Academy Advocacy Spurs Significant New Flexibility in Quality Payment Program

• CMS is simplifying the Quality Payment Program, especially for small practices, by reducing the number of programs, requirements and measures. The aim is to reduce administrative burdens that interfere with physician-patient relationships.
• More physicians should be able to be exempt from the Quality Payment Program and MIPS because of new minimum thresholds for volume and revenue.
• The Merit-Based Incentive Payment System's cost component continues to be weighted as zero percent of a participant's score. Preserving this is top Academy priority.
• New “virtual groups” proposal echoes concept floated by the Academy earlier this year as a means for enabling ophthalmologist success through IRIS® Registry participation.

The Center for Medicare & Medicaid Services today released its proposed changes to the Quality Payment Program. The draft rule covers how the agency wants the policy to operate in its second year. It represents the beginning of negotiations between the agency and stakeholders on what will be implemented for 2018.

Because this is a proposal, the agency continues to seek physician feedback. The Academy is performing a comprehensive analysis of the proposal and will weigh in later this summer to ensure ophthalmology’s needs are accounted for in the final policy.

What’s good

• The agency is building in significant new flexibility for physicians in the program’s second year.
• The Merit-Based Incentive Payment System’s cost continues to be weighted as zero percent of a physician’s overall score, helping ophthalmologists who are unlikely to fare well in when measured on resource use.
• Bonus points for physicians who manage complex cases. Bonus points for physicians who are part of small practices (15 or fewer clinicians).
• Variable performance period. Physicians need to report on the quality and cost components for a full 12-month calendar year. However, reporting on the advancing care information and improvement activities categories must only be done for 90 days.
• The low-volume threshold would be increased, enabling more physicians to be completely excluded from MIPS reporting. In the proposal, the amount of allowed Part B charges rises to $90,000, from $30,000. The number of beneficiaries seen to qualify for an exemption is doubled, to 200 or less.
• CMS is beginning the path toward allowing virtual groups as a means for physician-reporting.
• A proposed delay in the transition to the 2015 standard for certified electronic health record technology, which was slated to take effect in 2018. The delay would last at least a year.

What needs work

• Less credit given for "topped out" measures. Many of ophthalmology’s quality measures require near-perfect scores to get more than 3-5 points, out of 10. Stricter scoring would make it more difficult for ophthalmologists to perform well.
• IRIS Registry participants can earn more bonus points toward the advancing care information component. However, the proposal's 10 percent remains insufficient. We steadfastly believe that registry participation should count for 100 percent of this category.

What’s next
The Academy will use this summer to communicate to CMS what should remain in the final rule and what needs to be re-thought. We’ll work to educate our members on how the policy’s second-year configuration will affect ophthalmologists. Stay tuned for comprehensive analysis on AAO.org and in Washington Report Express.

Learn more
Access the Academy’s broad array of resources for succeeding in the Quality Payment Program at aao.org/medicare.

If you have any questions, email Academy Advocacy Communications Manager Matt Daigle at mdaigle@aao.org.