Face the facts about your patient-facing status, MIPS-eligible clinicians. CMS has released the list of the 5,702 codes that qualify as patient-facing services and procedures in 2018.
Absent from the list are anesthesia, pathology and radiology codes. In addition, CMS explains that clinicians have to hit a claims threshold before they're considered patient-facing:
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An individual MIPS eligible clinician who bills 100 or fewer patient-facing encounters (including Medicare telehealth services defined in section 1834(m) of the Social Security Act) during the non-patient facing determination period; and
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A group or virtual group, if more than 75 percent of the clinicians 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.
When CMS determines a clinician or group tax identification number is non-patient facing, it will re-weigh the clinician's or group's advancing care information (ACI) category from 25% to zero. Essentially, non-patient facing providers will be exempt from ACI performance. (That 25% will be added to the providers' quality category weight instead.)
CMS eases up on the non-patient facing provider's improvement activities requirements as well. Non-patient facing providers must perform two medium-weighted or one high-weighted activity. Patient-facing providers must perform at four medium-weighted or two high-weighted activities.
Clinicians don't need to tell CMS that they're non-patient facing -- the agency will review claims data to determine who is and who is not patient-facing.