MIPS – Questions Answered on Program that Can Affect Reimbursements

Recently, AOA and COA have received many questions related to the new Medicare Merit-Based Incentive Payment System (MIPS) and CMS-related requirements and deadlines. These are important questions as doctors do not want to suffer negative Medicare reimbursement adjustments that would begin in 2019 by not participating in MIPs. The following is a lengthy, but hopefully informative discussion of the MIPs and related programs rollout.

Generally

It is important for doctors of optometry to understand that the program requirements for MIPS are not yet finalized, though the final program requirements are expected to be released very soon. Based on the questions received, we wanted to ensure that doctors are aware that participating in a Practice Transformation Network (PTN) is not a Medicare requirement. Rather, CMS has proposed that participating in a CMS Transforming Clinical Practice Initiative and the related Practice Transformation Networks (PTN) and Support and Alignment Networks (SAN) may be considered a Clinical Practice Improvement Activity that can help doctors to meet one set of program requirements under the proposed program structure. Participation in a PTN or SAN is just one of many options available for meeting certain program requirements. While there may be specific deadlines related to participation in a PTN and SAN, there is no overall CMS related MIPS deadline at this point. 

CMS Announces Needed Flexibility for Merit Based Incentive Payment System

On September 8, in response to concerns raised by the American Optometric Association and other physician organizations, the Centers for Medicare & Medicaid Services (CMS) announced that CMS will offer needed flexibility for the first year of the Merit Based Incentive Payment System (MIPS). CMS has indicated that doctors will have options with regard to how to participate in this new program in 2017.

• Test the Quality Payment Program by submitting at least some data for the program.
• Participate for part of the calendar year.
• Participate for the full calendar year

Please note that CMS had proposed that participating in a CMS Transforming Clinical Practice Initiative (TCPI) and the related Practice Transformation Networks (PTN) and Support and Alignment Networks (SAN) may be considered a Clinical Practice Improvement Activity that can help doctors to meet program requirements under the proposed program structure.  Participation in a TCPI-related program, such as a PTN, is not required, but can help to earn points under the proposed system. Similarly, there are several proposed activities related to Qualified Clinical Data Registry use, such as AOA MORE, that can also help doctor to earn points under the proposed program requirements.  

CMS intends to release final rules related to these program options prior to November 1. Look for additional updates in the coming weeks. Read more from CMS here. If you have questions regarding MIPS, please contact Kara Webb at the American Optometric Association at: kcwebb@aoa.org

CMS Proposed Changes for 2016 Meaningful Use Program Impact AOA MORE

Responding to significant concerns from physicians organizations, such as AOA, the CMS has proposed to change the electronic health record (EHR) reporting period for Meaningful Use to 90 days in 2016. This proposed change to shorten the previous 12 month reporting period could have a positive impact for many doctors of optometry.

Under the Meaningful Use program, one of the objectives requires doctors to engage with a specialized registry, such as AOA MORE (the Measures and Outcomes Registry for EyeCare)  To receive credit for this objective, at a minimum, doctors of optometry must register their intent to submit data to a registry with the first 60 days of their EHR reporting period. If CMS finalizes the 90 day reporting period for this year, doctors who choose the last 90 days of 2016 as their reporting period will have more time to register with AOA MORE to meet this program requirement. Visit www.aoa.org/MORE to register with AOA MORE and look for updates on CMS final actions on this proposal in the coming weeks.