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Who is considered a non-patient facing clinician?

For payment years 2019 and 2020, a non-patient facing clinician

  • Bills for 100 patient-facing encounters or less, including Medicare telehealth services, during the non-patient facing determination period.
  • Has a group where more than 75 percent of the NPIs billing under the group’s TIN bill for 100 patient-facing encounters or less, including Medicare telehealth services, during the non-patient facing determination period.

Beginning with the 2021 MIPS payment year, non-patient facing determinations will be based on the MIPS determination period.

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