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December 20, 2018

Frequently Asked Questions From The November 19th Physician Fee Schedule Final Rule: Understanding 3 Key Topics Call.

The Centers for Medicare & Medicaid Services (CMS) recently distributed the following answers in response to frequently asked questions during the November 19, 2018, Physician Fee Schedule Final Rule: Understanding 3 Key Topics Call.  Please share with your appropriate staff.

E/M
What parts of the history can be documented by ancillary staff or the beneficiary starting in CY 2019? View the responseExternal PDF

QPP
How does the MIPS payment adjustment apply to clinicians, especially those who may switch practices during the performance year?

A. Below are the general rules on how the payment adjustment is applied, which is different than the legacy programs.

  1. A MIPS eligible clinician (NPI) who bills to the same TIN in the payment year as they did during the performance period will be assessed the payment adjustment under that TIN/NPI combination according to the final score earned from data submitted/collected under that TIN
  2. A MIPS eligible clinician (NPI) who bills to a (new) TIN in the payment year that they did NOT bill to during the performance period will be assessed the payment adjustment under that (new) TIN/NPI combination based on the most advantageous final score attributed to that NPI under any TIN/NPI combination for the performance period

Additionally, we have a fact sheetExternal PDF that provides additional information and scenarios on the MIPS payment adjustments.

Are there any changes to the data completeness requirements for the MIPS Quality performance category in 2019?

A. No, the data completeness requirements are the same as in Year 2 (2018) even with the update to the submission terminology. Individual clinicians or groups submitting quality measure data on QCDR measures, MIPS CQMs, and eCQMs must submit data on at least 60% of the clinician or group’s patients that meet the measure’s denominator criteria, regardless of payer. Individual clinicians or groups submitting quality measure data on the Medicare Part B claims measures must submit data on at least 60% of the applicable Medicare Part B patients seen during the performance period.

Call Materials
An audio recordingZip File, transcriptExternal PDF, and slide presentationExternal PDF are available for this callExternal Website.

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