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Potential Future Cost Measure Picks Up Specialists

CMS MIPS cost 2022

Centers for Medicare and Medicaid Services (CMS) and Acumen, a CMS measure development contractor, released draft specifications and field test reports for new MIPS Cost measures in development. Unexpectedly, the draft Emergency Medicine (EM) Cost measure picked up ophthalmology practices in field test. We have worked with our colleagues in emergency medicine to oppose this kind of inappropriate attribution.


As part of the measure development process, CMS and Acumen conduct a Field Test of every complete draft measure prior to proposing the measure for inclusion in MIPS. This means that the measures included in this year's field test could be included in MIPS as early as the 2024 performance year.

Field testing is an opportunity for clinicians and other stakeholders to learn about episode-based cost measures and to provide input on the draft specifications. During a field test, each clinician or group that meets a measure's attribution requirements can access a Field Test report for that measure.

This year, CMS is field testing five episode-based Cost measures -- Emergency Medicine, Low Back Pain, Heart Failure, Major Depressive Disorder, and Psychoses/Related Conditions.

Emergency Medicine Cost Measure

In our testing, we found that some ophthalmologists were picked up in attribution of cost for this measure since they treat ocular conditions in the emergency department (e.g., glaucoma, traumatic eye injuries resulting from gunshot wounds or motor vehicle accidents, severe anterior uveitis in Crohn's patients visiting the ED for exacerbations, etc.).

Given the purpose of this measure is to evaluate the emergency medicine providers who coordinate and control EM care, we have submitted a formal comment letter to CMS and Acumen opposing non-EM clinician attribution.

After Acumen receives feedback, they will share it with the Clinician Expert Workgroup developing the Cost measure. The workgroup will consider this feedback as they work to finalize the measure specification. We do not expect to see a finalized measure anytime soon, but we will keep you updated on any progress.

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Jessica Peterson

Written by Jessica Peterson

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

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