Thank you for your inquiry about CMS69v9: Preventive Care and Screening: Body Mass Index (BMI) Screening and Follow-Up Plan. You are correct that 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 the 2020 version of the measure specification (CMS69v8), a follow-up/intervention needed to be documented on or before the most recent high/low BMI (12 months or less on or before the qualifying encounter). To meet the numerator requirements for the current 2021 specification (CMS69v9), the most recent high/low BMI has to be documented during the qualifying encounter or during the previous twelve months and 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' Thank you for your feedback. We will take it into consideration during the next eCQM Annual Update.

EMR vendor is interpreting eCQM code to mean that providers won't receive credit for meeting the requirements unless the follow-up/counseling provided is documented ONLY on the day of the visit. They are disregarding the guidance that states the follow-up/counseling order can take place the day of the visit or in the previous 12 months.