This week, ASCRS•ASOA submitted comments on CMS’s third request for information related to episode-based cost measures. The MACRA statute required CMS to develop cost measures to use in MIPS based on specific procedures or conditions, known as episodes. The episode measures are designed to measure the total cost of care associated with the procedure or condition. In the 2017 MACRA final rule, CMS finalized a cataract episode measure, however, the Cost category is weighted at 0% of the final MIPS score, and cost measures will only be calculated for information purposes in the first year of MIPS. ASCRS and the medical community opposed the measures in the Cost category, including the cataract measure, since they relied on the same flawed attribution methodology as used under the Value-Based Payment Modifier that potentially hold physicians accountable for the cost of care they did not provide. In addition, the measures are not risk adjusted.
Over the last year, ASCRS has submitted comments and participated in Technical Expert Panels (TEPs), urging CMS to make significant changes to the methodology it uses to measure cost. In the comments submitted this week, we thank CMS for acknowledging that additional work must be done to improve attribution and risk adjustment. However, since CMS has not made any progress on these issues, we recommend CMS re-focus the effort to develop episodes—the draft list includes hundreds of procedures and conditions from all specialties—and instead develop and test a handful of episodes to ensure they are accurately measuring cost and are risk adjusted. We continued to voice our concerns that if the episodes are not risk adjusted, it will disincentivize physicians from treating the sickest and most complex patients, who typically have the highest cost of care. For the cataract episode, specifically, we continued to recommend CMS only compare surgeries completed in the same site of service to each other. Currently, the facility payment for HOPDs is much greater than the facility payment for ASCs. Ophthalmologists are not always able to choose the site of surgery, and therefore should not be compared to others practicing in facilities with lower reimbursement.
ASCRS continues to participate in the TEP process to provide clinical input on the measures. We are also urging CMS to continue the 0% weighting for the Cost category of MIPS for 2018. We will keep you updated.