Thank you for your inquiry about CMS69v9: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan. You are correct that previously published versions of this measure allowed for the follow-up/intervention to be documented on or before the most recent high/low BMI (12 months or less on or before the qualifying encounter). However, changes to the timing anchors in CMS69v9 (2021), specific to the clinical actions included in the numerator, require a follow-up intervention be 12 months on or after the most recent high/low BMI. To meet the numerator requirements for CMS69v9, the most recent high/low BMI has to be documented during the qualifying encounter or during the previous twelve months. However, the follow-up plan/intervention for the most recent high/low BMI must be on or after the most recent high/low BMI. High BMI and Order for Follow Up "Most Recent Documented BMI" MostRecentBMI   with ( ( ( ["Intervention, Order": "Follow Up for Above Normal BMI"]       union ["Intervention, Order": "Referrals Where Weight Assessment May Occur"] ) ReferralHighBMI       where ReferralHighBMI.reason in "Overweight or Obese" )     union ["Medication, Order": "Medications for Above Normal BMI"] ) HighBMIIntervention     such that MostRecentBMI.relevantDatetime 12 months or less on or before day of HighBMIIntervention.authorDatetime   where MostRecentBMI.result >= 25 'kg/m2' As a result, in the scenario that you outlined, this patient will not meet the measure numerator criteria because the follow-up plan documented on 03/1/2021 is prior to the most recent high BMI on 04/1/2021. Thank you for your feedback. We will take it into consideration during the next eCQM Annual Update.

In CMS69v9 (2021), the change to link the timing of the BMI with the follow up action changed which resulted in changing the timing anchors for the clinical actions. Based on the previously published versions, a follow up action could have occurred prior to the high/low BMI measurement. The changes described will now change a previously met outcome to unmet when a new BMI is captured even though the previously met follow up numerator actions were performed on during the qualifying encounter with an abnormal BMI. please review the example below. The follow up plan has not changed but was not recorded within the 4/1/21 visit. Did you intend for the Met outcome to stick once completed for the measurement period? the way it is now, a previously Met outcome will flip with a new abnormal BMI, even if it is a few days after and the plan would not change. 3/1/2021 – Encounter for BMI evaluation 3/1/2021 – BMI calculated as high 3/1/2021 – follow up plan documented using Smart data element Measure is Met as outcome 4/1/21 - BMI updated during specialist visit with 2lbs loss but still seen as abnormal. Measure is now unmet due to more recent BMI