At the recent meeting of the American Optometric Association it was noted that the American Board of Optometry (ABO) was in the process of seeking “approval by CMS” (CMS is the Centers for Medicare and Medicaid Services, the federal agency that administers those programs).  The American Board of Clinical Optometry has been asked if our board will attempt a similar process.  We would like to clarify what this “approval” process means, and why ABCO will not be seeking it at this time.

What is the PQRS "Add-On" And Who Is Eligible for PQRS Money?

If ultimately earned, the CMS “approval” would mean the ABO Board met the conditions for the Medicare Physician Quality Reporting System (PQRS) Maintenance of Certification Program add-on incentive payment. Ths program allows physicians who participate in an approved Maintenance of Certification (MOC) Program AND complete the other requirements (discussed below) to receive an ADDITIONAL 0.5% incentive payment as an add-on to the standard PQRS incentive payments which all optometrists are eligible for.  The CMS approval only allows providers to earn the additional 0.5% incentive IF all requirements are otherwise met; it does not affect their ability to receive the standard PQRS incentive. Any licensed optometrist can receive the PQRS incentive payments if the requirements are met; participation in a “board certification” program is not necessary to to earn the PQRS money. In addition, there is no CMS penalty for not seeking the CMS approval or not participating in the add-on program.

It is important that optometrists understand that board certification is NOT required for their participation as providers in Medicare OR under the PQRS program (other than the additional 0.5% Maintenance of Certification Program). To our knowledge, CMS currently has no plans to make such certification a requirement for optometrists’ participation and the law does not give them the authority to do so. Furthermore, it is the belief of ABCO that seeking such approval may send an erroneous message to CMS that participation in a certification program is necessary to insure competent practice for reimbursement. We at ABCO believe that maintaining optometric licensure is sufficient evidence of competence.

CMS May Deny Payment to Optometrists Even if the MOC Program is CMS Approved

It is also possible that an optometrist who satisfies the MOC requirements to qualify for the PQRS MOC add-on might be denied the payment by CMS in any event. This is because the statute which created the add-on specifically says one must have a "medical license" to qualify. Even if ABCO (or the ABO) were to qualify its MOC process and earn CMS approval for the add-on payment, it is possible that an optometrist who does the considerable work required to qualify for the add-on payment, but that does not also hold a medical license, would still be denied the payment. Moreover, because you must participate in qualified MOC process for "at least one-year," it would be 2013 at the earliest before you would discover that not having a medical license disqualified you from the program, and the time and money spent would be lost. Therefore, we at ABCO will not seek such “approval” by CMS for the PQRS Maintenance of Certification Program at this time.

Seeking the PQRS Add-On Payment is Not Cost-Effective for Doctors

We also do not believe that such approval is cost-effective for our ABCO fellows or for optometrist generally.* The cost of seeking approval is high, and those costs would have to be passed on to ABCO participants.  It is our opinion that the high cost is not offset by the potential revenue that could be earned by ODs who might seek the additional 0.5% MOC Program add-on payment.  An optometrist who bills $100,000 of Medicare fees in a year would receive an additional $500/year from the additional MOC incentive.  The cost to the ABCO fellows in fees and assessments if we were to seek approval would probably exceed this small amount.  Of course, most doctors of optometry probably collect less (many far less) than $100,000 from Medicare yearly.  We wish to maintain our goal of offering ABCO as an alternative, cost-effective path to ensure participation in relevant third party programs. The PQRS MOC add-on incentive simply is not relevant to most of our participants.

Certified Optometrists Must Complete MOC Elements "More Frequently" Than Required to Maintain Certification

It is also important to note that, even if you hold a medical license, or CMS decides not to require one, participation in a CMS approved MOC program is not in and of itself sufficient to receive the additional 0.5% incentive payment. The CMS requirements also require that, to receive the 0.5% MOC incentive, the participant must “More frequently than is required to qualify for or maintain board certification” participate in the certifying entity's maintenance of certification programs and complete qualified MOC Program practice assessments. This means that, even those qualified for the additional incentive as a result of their certification by the ABO and holding an appropriate license, must complete additional self-assessments and practice performance modules over and above what is required to maintain their certification. Therefore, not all certified optometrists will meet the requirement for the small additional incentive. Again, the cost of these self-assessments and practice performance modules (both monetarily and in terms of time spent away from practice) can be substantial, and for most doctors of optometry will not warrant the small amount of additional revenue that can be gained from the additional PQRS bonus.

The MOC Add-On Burdens and Costs Far Exceed Any Potential Benefits

For these reasons, the ABCO feels that the costs and burdens of the CMS approval process for its Maintenance of Certification PQRS incentive far exceed the potential benefits to ABCO fellows. We feel that to seek approval from CMS for the ABCO MOC process would divert ABCO resources away from our primary mission of offering an alternative path to ensure participation in third party programs without offering any meaningful or certain benefits to ABCO Fellows. We also believe that self-assessment can be an important part of every optometric practice, and it is our goal to offer a certification program that incorporates this in a cost-effective manner.  Therefore we have no plans to seek CMS approval at this time.  More information on PQRS can be obtained from the CMS website (http://www.cms.gov/PQRS).

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* It does not appear ABCO is alone in this belief. We note that only 8 of 24 ABMS specialties have sought CMS approval. Among those that did not seek it in 2011 were the American Board of Family Practice and the American Board of Internal Medicine. ABCO believes this is because, though qualifying and being eligible for the payment is not a possible issue for these boards and their certified doctors, like the ABCO, these boards also recognize that the costs and burdens of earning the add-on far exceed the monetary payments one can earn through the program.