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The Centers for Medicare and Medicaid Services (CMS) always keeps us on our toes. Performance year 2019 is no exception. We break down the key changes to the Quality Payment Program (QPP) that will impact the specialty of anesthesiology.

Discontinued Measures

Merit-based Incentive Payment System (MIPS) measures 426 (PACU Transfer of Care Checklist) and 427 (ICU Transfer of Care Checklist) have been discontinued. abeo anticipates this will cause many anesthesia practices to have less than 6 eligible quality measures for reporting. Practices must ensure they are reporting on all eligible measures including measure 404 and measure 463, which some practices may have previously avoided reporting.  Practices that bill for more than twenty face-to-face encounters (i.e., more than twenty consult codes) would be required to report a measure like 47, 130, or 226 to reach the required 6 measures.

CMS will analyze claims data at the end of the reporting period to ensure that the practice or eligible clinician reported on all applicable measures. If less than 6 measures are applicable to the practice or eligible clinician, the quality denominator score will be appropriately reduced to ensure the practice or eligible clinician is not adversely impacted.

Claims Reporting

Beginning in 2019, only small practices (i.e., practices of fifteen or fewer eligible clinicians), are eligible for claims-based reporting. MIPS measure 76 is the only remaining claims measure applicable to anesthesia practices.

A Minimum of 30 Total Points is Required

The minimum total points threshold required to avoid a penalty has been increased to thirty. This increase introduces a greater of risk for many practices because they must complete both requirements listed below to avoid a penalty.

  1. Report and achieve the 60% completeness threshold on at least 5 quality measures (if less than 5 quality measures apply, they must achieve that threshold on all eligible measures);


  1. Successfully complete the requirements for the Improvement Activities category. For practices classified as non-patient facing, that would be 1 high or 2 medium weighted activities. For all other practices /eligible clinicians, it is 2 high or 4 medium weighted activities.

With the removal of measures 426 and 427 and the increased performance threshold of 30 points, it becomes very important that all eligible clinicians and practices working in the specialty of anesthesiology understand the MIPS reporting requirements of the QPP and identify all applicable measures for their practice.


Additional Resources:

You can find more information and contact CMS on their Quality Payment Program website, by e-mail at, or by phone at 866.288.8202.


abeo Management Corporation (abeo) serves as a leading source of revenue cycle management and practice management with a specialization in anesthesia. The company leverages its people, processes, and software to serve independent practices, surgery centers, hospitals and healthcare systems with a scope of services that include billing, coding, transcription, practice management, and business consulting.

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