Thank you for your question. For CMS 69, Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan, there is limited overlap where codes contained in the "BMI Encounter Code Set" value set (OID: 2.16.840.1.113883.3.600.1.1751) also indicate an appropriate intervention would occur. Therefore, we expect the way the measure is written and coded to essentially reduce burden, since both clinical actions, BMI and follow up, could be covered during the same encounter. If we were to add a new constraint to the measure logic so that the same encounter could not count towards the Initial Population and Numerator, we may find that performance would be affected to the extent that providers may fail the measure when they should pass.

While there are time parameters around when the different encounters can occur, there is no time parameter of these sets in relation to one another. Example: A patient is seen on 1/1/2019 using BMI Encounter value set CPT code 97803 for Medical nutrition therapy; re-assessment and intervention, individual, face-to-face with the patient, each 15 minutes and their BMI was recorded as 30.1 This same CPT code is contained in three value sets for the measure: Above Normal Follow-up BMI Encounter Code Set Below Normal Follow up So if the patient has this code dated 1/1/2019 it would be pulled into the IPP because the encounter occurred during the reporting year. They would require a High BMI Follow up to occur and based on the way the logic reads for the NUM, it is looking for "High BMI Follow Up Encounters to have been performed:" "Qualifying Encounters During the Measurement Period" QualifyingEncounter with ( ["Intervention, Order": "Above Normal Follow-up"] union ["Intervention, Performed": "Above Normal Follow-up"] union ( ["Intervention, Order": "Referrals where weight assessment may occur"] Referral where Referral.reason in "Overweight or Obese" ) union ["Medication, Order": "Above Normal Medications"] ) HighBMIInterventions such that Coalesce(start of HighBMIInterventions.relevantPeriod, HighBMIInterventions.authorDatetime)12 months or less on or before end of QualifyingEncounter.relevantPeriod Since the same code is in the value set Intervention, Performed": "Above Normal Follow-up and the 1/1/2019 encounter falls during the defined time frame of 12 months or less on or before end of QualifyingEncounter.relevantPeriod - the Qualifying encounter causes the patient to also appear in the Numerator even if no other action was taken. Simply because they had an initial encounter with a code that also qualifies for a follow up, they are in the Numerator. Can you clarify if this was the intent of the measure? Or if there is a possible error in the value sets overlapping? We don't believe that the intent was for patients with only a single visit to qualify for Numerator credit, but do not see a way based on the outlined logic to prevent that from occurring.