Skip to main content

Ophthalmic Community Emphasizes Cost Measure Issues With CMS

The Academy and other groups participated in an Oct. 4 meeting with CMS in which we successfully convinced the agency that the diabetes cost measure is not applicable to ophthalmology. Members who believe they have been incorrectly applied cost measures have until 8 p.m. ET Monday, Oct. 9, to submit a targeted review.

After repeated entreaties urging the Centers for Medicare & Medicaid Services (CMS) to correct issues in its Merit-Based Incentive Payment System (MIPS) diabetes cost measure methodology, the Academy and others from the ophthalmic community successfully clarified our concerns with the Center for Clinical Standards and Quality team and its measure development contractor, Acumen.

We were able to help CMS understand that ophthalmologists typically practice in a single specialty group and are not responsible for managing diabetes care.

CMS committed to fixing the group attribution in its calculation of 2023 cost measure performance and plans to improve transparency by sharing details on the revised measure publicly. While the agency did not commit to fixing the problem in 2022 performance scores, it assured us it would discuss its options internally.

The Academy has heard from members that in their final score preview for the 2022 MIPS performance year, CMS has incorrectly applied the cost measure for managing patients with diabetes to some ophthalmologists who participate in MIPS as a group.

Working with the American Society of Retina Specialists (ASRS) and American Society of Cataract and Refractive Surgery (ASCRS), we raised the issue in a joint letter on Jun. 28.

Our meeting Wednesday was a culmination of efforts to engage CMS and we were pleased that Michelle Schreiber, MD, deputy director for Quality & Value, attended the meeting. While CMS is considering how to address 2022 scores, Dr. Schreiber encourages ophthalmologists being scored on the diabetes cost measure to file a targeted review. CMS plans to take another look at the targeted reviews that have been submitted related to this particular cost measure, including the ones that have been denied.

The Academy continues to press CMS to also correct problems related to the cataract cost measure. CMS has alerted us that it has updated the patient level data files to remove duplicates, but we remain concerned about the effectiveness of this process, due to the lack of transparency from the agency regarding its efforts. We are in the process of scheduling a meeting with CMS to discuss these concerns.

Targeted Review

If you see these issues or believe another error has been made in your MIPS score, submit a request for a targeted review by 8 p.m. ET Monday, Oct. 9. The Academy has developed suggested language for you to use in your targeted review, depending which cost measure you believe has been incorrectly calculated for you or your group. Tailor these templates to your specific practice and situation.

Here is the draft language:

Diabetes Cost Measure

Cataract Cost Measure

Related Stories

Member exclusive - Locked
Advocacy on Capitol Hill

Make Your Voice Heard: Comment on the 2027 Medicare Physician Fee Schedule

The draft 2027 Medicare Physician Fee Schedule has been released, and comments on it are due to CMS by Sept. 14. Join the Academy in making your voice heard. See what's at stake for ophthalmology.

Member exclusive - Locked
Ophthalmologist Jeffrey Carlisle, MD, and team

CMS Proposes Significant MIPS Changes in 2027 Fee Schedule

The Centers for Medicare and Medicaid Services’ (CMS) proposed 2027 rule would sunset Traditional MIPS, mandate MVP reporting, and add a core measure requirement. Here's what you need to know.

Member exclusive - Locked Fallback image

The Academy’s IRIS Registry Continues to Help Ophthalmologists Succeed in MIPS

While cost category concerns remain, The Academy's clinical data registry again helped our members achieve strong performance in the Merit-Based Incentive Payment System (MIPS).

Latest Updates

Member exclusive - Locked
Glaucoma Screening

Academy Sponsors Glaucoma Screenings at the American Legion Convention

Academy-supported screenings help veterans and their families identify potentially serious eye conditions.

Member exclusive - Locked
Safe Surgery Action Fund

Introducing the Safe Surgery Action Fund

The new name reflects an expanded mission to defend physician-led surgical eye care through support for legislative, regulatory, legal, and public advocacy.

Member exclusive - Locked
Advocacy on Capitol Hill

Academy Joins Coalition Pushing Back on Modifier -25 Proposal

The Academy is now part of a coalition fighting against a proposed CMS policy that could reduce payments for some services by as much as 50%.