Samuel D. Pierce
CMS published its final rule for Medicare’s 2019 Physician Fee Schedule, and “the American Optometric Association and affiliates left their mark on key policy considerations that affect optometry and secured a resounding affirmation of comprehensive eye examinations,” according to an announcement from the AOA.
The final rule, published Nov. 1, updated payment policies, rates and quality provisions for services furnished under the Physician Fee Schedule (PFS) as of Jan. 1, with the goal to improve accessibility, quality, affordability and innovation.
AOA President Samuel D. Pierce, OD, spoke with Primary Care Optometry News about the new policies and what they mean for optometry.
PCON: What do you see as the biggest wins of the PFS rulemaking for the industry? What kind of advocacy efforts did the AOA undertake to educate lawmakers on optometry’s — and patients’ needs?
Pierce: In July, CMS proposed several new and significant policy changes for calendar year (CY) 2019 that would impact how doctors of optometry and other physicians must furnish care and practice. The AOA immediately responded by engaging in a series of meetings with CMS officials and crafting detailed public comments that argued for very specific policy adjustments. The AOA’s clear and patient-focused messages resonated, and the final rule reflects recommendations that are right for the practice of health care.
However, the biggest win for optometry was securing a resounding affirmation of comprehensive eye exams — demonstrating that AOA’s patient-focused argument on the importance of eye exams broke through. In fact, last year, the AOA offered CMS an innovative policy recommendation that would create a Quality Payment Program (MIPS) improvement activity to encourage greater patient education efforts nationwide about in-person, comprehensive eye exams. The CMS embraced this recommendation and finalized it for the CY 2019 performance period and thereafter.
Specifically, CMS notes that in order for providers to receive credit for this activity, MIPS-eligible clinicians must provide literature or facilitate conversations about the topic "using resources such as the Think About Your Eyes campaign and/or referring patients to resources providing no-cost eye exams ... such as the AOA’s Vision USA." Now, for CY 2019, any doctor type who educates patients on the value of comprehensive eye exams can earn this MIPS improvement activity credit.
However, the proposal was initially met with opposition from the American Academy of Ophthalmology (AAO), who urged CMS against finalizing the proposal. The AAO commented that "the proposed activity description is very likely to lead to increases in unnecessary expenditures both for public programs and for low-income patients."
CMS patently rejected the AAO's comment and responded by indicating, "since comprehensive eye exams are relatively low-cost interventions, and early detection of conditions that can be identified through an eye exam may reduce more costly treatment later, we believe this improvement activity will not unnecessarily increase expenditures for public programs and the target population." Overall, CMS noted the improvement activity "will have a positive impact on patient care and promote health equity."
At a time when our detractors oppose us at every opportunity and every level, AOA's cogent and patient-care-focused advocacy efforts rise above the fray and prevail. CMS made decisions that were right for the practice of health care and right for the care of our patients.
Disclosure: Pierce is president of the AOA.