eCQMs and Telehealth
CMS guidance clarifies MIPS measure specifications.
Which electronic clinical quality measures (eCQMs) include telehealth-eligible encounter codes, and which do not? Guidance from the Centers for Medicare & Medicaid Services (CMS) identifies the eCQMs that eligible clinicians may report for the Merit-Based Incentive Payment System (MIPS) 2021 performance period to receive credit, even if the encounters are not in person.
Many professional services are being conducted via telehealth due to the public health emergency for COVID-19, but MIPS eligible clinicians count these encounters toward their quality reporting?
For the 2021 MIPS performance period, most of the available eCQMs include CPT® and HCPCS Level II encounter codes that Medicare will cover when furnished either in-person or via telehealth. In fact, current eCQM logic and value sets don’t differentiate between the two settings for telehealth-eligible codes payable under the Medicare Physician Fee Schedule. There are 39 telehealth-eligible eCQMs for the 2021 MIPS performance period.
eCQMs That Cannot Be Completed Via Telehealth
There are eight more eCQMs with specifications that cannot be fulfilled via telehealth. Some value sets in these eCQMs may include telehealth-eligible codes in the denominator, but the required quality action in the numerator cannot be completed via telehealth. Clinicians should be sure they can meet all aspects of the quality action within the measure specification.
The eCQMs not eligible for telehealth encounters during the 2021 performance period are:
|CMS eCQM ID||MIPS Quality ID||Measure Title||Reason Not Eligible for Telehealth|
|CMS22v9||317||Preventive Care and Screening: Screening for High Blood Pressure and Follow-Up Documented||Screening measure requires therapy, treatment, or assessment that cannot be conducted via telehealth|
|CMS69v9||128||Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan||Screening measure requires therapy, treatment, or assessment that cannot be conducted via telehealth|
|CMS142v9||019||Diabetic Retinopathy: Communication with the Physician Managing Ongoing Diabetes Care||Clinical action is not appropriate for remote visit|
|CMS143v9||012||Primary Open-Angle Glaucoma (POAG): Optic Nerve Evaluation||Clinical action is not appropriate for remote visit|
|CMS771v2||476||Urinary Symptom Score Change 6-12 Months After Diagnosis of Benign Prostatic Hyperplasia||Clinical action is not appropriate for remote visit|
|CMS75v9||378||Children Who Have Dental Decay or Cavities||Measure does not contain telehealth-eligible codes|
|CMS129v10||102||Prostate Cancer: Avoidance of Overuse of Bone Scan for Staging Low Risk Prostate Cancer Patients||Measure does not contain telehealth-eligible codes and does not require an encounter during the measurement period|
|CMS133v9||191||Cataracts: 20/40 or Better Visual Acuity within 90 Days Following Cataract Surgery||Measure does not contain telehealth-eligible codes and does not require an encounter during the measurement period|
Telehealth Eligibility Applies to All Collection Types
There are six collection types for MIPS quality measures; eCQMs is just one option. Others include:
- MIPS CQMs
- Qualified Clinical Data Registry
- Medicare Part B Claims
- CMS Web Interface
- Consumer Assessment of Healthcare Providers and Systems (CAHPS) for MIPS Survey
Each collection type has unique requirements. What applies to one does not necessarily apply to the other. Telehealth eligibility, however, is the same across the board. Encounter codes that may be conducted via telehealth are identified in the measure’s specifications. These specifications instruct you to append the appropriate modifier GQ, GT, or 95 or place of service 02 to the telehealth-eligible encounter code when performed via telehealth.
In the Quality Payment Program Resource Library, look also for “2020 CMS Web Interface Telehealth Guidance” and “2020 Quality Measures List with Telehealth Guidance.”