POS 19 Now Included in MIPS Definition of hospital-based MIPS eligible clinician

While this is not directly related to the Dose Registry, it is important information for radiology groups.  In the original MIPS rule, Place of Service 19 was not included in the definition of “hospital-based clinicians”  thereby complicating these clinicians ability to meet their Merit-based Incentive Payment requirements.  CMS is proposing to correct that oversight effective next year.  I copied some text directly from the proposed rule below as well as the link to the entire QPP proposed rule.


(b) Hospital-Based MIPS Eligible Clinicians

We are proposing to modify our policy to include covered professional services furnished by MIPS eligible clinicians in an off-campus-outpatient hospital (POS 19) in the definition of hospital-based MIPS eligible clinician. POS 19 was developed in 2015 in order to capture the numerous physicians that are paid for a portion of their services in an “off campus-outpatient hospital” versus an on campus-outpatient hospital, (POS 22). We also believe that these MIPS eligible clinicians would not typically have control of the development and maintenance of their EHR systems, just like those who bill using POS 22. We propose to add POS 19 to our existing definition of a hospital-based MIPS eligible clinician beginning with the performance period in 2018.

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QPP Proposed Rule

As always, if you or your facility finds the Dose Registry challenging or need some support maintaining it we are here to help.  We also offer a low-cost option for meeting The Joint Commission’s Dose Incident Identification requirements, often saving facility tens, and often hundreds of thousands of dollars.

Michael Bohl



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