Thank you for your inquiry regarding CMS 69 v6. We acknowledge your comments on the complexity of the measure and share your desire to seek simplification. Specifications are reviewed annually and feedback received from the community is taken into consideration to simplify the measure, while also ensuring specifications follow clinical guidelines. We reviewed the (3) scenarios you submitted and are in agreement with the numerator outcomes as specified in the power point. We appreciate your submission and again it will be taken under consideration as we strive to reduce the burden of quality measurement, while continuing to improve care.

• There are Exclusions (Pregnancy and Palliative Care) but they can largely be ignored for the sake of this conversation A. We are not seeing a lot the palliative care exclusion – likely due to (a) the center being aware, (b) the center having the discipline to document in a structured manner and (c) Azara having this mapped B. Pregnancy while often miscoded, is not really the root of confusion   • The Denominator – while relatively straight forward, does have a nuance / complexity A. The patient needs to be over 18 at any qualifying visit in the year (e.g., say 2018 for sake of conversation)  So if the patient will turn 18 later in the year and has only a single visit in the year and they are 17 at that visit, they are not included in the measure at all B. This is different than other measures  For example, if a female patient has a visit in the year when they are 23 but are turning 24 in the year, they are included in the Cervical Cancer Screening Denominator– there is no check for their age at the time of the actual visit   • The Numerator is where things get more complicated (at least as we interpret the specificaitons) A. For sake of this argument making the assumption we are talking about patients where the BMI was recorded and is out of range (too high or too low) – this is not the complex portion B. The 12-month look back for a recorded BMI is from any encounter that occurred during the year (again presuming the patient was 18+ at the visit) and not simply the most recent visit in 2018  For example, if a patient has visits in Jan 2018 and in Mar 2018 and BMI was not recorded at either, you would be looking for a BMI recorded 12 months prior to the Jan 2018 visit and 12 months prior to the Mar 2018 visit – essentially a BMI recorded any time in 2017 C. If an out of range BMI is found, you need to look for follow-up. To do so,  You need to understand from which encounter you looked 12 months back to find that BMI (in my example, was it from the Jan 2018 or the Mar 2018 visit)  Once you establish the visit you looked back to find the BMI, you need to look 12 months back from that same visit to find the appropriate follow-up D. Then there are the cases where follow-up was done but not in the right timeframe  From my example, if the BMI was last recorded in Feb of 2017 which is within 12 months of the Jan 2018 visit but not the Mar 2018 visit, follow-up done after Jan 2018 (for example if it was done in the Mar 2018 visit) does not count because it was not within the 12 months preceding the Jan 2018 visit   I have attached a PPT with a scenario illustratging some of the complexities – hoping that helps. I have not made any suggestions for simplifying things – I could do so but here was just trying to illustrate the complex and confusing nature of the specs. Also not trying to saying that these kinds of cases happen a predominant amount of the time. The reality, however, is that they do happen a small percentage of the time and the centers end up focusing on these small number of confusing case as they are trying to get as accurate and good a score as possible submitted.   Truly appreciate you all listening to our feedback and continuing to work with our team here at Azara. We appreciate how the BPHC has changed and aligned with the CMS specs to reduce the confusion and complexity – in fact are thankful and applaud that fact! We are, however, always striving to make things less confusing / complex in general while at the same time trying to stay within the bounds of the general intent of the measures.   Thank you again,   Greg Augustine Chief Operating Officer

​The current logic in the CMS69 measure, Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan, allows for the 12 month look back period to be based on any eligible encounter which creates unnecessary complexity in some scenarios. Proposed Solution: Update numerator and exception logic criteria to be based on the most recent eligible encounter versus any eligible encounter. Rationale: Simplify logic intent.

Final Recommendation: Based on CRP feedback, this change will not be made, and the issue will be re-evaluated for consideration next year. Update numerator and exception logic criteria to be based off of the most recent eligible encounter versus any eligible encounter.