Home > EHR, meaningful use, Medicare > CMS Proposes to Not Require MU (Advancing Care Information) for Non-Patient-Facing MIPS Eligible Clinicians

CMS Proposes to Not Require MU (Advancing Care Information) for Non-Patient-Facing MIPS Eligible Clinicians

The proposed rule released yesterday by the Centers for Medicare and Medicaid Services (CMS) to establish the foundation of the Merit-based Incentive Payment System (MIPS) includes a proposal to reweight the “Advancing Care Information” performance category the MIPS Composite Performance Score (CPS) to zero for non-patient-facing participants. The Advancing Care Information performance category is essentially a rebranding and simplification for the MIPS era of the prior EHR Incentive Program’s “meaningful use” requirements.

Generally speaking, payment adjustments under MIPS would be determined by the relative CPS of MIPS eligible clinicians. The CPS would be comprised of performance in four categories: quality, resource use, clinical practice improvement activities, and advancing care information.

The Advancing Care Information performance category would, by default, count for up to 25 percent of an eligible clinician’s CPS. However, CMS proposes that non-patient-facing MIPS eligible clinicians would have their Advancing Care Information performance category automatically reweighted to zero, thus basing their CPS on other performance categories (some of which also have reweighting). The end result is that the CPS of non-patient-facing MIPS eligible clinicians would not be influenced by the Advancing Care Information performance category—at least not initially (CMS indicated that they would revisit this issue in future rulemakings).

CMS proposes that “non-patient-facing MIPS eligible clinicians” would be defined as individual MIPS eligible clinicians or groups that bill 25 or fewer patient-facing encounters during a performance period. A “patient-facing encounter” would be an instance in which MIPS eligible clinician or group billed for services such as general office visits, outpatient visits, and surgical procedure codes under the Physician Fee Schedule. CMS plans to publish a proposed list of these patient-facing encounter codes online.

The current assumption (without the aforementioned list of encounter codes to verify) is that most of ACR’s diagnostic radiologists and nuclear medicine physicians would meet the proposed “non-patient-facing” definition, and thus would have their Advancing Care Information performance category automatically reweighted to zero.  At this writing, it is unclear (again, without that list of encounter codes) if interventional radiologists would also meet the proposed “non-patient-facing MIPS eligible clinician” definition.

Advertisements
Categories: EHR, meaningful use, Medicare
  1. No comments yet.
  1. No trackbacks yet.

Leave a Reply

Fill in your details below or click an icon to log in:

WordPress.com Logo

You are commenting using your WordPress.com account. Log Out / Change )

Twitter picture

You are commenting using your Twitter account. Log Out / Change )

Facebook photo

You are commenting using your Facebook account. Log Out / Change )

Google+ photo

You are commenting using your Google+ account. Log Out / Change )

Connecting to %s