The American College of Radiology (ACR) submitted comments to the Centers for Medicare and Medicaid Services (CMS) on patient relationship categories and codes for the Medicare Access and CHIP Reauthorization Act (MACRA).
The comment letter was prepared in response to CMS’ Request for Information seeking public comment on patient relationship categories and codes to be developed under the new Merit-based Incentive Payment System (MIPS).
As previously reported in Advocacy in Action, patient relationship codes will be used to accurately attribute patients to the appropriate physicians for purposes of identifying the physician who is responsible for particular services as mandated by Section 101(f) of MACRA.
To evaluate resources used to treat patients, the secretary of the Department of Health and Human Services will be required to conduct an analysis of resource use based on care episode, patient condition and patient relationship codes that will be submitted on claims.
In the comment letter, the ACR expressed concern about the additional reporting and administrative burden these new codes could cause radiologists. The College encouraged CMS to implement the new codes in a manner that minimizes this burden. Recognizing that MACRA requires the reporting of these codes with all claims starting in 2018, the ACR urged CMS to provide guidance for billing entities and physicians well in advance of implementation. CMS was also encouraged to provide additional information regarding the use of the patient relationship codes to the attribution of costs to physicians.