The Centers for Medicare and Medicaid Services (CMS) issued an important clarification on the MIPS Diabetes episode-based Cost measure this week. This will likely result in fewer specialists outside of endocrinology, primary care, and hospital medicine being attributed this measure.   

Background

In 2020, we gave CMS feedback on the Field Testing of the preliminary Diabetes cost measure. In our testing, we found that many ophthalmologists were picked up in attribution of cost for this measure since they treat diabetic eye disease. We brought this concern to CMS as ophthalmologists are not the primary clinicians managing diabetes care. 

Based on this concern, CMS revised the measure methodology by adding a requirement that the clinician would only be attributed if they prescribed at least 2 patients with at least 2 diabetes medications.

In reviewing the latest specification in the proposed rule, we saw that this change was implemented in the methodology, but now it is called a "condition-related prescription" instead of "diabetes medication prescription". Diabetes-related conditions, such as diabetic retinopathy, can require prescription management. In fact, we found ophthalmic injections listed in the Service Assignment code list for the proposed measure. Because of this, we voiced this concern to CMS again.

CMS Issued Clarification

In response to our concern, CMS clarified that, for the purposes of this measure, they will consider condition-related prescriptions to be the Medicare Part D prescription drugs that are related to managing the patient's diabetes care. Specifically, CMS includes medications such as insulin formulations, metformin, hydrochlorothiazide, ACE inhibitors, and ARBs. 

You can find these prescription medications listed in the Service_Assignment_D tab of the Diabetes measure codes list. If you do not prescribe the Part D medications on this list, you should not be picked up on the new Diabetes Cost measure.

Important Note: If you are group reporting and a clinician in your TIN does treat diabetic with the Part D medications on the list, at the group level, your group will receive a score on this Cost measure.

Next Steps

• Share this information with your colleagues.
• Keep an eye out for an announcement of our 2022 QPP and MIPS Final Rule webinar in the coming weeks.
• Review our Top 2022 Final MIPS Changes Report for a quick rundown of major MIPS changes relevant to our specialties.

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