AOA asks CMS to simplify MIPS

The American Optometric Association submitted a letter to CMS requesting that Medicare’s Merit-based Incentive Payment System be simplified and more flexible so it becomes a tool for quality improvement rather than a regulatory hurdle for doctors.

The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), enacted in 2015, incorporates new and existing quality payment programs, such as the Physician Quality Reporting System (PQRS), the Value-Based Payment Modifier and meaningful use programs, into one Merit-based Incentive Payment System (MIPS).

CMS issued a Notice of Proposed Rule Making on April 27, 2016, and is soliciting comments to contribute to the development of the final regulations.

The AOA outlined its concerns over several components of the proposed rule in a statement it provided to Primary Care Optometry News.

According to the proposed rule, doctors who bill less than $10,000 to Medicare and see fewer than 100 patients would be excluded from the MIPS performance measurement and the resulting bonuses and penalties. Because this would apply to about half of the 35,000 ODs who are Medicare providers, the AOA is advocating for exclusion based on only one of these two criteria, as well as exclusion for those near retirement.

CMS plans to begin measuring performance through MIPS in 2017, with payment incentives and penalties beginning in 2019, the AOA said. The association is asking for a delay for doctors to become familiar with the program requirements.

The AOA has requested greater flexibility in the meaningful use performance categories, that the percentage of patients for which the quality measures are required be lowered and for optometrists to be permitted to develop specialty-specific Clinical Practice Improvement Activities.

AOA President Andrea P. Thau, OD, said in the statement provided to PCON that the comments the AOA submitted to CMS, “are one step – we will be just as vigilant in championing a policy that supports the flexibility that the Medicare system needs and reinforces patient access to the physicians beneficiaries need, including America’s doctors of optometry.”
In a July 13 statement before the U.S. Senate Committee on Finance, CMS acting administrator Andy Slavitt said CMS has received 3,875 comments during the public comment period and expects to issue final rulemaking after the review is complete.

“It is our intent to allow as much flexibility as possible for clinicians to switch between MIPS and participation in advanced alternative payment models based on what works best for them and their patients,” Slavitt said. “The proposed rule is the latest step in our efforts to work in concert with stakeholders on the front line of care delivery to draw upon their expertise and incorporate their input into the policies for the quality payment program so that together we can achieve the aim of the law.” – by Nancy Hemphill, ELS, FAAO