A greater number of imaging specialists may be able to take advantage of the “non-patient facing” exemption outlined in the final ruling on the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), released today by CMS.
Aiming to provide “practice driven, quality improvement,” the ruling allows physicians to pick from three Merit-based Incentive Payment System (MIPS) reporting periods to smooth the transition. To achieve the highest possible MIPS scores, physicians are encouraged to submit data in all three categories: quality, improvement activities and advancing care information.
In early iterations of MACRA, the non-patient facing exemption was allocated by specialty. However, it resulted in inconsistencies like a cardio imaging specialist being billed under cardiology, possibly resulting in reduced payments for the physician. When the definition was changed to a threshold rule, it initially applied only to physicians who had 25 or fewer patient facing encounters.
Instead, the exemption will apply to doctors who have 100 or fewer patient-facing encounters during a 12-month determination period. The 2019 MIPS payment adjustment for non-patient facing clinicians will be based on data from September 2015 to August 2016.
The threshold of 100 is a good sign for radiologists, according to Danny Hughes, PhD, of the Harvey L. Neiman Health Policy Institute.
“It is important for radiologists to have a reasonable threshold to be classified as non-patient facing to ensure that radiologists are provided a fair opportunity for success under MIPS,” said Hughes. “A threshold of 100 or fewer is what our analysis recommends.”
Perhaps the most surprising aspect of the ruling is the clause dictating that if 75 percent of the group’s physicians meet the non-patient facing criteria then the entire group does as well, providing a security blanket of sorts to interventional radiologists.
“The vast majority of radiologists that do not meet the non-patient facing criteria were interventional radiologists,” said Hughes. “This will allow radiologists that primarily perform interventional procedures to continue to add value to their groups without adversely affecting the group’s opportunities to succeed in performance review under MIPS.”
Read the full ruling or the executive summary at the Center for Medicare Services. Visit HealthExec.com for more coverage of the MACRA ruling.