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8 EW ASCRS NEWS January 2017 a separate weight of the final MIPS scores. For the first year, the category weights are: Quality (60% of MIPS score), Resource Use (0% of MIPS score), Improvement Activities (15% of MIPS score), and Advancing Care Information (25% of MIPS score). Following advocacy from ASCRS and the medical community, CMS lowered the reporting threshold for the Quality performance category to 50% of eligible patients depending on the reporting method. Physicians are required to report on 50% of Medicare Part B patients, and for registry reporting, physicians would be required to report on 50% of all patients, not just Part B. The previ- ously proposed policy would have required reporting on 90% of all patients through registry and 80% of patients via claims. CMS also finalized its proposal to require physicians to report on at least six quality measures, with at least one being an outcome mea- sure, but did not finalize the pro- posal that at least one measure be cross-cutting. ASCRS urged CMS to reinstate its previous PQRS measures groups, such as cataract and diabetic retinopathy, but these are not in- cluded in the final rule. ASCRS will continue to advocate for this inclu- sion. CMS also retained the existing ophthalmology measures from the proposed rule, which are currently available for PQRS reporting. In addition, CMS is not finalizing the proposal to include ASCRS-opposed global and population measures in the quality score; however, CMS will calculate the measures based on claims for informational purposes. CMS lowered the category weight for Resource Use, or Cost, to 0% of the overall MIPS score for the 2017 performance period. This was advocated for by ASCRS and the medical community so that physi- cians are not penalized for the cost of care they did not provide. CMS plans to calculate the proposed cost measures based on the 2017 perfor- mance for informational purposes. The weight for this category will increase in future years to 10% in 2020, based on 2018 performance, and 30% for payment year 2021 and beyond. Also in the Resource Use category, CMS finalized a list of 41 episode-based resource use measures, including one for cataract and lens procedures. ASCRS will continue to advocate for changes to the attribu- tion methodology in this category and for a new, more transparent risk adjustment methodology. For Improvement Activities, which account for 15% of the MIPS score, CMS has shortened the title of the proposed Clinical Practice Improvement Activities category to Improvement Activities. In addition, CMS modified its proposal to lower the number of activities that must be reported for full achievement. The requirement will be four medi- um-weighted or two high-weighted activities for 2017. For small practic- es with 15 or fewer Medicare provid- ers, CMS reduced the requirement to only one high-weighted or two medium-weighted activities. Under the Advancing Care Information (ACI) category, CMS finalized its proposal to measure a provider's use of Certified EHR Technology (CEHRT) through the Advancing Care Information Tech- nology Category by calculating a base and a performance score. CMS reduced the number of measures required in the base score, however, ASCRS still opposes CMS' policy to retain the "all-or-nothing" scoring for the base score whereby a phy- sician must have at least one in the numerator of each of the base measures. ASCRS is advocating for simplification of the scoring for this category and removal of the all-or- nothing provision of the base score. As a whole, the MIPS final score for the 2017 performance period will be determined by adding the weight- ed scores from the three categories: Quality, Improvement Activities, and ACI. Additionally, due to the flexible reporting requirements for the first performance year, any final score above the performance thresh- old of 3 points will be eligible for a bonus. Final scores above 70 qualify as "exceptional performance" and are eligible for an additional bonus. CMS increased the Medicare low-volume threshold that exempts physicians from all performance re- porting to $30,000 in revenue or 100 patients, up from $10,000 in annual Medicare revenue and less than 100 Medicare patients in the proposed rule, estimating that this change will exempt 32.5% of physicians and other clinicians from the program. However, it is still likely that most ophthalmologists will not qualify for the low volume exemption. The new rule includes informa- tion on Advanced APMs. Advanced APMs must incorporate a quality measure component; 50% of partic- ipants must use EHR; and the model must have two-sided risks. In addi- tion, CMS finalized the proposed payment and patient thresholds for providers to be considered Qualified Participants (QPs) and thus eligible for a 5% bonus. With these require- ments, ASCRS thinks the majority of its members will not qualify as QPs and will participate in MIPS. Physicians practicing in APMs that do not meet the payment or patient thresholds, or are not considered "advanced" APMs—such as Track 1 ACOs—are eligible to earn credit for MIPS through their participation in these models. Ophthalmologists practicing in Track 1 ACOs would be required to report quality data to the ACO, would receive full credit for Improvement Activities, and would be required to report ACI data on their own to receive a MIPS score. For full information on partici- pating in MACRA, ASCRS members have exclusive access to the online MACRA Center at ascrs.org/macra- center. EW Contact information Allison Dickert Madson: amadson@ascrs.org MACRA continued from page 3 ORA ™ SYSTEM IMPORTANT PRODUCT INFORMATION CAUTION: Federal (USA) law restricts this device to sale by, or on the order of, a physician. INTENDED USE: The ORA ™ System uses wavefront aberrometry data in the measurement and analysis of the refractive power of the eye (i.e. sphere, cylinder, and axis measurements) to support cataract surgical procedures. CONTRAINDICATIONS: The ORA ™ System is contraindicated for patients: who have progressive retinal pathology such as diabetic retinopathy, macular degeneration, or any other pathology that the physician deems would interfere with patient fixation; who have corneal pathology such as Fuchs', EBMD, keratoconus, advanced pterygium impairing the cornea, or any other pathology that the physician deems would interfere with the measurement process; whose preoperative regimen includes residual viscous substances left on the corneal surface such as lidocaine gel or viscoelastics; with visually significant media opacity (such as prominent floaters or asteroid hyalosis) what will either limit or prohibit the measurement process; or who have received retro or peribulbar block or any other treatment that impairs their ability to visualize the fixation light. In addition, utilization of iris hooks during an ORA ™ System image capture is contraindicated, because the use of iris hooks will yield inaccurate measurements. WARNINGS AND PRECAUTIONS: Significant central corneal irregularities resulting in higher order aberrations might yield inaccurate refractive measurements. Post refractive keratectomy eyes might yield inaccurate refractive measurement. The safety and effectiveness of using the data from the ORA ™ System have not been established for determining treatments involving higher order aberrations of the eye such as coma and spherical aberrations. The ORA ™ System is intended for use by qualified health personnel only. Improper use of this device may result in exposure to dangerous voltage or hazardous laser-like radiation exposure. Do not operate the ORA ™ System in the presence of flammable anesthetics or volatile solvents such as alcohol or benzene, or in locations that present an explosion hazard. ATTENTION: Refer to the ORA ™ System Operator's Manual for a complete description of proper use and maintenance of the ORA ™ System, as well as a complete list of contraindications, warnings and precautions. Advancing CATARACT SURGERY LenSx ® LASER ® © 2015 Novartis 12/15 US-ORA-15-E-0947

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