Blog Post

What to do with CMS's new patient-facing encounter codes

January 18, 2017

    CMS recently published a list of patient-facing encounter codes that will affect which reporting requirements and performance metrics apply to clinicians within the Merit-Based Incentive Payment System (MIPS) under MACRA. This list of encounter codes helps radiologists gain clarity on what performance metrics they will be evaluated on under MIPS.

    Quick refresher: MIPS for patient-facing and non-patient-facing physicians

    MIPS reporting requirements and performance categories are weighted differently for patient-facing and non-patient-facing clinicians. Notably, for non-patient-facing clinicians, the cost category within MIPS is weighted at zero, and reporting requirements for clinical improvement activities are cut in half. As a result of this re-weighting, these physicians experience a greater emphasis on quality.

    MIPS performance metrics and reporting requirements

    Resource Use
    Clinical Practice Improvement
    Advancing Care Information
    Six measures including one outcomes measure, or one specialty measure set
    Based on claims, so no reporting; includes 10 episode-based costs and total costs per beneficiary
    Four medium-weighted or two high-weighted measures
    Five required measures
    Same as patient-facing requirements if possible; if not, as many as possible
    Category weighted at zero
    Two medium-weighted or one high-weighted measure
    When enough measures are not applicable or available, category weighted at zero

    What "patient facing" means

    Since the definition of non-patient-facing clinicians in the initial MACRA proposal was written in a way that excluded many radiologists, there were concerns that the full set of MIPS performance metrics put forth did not take their unique needs into account.

    However, in the final rule, the definition of non-patient-facing physicians was revised and broadened for both providers and groups as follows:

    • Non-patient-facing MIPS-eligible clinician: An individual who bills 100 or fewer patient-facing encounters annually.
    • Non-patient-facing MIPS-eligible group: A group in which at least 75% of eligible providers are designated as non-patient-facing clinicians.

    To determine which providers qualify for non-patient-facing status, CMS will use Medicare claims from two twelve-month time periods, with the first beginning September 1 two years prior to the performance year. Providers and groups will only be deemed patient facing if they exceed the thresholds for two consecutive assessment periods.

    Non-patient-facing determination timeline for the 2017 performance year (PY)

    determination timeline


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