New MIPS Measure for Anesthesia

June 3, 2020

By Pamela Linton, CPC, CANPC, Corporate Coding Manager – Anesthesia and Pain Management

Measure 477 – Multimodal Pain Management

This measure may look familiar if you reported MIPS last year through the ASA as it was AQI59. CMS has adopted this measure as a regular MIPS measure for 2020. However, it did come with some notable changes.

AQI59MIPS Measure 477
All patients regardless of agePatients age 18 years of age and older
QDC (Quality Data Code) for Elective Procedure – G9643 has been deletedQDC (Quality Data Code) M1142 – Has Been Added as a Denominator Exclusion for Emergency Cases

The following ASA codes are included in the denominator:

00102, 00120, 00160, 00162, 00170, 00172, 00174, 00190, 00222, 00300, 00320, 00402, 00404, 00406, 00450, 00470, 00472, 00500, 00528, 00529, 00539, 00540, 00541, 00542, 00546, 00548, 00600, 00620, 00625, 00626, 00630, 00670, 00700, 00730, 00750, 00752, 00754, 00756, 00770, 00790, 00792, 00794, 00797, 00800, 00820, 00830, 00832, 00840, 00844, 00846, 00848, 00860, 00862, 00864, 00865, 00866, 00870, 00872, 00873, 00880, 00902, 00906, 00910, 00912, 00914, 00916, 00918, 00920, 00940, 00942, 00948, 01120, 01160, 01170, 01173, 01210, 01214, 01215, 01220, 01230, 01360, 01392, 01400, 01402, 01480, 01484, 01486, 01630, 01934, 01636, 01638, 01740, 01742, 01744, 01760, 01830, 01832, 01961

Denominator Exceptions: Documentation of medical reasons for not using multimodal pain management (e.g., allergy to multiple classes of analgesics, intubated patient, hepatic failure, patient reports no pain during PACU stay, other medical reason(s) – G2149.

Documentation of these exceptions will be critical in helping you achieve the highest MIPS score possible for 2020.

Multi-modal pain management consists of two or more of the following modalities. Opioids can still be given; however, they cannot be counted as one of the modalities.

While opioids may continue to be important pain medications, they must be combined with other classes of medication known to prevent and help relieve postoperative pain unless contraindicated. This list includes but is not limited to:

  • Non-steroidal anti-inflammatory drugs (NSAIDs): Examples include ibuprofen, diclofenac, ketorolac, celecoxib, nabumetone. NSAIDs act on the prostaglandin system and work to decrease inflammation.
  • NMDA antagonists: When administered in low dose, ketamine, magnesium and other NMDA antagonists act on the N-methyl-D-aspartate receptors in the central nervous system to decrease acute pain and hyperalgesia.
  • Acetaminophen: Acetaminophen acts on the central prostaglandin synthesis and provides pain relief through multiple mechanisms.
  • Gabapentinoids: Examples include gabapentin and pregabalin. These medications are membrane stabilizers that essentially decrease nerve firing.
  • Regional Block: The ASA and ASRA also strongly recommend the use of target-specific local anesthetic applications in the form of regional analgesic techniques as part of the multimodal analgesic protocol whenever indicated.
  • Steroids: Dexamethasone during surgery has been shown to decrease pain and opioid requirements.
  • Local Anesthetics: Injection of local anesthesia in or around the surgical site by the surgeon is an example. Systemic lidocaine administered intravenously represents an alternative to regional analgesic techniques.


Example 1: A 49-year old patient with documentation of a local anesthetic given by the surgeon and a post-operative pain block done by the anesthesiologist two hours prior to surgery.

Quality Measure Coding: G2148. Documentation of multimodal pain management with the required time frame.

Example 2: A 66-year old patient with no reported pain in the PACU

Quality Measure Coding: G2149. This is listed as one of the denominator exceptions within

the measure specifications.

Example 3: A 55-year old patient without a documented denominator exception and no indication that multimodal pain management was used.

Quality Measure Coding: G2150. This example would be reported as performance not met.

Example 4: A 45-year old patient with an emergency appendectomy

Quality Measure Coding: M1142. This example is reported as a denominator exclusion.


If Zotec is coding your MIPS directly from the medical record be sure to include documentation for modalities that might be performed by another provider, such as an incision that is infiltrated with a local anesthetic by the surgeon at the beginning of the procedure. If you are using a checklist to provide us with this information the documentation to support what is on the checklist must be documented somewhere within the medical record. Recently, an anesthesia client underwent a CMS MIPS audit which confirms that CMS is looking to ensure the documentation in the medical record matches the MIPS reporting. Also, the MIPS checklist should be filled out completely for all the measures your group has elected to report. This is especially important since the reporting threshold has risen to 70% for 2020, which is up from 60% for 2019.

Learn more about Zotec Partners here.