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What are Patient-facing Encounters?

CMS defines a patient-facing encounter as an instance in which a MIPS eligible clinician billed for services such as general office visits, outpatient visits, and procedure codes under the Medicare Physician Fee Schedule.


What is the Patient-facing Encounters Codes List?
This 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, 
  • 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.

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