Editor’s note: At press time, the proposed revisions to the MACRA legislation, as described in this article, were included in the QPP final rule. See for more on the final rule for 2018.

WHEN THE MACRA legislation became law and MIPS became a reality in 2017, many optometrists bemoaned the regulatory burden of collecting data and reporting various measures, as required to prevent a negative adjustment to their 2019 federal CMS payments. From my conversations with O.D.s, most opted to do the minimum just to avoid the penalty, while others had systems in place to collect and report data on a more consistent basis, and potentially increase their reimbursement in 2019 with a positive adjustment.

In considering your personal path for 2018, with a corresponding payment year of 2020, it is important to know and understand the potential — or, rather, likely — revisions to the program. Let’s start with what we know.


Currently, the Quality Payment Program (QPP) requires that you bill Medicare more than $30,000 in Part B allowed charges a year and provide care for more than 100 Medicare patients a year to participate in 2017.

This summer, there were proposed revisions to MACRA that were focused on reducing the reporting burden on clinicians and increasing flexibility within the overall reporting in 2018.

One of the major proposed changes that would affect optometrists is the revised low-volume threshold for Medicare Part B patients. The proposed low-volume threshold would make exempt clinicians who treat fewer than 200 (up from 100) Medicare Part B patients and who bill less than $90,000 (up from $30,000) in Part B allowed charges in a year.

Another significant proposed change is maintaining a permanent 90-day reporting period for the ACI category, rather than a full year as is the current requirement. By doing so, it is expected that many more would be able to meet the reporting requirement without unnecessary burden on their practices.

For additional detail, interested O.D.s can review the proposed rule here: .


So as of the time of this writing, that’s the current state of MIPS: the proposed rules are not yet final, but many are expressing the need to fine-tune and approve before years’ end. To me, the logical question is: Should I, as a clinician, take the path of exemption?

Exemption is the path of least resistance, and with the low-volume rules being revised to the benefit of many O.D.s, it’s my experience that many will choose to do that.

The larger question is: Do I want to be invisible within the health care quality reporting system?

With all healthcare carriers moving in the direction of outcome-based care, quality reporting will certainly be an important metric that they will rely on in deciding which providers will be part of their network. So, this isn’t just a Medicare issue — it has the potential to affect all aspects of your practice that are engrained with third-party coverage and payment, including all other major medical carriers and, most likely, managed vision care plans.


The final question you need to answer is simple: Am I going to be an active part of the healthcare system going forward, or am I going to remain invisible and let change happen to me? OM