11 Easy Steps to Avoid a MIPS Penalty in 2019 … Without an EHR or a Registry

What I’m about to lay out here should work, and you should avoid the four percent Merit-based Incentive Payment System (MIPS) penalty in 2019—even without an electronic health record (EHR) or a Registry!


You won’t know for sure until sometime in 2018 or perhaps not until you get your first explanation of benefits (EOB) in 2019.
I can’t take any responsibility that this will actually work, but theoretically, this should exempt me (and you) from MIPS penalty in 2019.
This should work in 2017 (for 2019), but not in future years—unless the rules get relaxed again by the Centers for Medicare & Medicaid Service (CMS).

So, without further ado...

Go to: qpp.cms.gov/mips/quality-measures

Filter by “Data Submission” and check off “Claims.”

You should then have a list of the 74 quality measures that you can submit through claims (i.e., no EHR or Registry needed).


You can choose any one you like, but I find the easiest one to be: “Documentation of Current Medications in the Medical Record.”

If you click on the link, it identifies this measure as “Quality ID: 130.”


On another part of the website, you can download a large zip file with all of the measures and how to submit them. (If you use my example, don’t bother doing this.)

Here’s how: qpp.cms.gov/about/resource-library. Scroll down and click on Quality Measure Specifications, and then download 2017_Measure_130_Claims.pdf from the list.

This will show you that to report Measure 130 by claim, you need to use a G code. In this case G8427.


So now you have to satisfy the measure, which reads:

Eligible clinician attests to documenting, updating or reviewing a patient’s current medications using all immediate resources available on the date of encounter. This list must include ALL known prescriptions, over-the counters, herbals, and vitamin/mineral/dietary (nutritional) supplements AND must contain the medications’ name, dosages, frequency and route of administration

Once you have done that, you can report the code on your claim. The CPT code is G8427, and you should link it to any ICD-10 code in your claim. (You can list this with an Evaluation/Management and/or a procedure code).

Some clearinghouses won’t accept $0 charges, so I recommend you place a $0.01 charge to it (and write it off later).

Upon receiving your EOB, you should notice two remark codes relating to the G8427 line—CO-246 and N620. Both of these codes indicate that CMS acknowledges your quality submission.

Good Luck

As stated earlier, for 2017 (for the 2019 Penalty year) you only need to do this one time for one patient, and you should be exempt from the four percent penalty, but I would recommend doing it around a dozen times, just to be sure.

Good luck!

Mark D. Kaufmann, MD is an associate Clinical Professor of dermatology in the Department of Dermatology at the Icahn School of Medicine at Mount Sinai in New York City.

Robots can diagnose skin malignancies. Big data may give insurers ammunition to reduce payments. And dermatologists are left dealing with the fall-out from the rapid evolution of technology. In this special edition of Derm Insider with host Neal Bhatia, MD, Mark Kaufmann, MD dives into the challenges facing the specialty and offers a candid take on what can be done.