A large part of the Quality Payment Program (QPP) unease is the distinction between a patient-facing eligible clinician (EC) and a non-patient facing EC. That distinction is important in that it will determine which MIPS categories an EC needs to participate in and how the weight of those categories will affect their overall composite score. In the final rule, CMS indicated they would publish the codes for procedures they consider to be patient-facing “in advance of the performance period”. They delivered on that promise 2 business days before the start of the 2017 performance year.
While it was expected that inpatient and outpatient consults would be considered patient-facing, it was unclear if any surgical procedures pertaining to Interventional Radiology would be included. CMS ended up designating the codes most areas of IR, including common vascular and non-vascular procedures. While the type of procedure is important, so is the volume. CMS finalized the procedure threshold at 100. This means that if an EC bills 100 or fewer patient-facing codes, they would be considered non-patient facing.
Adding to the complexity of the QPP is the use of the CMS-coined term “non-patient facing determination period”. This term refers to the timeframe used to assess claims data for making determinations of non-patient facing or patient-facing status as well as hospital-based. CMS defines the non-patient facing determination period to mean a 24-month assessment period which consists of a two-segment approach. The initial 12-month period prior to the performance period will include review of Medicare claims data from September 1, 2015 to August 31, 2016. CMS will then conduct a second query using Medicare claims data from September 1, 2016 to August 31, 2017 to determine if any additional clinicians are non-patient facing while the performance year is in progress.
So, what does the designation of non-patient facing translate to in practice? If a MIPS EC is deemed non-patient facing based on the fact that greater than 75% of their covered professional services take place in a hospital setting (Place of service code 21, 22, or 23) or they bill 100 or fewer patient-facing codes, they are exempt from the Advancing Care Information (ACI) category. The 25% weight of ACI on the overall composite score will be reweighted to the Quality category (85%). The non-patient facing EC will also be required to report on fewer Clinical Practice Improvement Activities (CPIA); 1 high-weighted or 2 medium-weighted. This is expected to be viewed positively by radiologists as the vast majority will be deemed non-patient facing therefore will not be held to, and potentially penalized for, measures outside of their control.
The result of the non-patient facing determination and reweighting of MIPS categories puts that much more of an emphasis on the Quality category. ADVOCATE is equipped to monitor provider performance real-time and provide appropriate and beneficial feedback to allow the best possible chance at a positive payment adjustment come 2019.
The complete list of patient-facing CPT codes can be found by clicking here.
As always, ADVOCATE will keep you up to date on this and all issues impacting radiology as they become available.
Lauren Sloan, RD, LD, MHA
Process Improvement Specialist