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      ​Thank you for your inquiry. CMS68 is an episode-based measure and is to be reported for every encounter during the measurement period, requiring the provider to attest to having documented a list of current medications. CMS68, however, does not include provider attribution logic. Therefore, if multiple providers report this measure in a shared EHR, all of the encounters documented by providers in the network in a given measurement period would be used to evaluate whether or not the numerator was met for all providers reporting on that patient for this measure. If measure requirements are met, all providers using the shared EHR will meet measure requirements.

      As you note, there may be cases where a shared EHR is used in which other providers may be held accountable for the performance of other providers within the network. In our experience, creating or adding elements to the measure for attribution has been challenging and is still under investigation from a programmatic standpoint given shared EHR structures.

      Your question seems to relate to a reporting challenge leading to misattribution, and would recommend you reach out to the QPP Help Desk.




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      ​Thank you for your inquiry. CMS68 is an episode-based measure and is to be reported for every encounter during the measurement period, requiring the provider to attest to having documented a list of current medications. CMS68, however, does not include provider attribution logic. Therefore, if multiple providers report this measure in a shared EHR, all of the encounters documented by providers in the network in a given measurement period would be used to evaluate whether or not the numerator was met for all providers reporting on that patient for this measure. If measure requirements are met, all providers using the shared EHR will meet measure requirements. As you note, there may be cases where a shared EHR is used in which other providers may be held accountable for the performance of other providers within the network. In our experience, creating or adding elements to the measure for attribution has been challenging and is still under investigation from a programmatic standpoint given shared EHR structures. Your question seems to relate to a reporting challenge leading to misattribution, and would recommend you reach out to the QPP Help Desk.
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      Ambulatory Clinician who is using an integrated EHR system has raised concern over his denominator pulling encounters from other facilities into his denominator. These encounters where not under his control and he is being held accountable for care given in other care settings and by other clinicians. I'm seeking guidance on how we should be handling clinicians who are using integrated EHR's (multiple facilities data aggregated into one system) when encounters from other facilities are being pulled into an a single clinician's quality measures. In this CMS68 example, the ambulatory clinician should have 100% numerator compliance because of his actions during his encounters with the patient, but because of his integrated EHR system, patients who are seen in other facilities are being pulled into his denominator and causing him to receive a failing numerator.

            edave Mathematica EC eCQM Team
            amitborkar Amit (Inactive)
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