Medicare Compliance & Reimbursement

Caveat: Some measures may not be possible under the expansion.

If you’re revisiting your quality measure options for 2020, the feds released new guidance with a telehealth spin. Read on for the specifics.

Definition: The Centers for Medicare & Medicaid Services (CMS) uses providers’ data garnered from EHRs to “measure and track” quality in healthcare and look for ways to improve the delivery of care. The feds refer to this information as electronic clinical quality measures (eCQMs), and over the years they’ve used it to look at the practices of eligible professionals (EPs), eligible hospitals, and critical access hospitals (CAHs), according to CMS guidance.

Additionally, the Quality Payment Program (QPP) utilizes eCQMs in its various programs, including the Merit-Based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (Advanced APMs). The APM programs Comprehensive Primary Care Plus (CPC+) and Primary Care First (PCF) as well as the Medicaid Promoting Interoperability Program also look at providers’ eCQMs.

Now: At the beginning of July, CMS released performance year (PY) 2020 eCQM updates that take telehealth encounter changes into account, suggests a notice. The new guidance reminds eligible parties to review the list of the 42 telehealth-related eCQMs and coding policies.

“Telehealth-eligible CPT^® and HCPCS codes may be included in value sets where the required quality action in the numerator cannot be completed via telehealth,” CMS says. “Therefore, it is the eligible professionals’ and eligible clinicians’ responsibility to make sure they can meet all other aspects of the quality action within the measure specification, including other quality actions that cannot be completed by telehealth.”

Check out the PY 2020 update at https://ecqi.healthit.gov/sites/default/files/2020-eCQM-Telehealth-Guidance-Document.pdf.

2021: CMS also laid out the logistics and facts on 39 telehealth-related eCQMs for PY 2021. However, these “measures are not eligible for 2021 reporting unless and until they are proposed and finalized through notice-and-comment rulemaking for each applicable program,” the agency stresses.

See the PY 2021 outline at https://ecqi.healthit.gov/sites/default/files/2021-eCQM-Telehealth-Guidance-Document_0.pdf.