In performing measure validation at my healthcare system, we believed we had uncovered an error in our vendor's quality filter - as they showed a patient in the denominator as UNMET, where our validation showed no Documentation of Current Meds was done because the patient didn't have a qualifying visit during our validation period. It turned out that our vendor was correct, as the denominator value set inexplicably contains 99211 as a qualifying visit. This patient was "seen" for a vaccination and billed as a 99211.

As you must be aware, 99211 is a visit code for a nurse or MA visit - not a clinician visit. Thus, unless there is a problem or complication with a nursing activity, a clinician does not see the patient, nor does use of this billing code create a reasonable expectation that a clinician would see, evaluate, or perform documentation for this patient visit. And yet, the numerator is met by having the "eligible clinician attest to documenting a list of current meds using all immediate resources available on the date of the encounter." Restating the obvious - it is impossible to ask for an attestation of a clinician assessment when the nature of the visit is such that no clinician sees the patient.

Eligible clinicians bill for 99211 visits on behalf of their nursing/MA staff - because these individuals cannot. However, just because an eligible clinician bills for a service - it does not imply that a clinician assessed the patient. If the E/M code submitted was a 99212-99215 or 99202-99205, which define clinician office visits, you should reasonably assume a clinician was involved in the visit (and thus expect a medication assessment to be done and documented).

Further - even if you unreasonably rejected the concerns above, our EHR vendor (Oracle Health, formerly Cerner), appropriately requires that a clinician complete medication review / reconciliation.

Please also note that our validation included a review of the 2024 value sets, and we believe that only this measure AND one other Depression Remission at 12 months, includes 99211 in the value set. While a patient could have a depression re-screen (such as a PHQ-9) done without a clinician visit - I would make the same argument as for Documentation of Current Medications in the Medical Record... It is unreasonable to assume a treating would routinely evaluate depression remission during a 99211 visit.

Remove 99211 from the value set for these two eCQMs.