Non-patient Facing Clinicians Get a Reprieve
Quality reporting changes in 2018 for MIPS eligible clinicians who don’t see most of their patients face to face.
Clinicians, clinician groups, and virtual groups eligible to participate in the Merit-based Incentive Payment System (MIPS) should know what percentage of their patient encounters are considered non-patient facing. Although self-identification is not required in 2018, the reporting requirements are different from those for patient-facing encounters.
Defining Non-patient Facing
The Centers for Medicare & Medicaid Services (CMS) defines a “non-patient facing” clinician or group in the 2018 Quality Payment Program final rule as:
… an individual MIPS eligible clinician that bills 100 or fewer patient facing encounters (including Medicare telehealth services defined in section 1834(m) of the Act) during the non-patient facing determination period, and a group or virtual group provided that more than 75 percent of the NPIs billing under the group’s TIN or within a virtual group, as applicable, meet the definition of a non-patient facing individual MIPS eligible clinician during the non-patient facing determination period.
Note that the 2018 Quality Payment Program final rule modifies the definition of a non-patient facing MIPS eligible clinician to also include virtual groups — a new concept implemented this year.
MIPS eligible clinicians, clinician groups, and virtual groups with predominately non-patient facing encounters have alternative requirements for the Advancing Care Information and Improvement Activities performance categories.
MIPS improvement activities gauge participation in activities that improve clinical practice, such as:
- Ongoing care coordination
- Clinician and patient shared decision-making
- Regularly using patient safety practices
- Expanding practice access
Non-patient facing MIPS eligible clinicians (as well as groups with 15 or fewer clinicians and clinicians in a rural or health professional shortage area (HPSA)) should attest to completing up to two activities of any weight for a minimum of 90 consecutive days in 2018.
Each activity is weighted either medium or high. To achieve the maximum 40 points for the Improvement Activity performance score, you may select either of these combinations:
- 1 high-weighted activity
- 2 medium-weighted activities
Medium-weighted activities are worth 20 points of the total Improvement Activity performance category’s score, and high-weighted activities are worth 40 points.
In comparison, the requirements are double for clinicians in solo and group practice (who are not Advanced Payment Model participants, and have more than 15 clinicians who aren’t in a rural area or HPSA): two high-weighted activities; one high-weighted activity and two medium-weighted activities; or four medium-weighted activities.
Advancing Care Information
MIPS eligible clinicians and groups deemed non-patient facing during the non-patient facing determination periods are exempt from the Advancing Care Information performance category. CMS will automatically reweight this category to zero and reweight the Quality performance category from 50 percent to 75 percent.
Table 35 in the final rule provides a scoring example of a non-patient facing MIPS eligible clinician.
Mark Your Calendar
For performance periods occurring in 2018 and future years, CMS will utilize evaluation and management codes and surgical and procedural codes to identify patient-facing encounters and eligibility determinations regarding non-patient facing status. The codes change every year, as might a clinician’s status.
Click here for the list of patient-facing encounter codes used to determine the non-patient facing status of MIPS eligible clinicians.
For purposes of the 2020 MIPS payment year, CMS will initially identify individual MIPS eligible clinicians and groups who are considered non-patient facing MIPS eligible clinicians based on 12 months of data starting from Sept. 1, 2016, to Aug. 31, 2017. To account for the identification of additional individual MIPS eligible clinicians and groups that may qualify as non-patient facing during performance periods occurring in 2018, CMS will conduct another eligibility determination analysis based on 12 months of data starting from Sept. 1, 2017, to Aug. 31, 2018.
The initial 12-month segment of the non-patient facing determination period would span from the last 4 months of a calendar year two years prior to the performance period followed by the first eight months of the next calendar year and include a 30-day claims run out; and the second 12-month segment of the non-patient facing determination period would span from the last four months of a calendar year one year prior to the performance period followed by the first eight months of the performance period in the next calendar year and include a 30-day claims run out.
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