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

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

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.