Navigating the Quality Payment Program – Answers to PMI Questions

Preparing to participate in the 2017 QPP reporting year continues to present challenges as Revenue Cycle Management companies move forward with the program information that has been made available. PMI recently contacted the QPP Service Center to ask when the list of non-patient facing CPT codes will be available. These codes are needed for physicians and physician billers to adequately prepare for the 2017 reporting requirements for ACI (Advancing Care Information) and IA (Improvement Activities). The following response was received from Mark, CMS QPP Support Team – MIPS:

“We will be releasing the list of non-patient facing CPT codes in the next several months. Please sign-up to for the listserv to receive notifications when these updates occur to the website. Visit, scroll to the bottom of the page and select “Subscribe to Email Updates”. I hope you find this information helpful; please visit our website,, for additional information.”

PMI will continue to monitor these sites and await notification of their release as the as the roll out of QPP continues.

An additional inquiry was made about where to locate the MAV (Measure Applicability Validation) process for 2017 quality reporting. Mark, CMS QPP Support Team – MIPS, provided the details below:

“The MIPS validation process will vary by submission mechanism. For claims and registry submissions, we plan to use the algorithms from the current MAV (Measure Applicability Validation) process under PQRS to identify which measures an MIPS eligible clinician is able to report. For QCDRs, we don’t intend to establish a validation process. We expect that if you enroll in QCDRs, you’ll have sufficient meaningful measures to report. For the EHR submissions, we know you may not have 6 measures relevant within your EHR. If there aren’t enough EHR measures to meet the full specialty set requirements or the requirement to submit 6 measures, you should select a different submission mechanism to meet the Quality Performance category requirements. For the CMS Web Interface, you’re attributed beneficiaries on a defined population that is appropriate for the measures, so there’s no need for additional validation. Given the number of choices for submitting quality data, we anticipate that you’ll be able to find a submission mechanism that meets the MIPS submission requirements. We strongly encourage you to select the submission mechanism that has 6 measures that are available and appropriate to your specialty and practice type.”

PMI supplies support to its billing and registry clients for QPP.