I apologize if this seems redundant, but this inquiry for clarification comes after having already reviewed many tickets including:

https://jira.oncprojectracking.org/browse/CQM-1173
https://jira.oncprojectracking.org/browse/CQM-1413
https://jira.oncprojectracking.org/browse/CQM-1225

I am still unclear as to how Provider Attribution should be performed since CQM-1173 could be taken as contradictory to other tickets that exist. Many tickets discuss connecting the numerator to the denominator, but this ticket is more about connecting denominator Encounter Performed type items to other related events in the natural course of patient care.

The CQM-1173 clarification states:

For Meaningful Use (MU) and the Physician Quality Reporting System (PQRS), if the Eligible Professional (EP) registers as an individual, there is no sharing of data. Sharing of data occurs with GPRO for PQRS.

However, much of the documentation and tickets seems to indicate the following as the rule of thumb:

While the measures in the MU program are targeted towards individual providers, the goal is that the provider demonstrates the correct action was taken for the correct patient, and not that that specific provider necessarily took every action for that patient. In general, if you can demonstrate that the action in question was performed, you receive credit for participating in clinically-appropriate care.

To help support my question, please see the following example:

Hospitalist Provider

• Patient 1234 is a hospital patient from 12/11/2015 to 12/13/2015.
• Provider Jones provides services on 12/11/2015 – CPT 99220 Initial observation care, per day…
• Provider Adams provides services on 12/12/2015 – CPT 99224 Subsequent observation care, per day…

For the purpose of the eCQM measures in a general sense (excluding specific provisions in a particular measure):

1. Can both providers be attributed to the denominator of a measure where CPT 99220 is a denominator requirement, while 99224 is not in the measure?
2. Meaning, do both providers, including Adams, get credit for a measure requiring CPT 99220 since they are both treating the same patient on the same encounter event (same stay), but maybe on different days of the encounter?

CMS137v3 is an example where CPT 99920 is used as an Encounter Performed in the Denominator, while CPT 99924 is not. However, as you can see the entire treatment process was managed by both providers. In addition, many other providers (say a Nephrologist or Anesthesiologist) could have treated the patient during this same encounter stay, but may have performed or billed a service that does not exist in a value set for any measures whatsoever.

1. Since these providers are providing care related to CPT 99920 – can they be attributed to this measure by way of the patient specific encounter using Encounter Performed CPT 99920?
2. Again, please answer in general as to how provider attribution should be viewed as a whole for all measures, notwithstanding any caveats for measure specific tickets and guidance.