Yes, you should submit your Measures Group even if there are less than 20 eligible instances. CMS is anticipating that the following Measures Groups may be affected by the ICD-10-CM code updates:
- Diabetes Measures Group
- Cataracts Measures Group
- Oncology Measures Group
- Cardiovascular Prevention Measures Group
- Diabetic Retinopathy Measures Group
For EPs that submit less than 20 patients for one of the Measure Groups listed above, CMS reserves the option to validate if the EP had less than 20 denominator eligible instances. Upon confirmation of less than 20 denominator eligible instances, CMS will not apply the 2018 PQRS payment adjustment to those EPs.