Thank you for your inquiry. In CMS69v9 (2021), the change to link the timing of the BMI with the follow up action was intentional and differs from previous versions of the measure. This change is captured in the posted technical release note for the 2020 performance period as follows: "Revised measure timings to improve alignment with the intent of the measure requirements." This annual update resulted in changing the timing anchors for the clinical actions included in the numerator to better reflect the appropriate workflow when a patient with a BMI outside of normal parameters requires follow up. Based on the previously published versions, a follow up action could have occurred prior to the high/low BMI measurement. An example scenario for performance year 2020 is as follows: 3/1/2019 – Order for referral for weight assessment 11/1/2019 – BMI calculated as high 1/1/2020 – Encounter for BMI evaluation The scenario above does not indicate a recent intervention or follow up based upon the most current BMI because the follow up action is linked to the encounter date with a look-back period (applies to the versions implemented in performance period 2020 and prior). The clinical evidence supports providing the follow up after a result outside of the normal BMI range is established, to provide high quality patient care. Therefore, the measure version for 2021 implementation modifies the timing to ensure the patient is receiving more timely intervention(s) from their provider(s).

In the 2021 specs, the timing for the follow up actions in the numerator have been changed so the follow up is now relative to the BMI documentation, not the qualifying encounter, as it has been in past versions. This means potentially the follow up could happen after the qualifying encounter, or even after the measurement period. I do not see this change documented in the technical release notes. Is this an intentional change?