Quality Measures & Telehealth

Just before the 4th of July holiday weekend, CMS released new guidance for which eCQMs can be used during a telehealth visit for Reporting Year 2020. This unexpected update was the result of questions regarding if home-captured data was “good enough” for Quality Measures. Fortunately, out of the 47 eCQMs that exist, a total of 42 are telehealth allowable. As with everything, there is a caveat: some measures may require an in-person element that cannot be achieved fully with just telehealth. So while an eCQM is eligible, there may be an extra step required to complete the measure.

Measure Highlights

While the complete list available here, we do want to highlight the ones that we find most commonly used by practices:

Allowed:

  1. 50v8 – Receipt of Specialist Report
  2. 68v9 – Documentation of Current Medications
  3. 122v8 – Diabetes Hemoglobin A1c Poor Control
  4. 128v8 – Anti-depressant Medication Management
  5. 135v8 – Heart Failure Medication Therapy (ACE inhibitor or ARB or ARNI therapy)
  6. 138v8 – Tobacco Screening & Cessation
  7. 139v8 – Falls Screening
  8. 156v8 – Use of High-Risk Medication in the Elderly (inverse measure)
  9. 159v8 – Depression Remission at 12 months
  10. 161v8 – MDD Suicide Risk Assessment
  11. 165v8 – Controlling High Blood Pressure
  12. 347v3 – Statin Therapy for Treatment of CVD

NOT Allowed:

  1. 22v8 – Screening for High Blood Pressure & Follow-up
  2. 69v8 – BMI Screening & Follow-up
  3. 157v8 – Medication & Radiation Paint Intensity Quantified
  4. 129v9 – Prostate Cancer Overuse of Bone Scan
  5. 133v8 – Cataracts 20/40 or Better Within 90-days Following Surgery

What About MIPS CQMs?

eCQMs that have a MIPS CQM equivalent (formerly called Registry Measures) are also telehealth eligible/ineligible! Remember, the difference between the measure sets is: targeted population and (usually minor) differences in their formulas. Generally, however, the MIPS CQMs are identical in nature to their matched eCQMs.

If you have a MIPS CQM (there are 196 of them) you can safely assume it is NOT telehealth eligible if it is not on the list. If you are relying on telehealth visits and have MIPS CQMs not on the list, you will need to adjust your measures.

What About Specialty Registry Measures?

The guidance released only applies to measures that CMS oversees: MIPS CQMs & eCQMs. The onus is on the Qualified Registry to determine if a telehealth visit and their data standards are an equitable match. If you have a specialty registry, that you are using to report MIPS Quality, be sure to consult with them about this.

Going Forward

CMS has said that this list of CQMs for 2020 is final. However, they did also release a list for 2021 which has FEWER (39) measures allowed. Fortunately, those three extra measures are not common. It is important to note that this list is not final and may change between now and Jan 1, 2021.

As the 2021 list is updated we will provide you our analysis if anything significant changes. At this point, however, we do not believe that it will change radically.

Conclusion

The rush to telehealth brought about questions that almost no one was asking: “What Quality Measures can be done outside the clinic?” CMS has responded with a well-crafted list of measures.

As always, CMS reserves the right to change the MIPS program to adapt to the health community’s needs. Though it appears that they are finished changing the program for 2020. Historically, in late July, CMS releases a Proposed Rule that becomes final in late-Oct/early-Nov. Therefore, SHP anticipates additional changes to the MIPS program for 2021, but no further major changes to the program for 2020.

Practices, particularly those who are relying on Telehealth, should re-evaluate their Quality Measures against this list. If you find that you were using a measure that is not eligible, you may want to consider requesting an Extreme & Controllable Circumstances Exception for the Quality Category.

If you are not sure if you should file an ECCE, or if you want assistance with picking your eCQMs, contact your SHP Representative and they will get you in touch with our MIPS expert.