MIPS: Merit-Based Incentive Payment System

ASRS is advocating for:

  • Simplifying the proposed MIPS program to ensure that it facilitates meaningful opportunities for performance improvement while decreasing administrative and compliance burdens; 
  • Providing a more robust advanced payment model (APM) pathway that can support physicians who want to make the transition to new delivery and payment models; and 
  • Accommodating the needs of physicians in rural, solo, or small practices in order to enhance their opportunities for success and avoid unintended consequences.

ASRS joined the AMA and other medical specialties to advocate for a gradual transition into the Program. Participation in 2018-9 is critical to avoid a penalty. Failure to participate in MIPS in 2019 will result in a 7% across-the-board reduction in payments for Medicare services performed in 2021.

 What Do I Have to Do?

To participate in MIPS, retina specialists submit measures and attest to activities to fulfill requirements in three of the four categories: quality, advancing care information, and clinical practice improvement activities. CMS collects physicians' information from claims for the cost category. Based on performance in a given year, CMS adjusts Medicare payments two years later.  Here are some resources to get you started:

Important MIPS Deadlines

  • December 31- 2019 Promoting Interoperability Hardship Exception and Extreme and Uncontrollable Circumstances Applications deadline
  • December 31 - 2020 virtual group election closes

 MIPS Background

The Merit-Based Incentive Payment System started its third year in 2019. The Medicare Access and CHIP Reauthorization Act of 2015 (MACRA) required CMS to streamline to a new incentive program and replace its three legacy programs:

Physician Quality Reporting System (PQRS)

Value-Based Payment Modifier (VM)

Medicare EHR Incentive Program (“Meaningful Use”)

Effective in 2017, aspects of each of these legacy programs were combined to create the Quality Payment Program (QPP). QPP provides for two participation tracks: MIPS and Advanced Alternative Payment Models (Advanced APMs). Currently, there is no APM option for retina specialists. 

Episode Groupers: Through a contractor, Medicare is developing episode groupers that will pay a fixed sum for a given procedure that will be split among involved hospitals and other providers. ASRS, American Academy of Ophthalmology (AAO), American Optometry Association (AOA) and American Society of Cataract and Refractive Surgery (ASCRS) have representatives on the ophthalmology workgroup charged with developing episode groupers. The ophthalmology workgroup identified routine cataract surgery w/IOL (66984) as their first ophthalmology episode grouper code. ASRS is continuing to monitor whether a retina related grouper will be developed.


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