The list of patient-facing encounter codes is used to determine the non-patient facing status of MIPS eligible clinicians. A non-patient facing MIPS eligible clinician is:
An individual MIPS eligible clinician that bills 100 or fewer patient-facing encounters (including Medicare telehealth services defined in section 1834(m) of the Act) during the non-patient facing determination period, and
A group provided that more than 75 percent of the clinicians billing under the group’s TIN meet the definition of a non-patient facing individual MIPS eligible clinician during the non-patient facing determination period.
The list of patient-facing encounter codes are categorized into three overarching groups of codes (Evaluation and Management Codes; Surgical and Procedural Codes, and Visit Codes). The utilization of Evaluation and Management Codes, Surgical and Procedural Codes, and Visit Codes accurately classifies MIPS eligible clinicians as non-patient facing and patient-facing.
Given the flexibility in program requirements for non-patient facing clinicians, the encounter codes are critical for CMS to identify MIPS eligible clinicians.