Wiki NQF0059 - HBA1C MIPS quality reporting for FQHC

zremmich

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Our office visit codes are billed out to Part A because of the FQHC status. The only code that is going to go on the Part B claim is the actual lab procedure. Can the CPT II code go on that claim or does there have to be an office visit code on it as well? Can I bill just the lab code with the CPTII code – there will not be a 99211-99215 attached to this claim since that went on the FQHC Claim. I’m asking this because to report quality measure NQF0059 - HBA1C, the denominator contains the patient encounter (level of service) and this does not go on our Part B claim. Any insight or help is greatly appreciated.

Thanks,

Zach
 
I've sent your question to CMS for a response. Meanwhile, I found this from a CMS FAQ:

"At this time, FQHCs (as a facility) aren’t able to participate in MIPS. However, if you practice in an FQHC, the MIPS payment adjustment applies to payments made for items and services that are Part B charges billed by MIPS eligible clinicians outside/not assigned to the FQHC. This means if you’re a MIPS eligible clinician with Part B charges outside/not assigned to the FQHC, you’re expected to participate in MIPS."
 
Here is the response from CMS:

You may be exempt from MIPS if you are a part of a Rural Health Clinic (RHC) or Federally Qualified Health Center (FQHC). If you bill for Medicare Part B services exclusively through the RHC or FQHC payment methods, then you are not eligible for payment adjustments under MIPS. This is because MIPS does not apply to these facility payments. However, if you are a part of a RHC or FQHC and bill for Medicare Part B services under the Physician Fee Schedule (PFS), then payment for such other services would be subject to the MIPS payment adjustments unless your billings are below the low volume exclusion threshold determination or you meet another exclusion.

If the independent laboratory bills globally, it is not operationally feasible for us at this time to associate those billed allowable charges with a MIPS eligible clinician at an NPI level in order to include them for purposes of applying any MIPS payment adjustment.

If you still have the need for assistance please feel free to contact us at your convenience by calling 1-866-288-8292 or via email at qpp@cms.hhs.gov, you may also obtain information by going to the website at qpp.cms.gov or qualitypaymentprogram.cms.gov.
 
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