Independent Diagnostic Testing Facilities and QPP Compliance – Answers to PMI Questions

PMI recently contacted the QPP Service Center regarding the following question: Are physicians that work in IDTF’s required to participate in MIPS? Under PQRS they were exempt from participation.

The QPP Service Center responded:

Page 171-172 of the QPP Final Rule ( –

“Comment: A few commenter’s requested that CMS determine and state eligibility status

for clinicians providing services at independent diagnostic testing facilities (IDTFs) and to

provide clear, detailed guidance under what circumstances eligibility would occur under MIPS.

The commenter noted that CMS has issued similar guidance under the PQRS system of “eligible

but not able to participate”; however, the commenter indicated that the guidance provided in

PQRS does not address all variations of billing and coding practices of IDTFs.

We note that the MIPS payment adjustment applies only to the amount

otherwise paid under Part B with respect to items and services furnished by a MIPS eligible

clinician during a year. As discussed in section II.E.7. of this final rule with comment period, we

will apply the MIPS adjustment at the TIN/NPI level. In regard to suppliers of independent

diagnostic testing facility services, we note that such suppliers are not themselves included in the

definition of a MIPS eligible clinician. However, there may be circumstances in which a MIPS

eligible clinician would furnish the professional component of a Part B covered service that is

billed by such a supplier. Those services could be subject to MIPS adjustment based on the

MIPS eligible clinician’s performance during the applicable performance period. Because,

however, those services are billed by suppliers that are not MIPS eligible clinicians, it is not

operationally feasible for us at this time to associate those billed allowed charges with a MIPS

eligible clinician at an NPI level in order to include them for purposes of applying any MIPS

payment adjustment.”