Advocacy & Practice Updates — Clinical Updates
ASRS Comments on 2024 Fee Schedule Proposed Rule Support New Retina Measures and the RUC Process, Recommend Changes to MIPS
This week, ASRS submitted comments on the 2024 Medicare Physician Fee Schedule proposed rule. In its comments, ASRS thanks CMS for proposing the three new retina-specific and ASRS-developed quality measures and recommends they be finalized for use in MIPS for 2024. In addition, the Society thanks CMS for listening and acting on its previous comments and testimony by proposing exemptions for small-volume single-dose Part B drugs from the policy requiring manufacturers rebate Medicare for unused portions of drug.
In response to a request for information (RFI) in the proposed rule on valuation of E/M services, ASRS reiterates its long-standing support for the AMA’s Relative Value Update Committee (RUC) process as the appropriate method for valuing E/M codes, as well as all other physician services. ASRS continues to request CMS listen to the RUC’s recommendation and apply current E/M values to post-operative visits included in global surgery codes.
Finally, responding to another RFI on the future of the MIPS program, ASRS recommends that CMS move away from its recent attempts to broaden the program by removing specialty-specific measures and requiring all physicians to use primary care-based measures. ASRS notes that finalizing the new retina-specific measures would be a positive step to differentiate the care retina specialists provide and assist beneficiaries in choosing the appropriate physician for their care.
ASRS also signed on to a joint comment letter with the Alliance of Specialty Medicine and joined in comments on the 2024 hospital outpatient/ASC rule with other ophthalmic groups.
The final rule is expected to be released in November.
Posted September 13, 2023