure could make performing complex cataract surgeries cost-prohibitive, particularly for low-volume practices.

If CMS does not receive enough comments and responses urging them not to make these changes, CMS will likely change this measure in a way that will negatively impact ophthalmologists in MIPS.

How to Make Your Voice Heard

  1. Use our new online MarsdenAdvisors MIPS Cataract Cost Measure Reevaluation Comment Tool to guide you through the process of drafting your response. 
    • Our tool will help you draft your comments and will format them into a pdf for you to submit.
    • The tool includes an email guide to submission, MarsdenAdvisors' interpretation and analysis of the rationale and potential impacts of the suggested changes, as well as guidance in formatting, assembling, and drafting your submission. This tool is completely free– so please share it with your colleagues.
  2. Personalize your responses as much as possible. In our experience, CMS responds best to concrete examples.
  3. When you finish using the tool, it will automatically email you a completed letter that you can submit to CMS using the CMS ​​2022 Comprehensive Reevaluation Public Comment Survey.
    • The deadline for comment submission is May 28th, 2022 at 11:59 PM ET.

Remember: Unique comments are the most powerful advocacy tool we have at this phase of the comprehensive reevaluation process, so be sure to fill your comments with answers that point to the relevance of these discussions to your practice/organization. 

Next Steps

  • If you have any questions, ask us. MarsdenAdvisors is happy to provide you with further information and guidance on submitting your comments to CMS. 
  • Share this information and the MarsdenAdvisors MIPS Cataract Cost Measure Reevaluation Comment Tool with your colleagues. Anyone can use it to make drafting their comments easy and effective. 
  • Subscribe to our newsletter to get alerts on this and other important issues. You can subscribe using the field in our website footer below.

If you want hands-on, personalized assistance, contact us and we will have your back. 

Jessica Peterson

Written by Jessica Peterson

Jessica Peterson, MD, MPH is the Vice President of Health Policy at the consulting firm MarsdenAdvisors.

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