Important Clarification on MIPS Diabetes Cost Measure

MarsdenAdvisors has recently secured a crucial clarification on the MIPS Diabetes episode-based Cost measure from the Centers for Medicare and Medicaid Services (CMS). This will result in more specialists that group report MIPS being attributed this measure.

We have informed medical societies and have begun working with them to find a fix to this issue, but, in the meantime, this blog will outline what you need to know.


In 2020, we gave CMS feedback on the Field Testing of the preliminary Diabetes cost measure. In our testing, we found that many ophthalmologists were picked up in attribution of cost for this measure since they treat diabetic eye disease. We brought this concern to CMS as ophthalmologists are not the primary clinicians managing diabetes care.

Based on this concern, CMS indicated that they would revise the measure methodology by adding a requirement that the clinician would only be attributed if they prescribed at least 2 patients with at least 2 diabetes medications.

However, in reviewing this year’s measure specifications, we noticed that CMS had not yet updated the attribution methodology for TIN-level attribution. We reached out to CMS and found that last year’s communications with CMS led to a nationwide misunderstanding about this attribution revision. The revised methodology only applied to clinicians reporting MIPS at the individual level.

CMS Issued Clarification

For all performance years (beginning with 2022 onward) CMS will attribute the Diabetes Cost measure in a different way for those group reporting MIPS than for clinicians reporting at the individual-level.

Group Reporters

This clarification impacts group reporters by increasing the likelihood of specialties that treat diabetic complications, though do not manage diabetes, being attributed this measure. Any group that, for at least 20 patients, bill a Medicare Part B office visit (for which a diabetes ICD-10 is included anywhere on the claim) twice within 180 days will receive a score on this Cost measure.

Individual Level Reporters

A clinician is only attributed this measure if they prescribed at least 2 patients with at least 2 diabetes condition-related medications. For the purposes of this measure, CMS will consider condition-related prescriptions to be the Medicare Part D prescription drugs that are related to managing the patient’s diabetes care. Specifically, CMS includes medications such as insulin formulations, metformin, hydrochlorothiazide, ACE inhibitors, and ARBs.

You can find these prescription medications listed in the Service_Assignment_D tab of the Diabetes measure codes list. If you do not prescribe the Part D medications on this list and you are reporting at the individual clinician level, you should not be picked up on the Diabetes Cost measure.


Next Steps

  • Share this information with your colleagues.
  • Subscribe to our newsletter to get alerts on this and other important issues. You can subscribe using the field in our website footer below.
  • If you are a MarsdenAdvisors client, your 2023 pre-kickoff call recording will include more details on this measure.
  • We are working to put together a coalition of medical societies to get a retroactive fix if possible. If a retroactive fix is not possible, we will work toward a future resolution.
    • Contact your national medical society if you would like them to participate in this coalition.
    • Contact your US federal lawmakers to make them aware of the seriousness of this inappropriate attribution.

If you want hands-on, personalized assistance, contact us and we will have your back.

Jessica Peterson, MD, MPHWritten By: Jessica Peterson, MD, MPH

About the Author: Jessica Peterson, MD, MPH is the Senior Director of Value-Based Care Policy at Anatomy IT.

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