How do you determine a non-patient facing eligible clinician in your practice who still has to report for the Quality Payment Program under MIPS?
CMS is conducting eligibility determinations based on claims data from Sept. 1, 2015, through August 31, 2016, and another period from Sept. 1, 2016, through August 31, 2017. Non-patient facing clinicians who have been identified in the first period will not have their status change because of data in the second period – that will just be used to identify more who may have been missed during the first determination set. This information will be updated on the CMS website: www.qpp.cms.gov at a later date.
Clinicians who bill 100 or fewer patient-facing encounters (claims that include E&M codes, surgical procedure codes and visit codes) will be considered non-patient facing. Groups are considered non-patient facing if more than 75 percent of those clinicians are determined non-patient facing. A group is defined as one that CMS would identify by a single tax identifier.
CMS will also use Medicare telehealth service claims in the determination. For a full list of those codes, visit: www.cms.gov/Medicare/Medicare-General-Information/Telehealth/Telehealth-Codes.html
How non-patient facing clinicians will participate in MIPS is slightly different than other clinicians. In addition to not having to report in the ACI (Advancing Care Information) category, they will have a re-weighted performance score with the Quality category set at 85 percent of the total. Groups that elect to report using the CAHPS survey for MIPS (Consumer Assessment of Healthcare Providers and Systems) will not have those non-patient facing clinicians as focal providers. There are a number of specialty measure sets for clinicians under Pathology, Diagnostic Radiology, Anesthesiology, etc. that can be viewed at https://qpp.cms.gov/measures/quality. Many quality measures for non-patient facing clinicians will be able to be reported through qualified registries. It is also suggested that specialists contact their specialty society to see if they have compiled a suggested list of measures.
Non-patient-facing clinicians must also report on Improvement Activities (IA) as 15 percent of the total score. Requirements include one high-weighted activity or two medium-weighted activities.
The information for this article was taken from a webinar, Diving into the Details of MIPS, presented in early May by the Quality Reporting Engagement Group. Our team of experts can help determine which of your clinicians are eligible for MIPS reporting. If you have any questions, please contact firstname.lastname@example.org.