This week, ASCRS submitted comments  to CMS on the 2016 Medicare Physician Fee Schedule (MPFS) Proposed Rule. Specifically, the comments addressed CMS’ request for information regarding in-office, surgical-suite cataract surgery, as well as the issues of valuation of the global surgical package, public reporting of data on the Physician Compare website, the Value-Based Payment Modifier cost measures, and initial comments on the Merit-Based Incentive Payment System (MIPS).
Office-Based Surgical Suite Cataract Surgery
Based on the survey data from our membership, which was split, ASCRS did not take a position on office-based, surgical-suite cataract surgery. Our comments responded to specific questions raised by CMS and identified important issues CMS needs to consider before moving forward with an official proposal. We emphasized the high surgical intensity of cataract surgery and stressed the importance of patient safety due to the elderly patient population with co-morbidities and significant medical issues. In focusing on patient safety issues, the comments explain the need for intravenous sedation, as an addition to local or topical anesthesia, that is carefully monitored by appropriate staff, including CRNA’s and anesthesiologists. ASCRS also discusses the need for appropriate infection prevention and control, which requires proper regulation of in-office surgical suites at both federal and state levels, as well as the development of certification requirements. Finally, we emphasize that the option of non-facility cataract surgery might benefit our members who practice in certificate-of-need states and cannot build their own ASCs. These members are either stuck in hospital outpatient departments or multi-facility ASCs, and therefore, may experience difficulty in scheduling cataract surgeries. The results of the ASCRS member survey on office-based cataract surgery will be published in the October edition of EyeWorld.
Value-Based Payment Modifier, Physician Compare, Merit-Based Incentive Payment System
In addition, our comments identify problems with the Value-Based Payment Modifier that particularly impact ophthalmologists, such as the cost measures, and urge CMS to work with us to develop more relevant cost measures going forward. We also requested that CMS should refrain from publishing additional data on Physician Compare until more accurate data is gathered and has been tested. The comments also address the valuation of individual components of the global surgical package and our initial comments regarding the upcoming Merit-Based Incentive Payment System (MIPS) program. ASCRS also signed onto comments  from the Alliance of Specialty Medicine to CMS regarding the 2016 MPFS proposed rule. These comments provided a more detailed description of quality reporting program issues and suggestions for improvement.