Misaligned CQMs and eCQMs

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    • Type: EC eCQMs - Eligible Clinicians
    • Resolution: Answered
    • Priority: Moderate
    • Component/s: None
    • None
    • Vera L Macon
    • McKesson Corporation
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      Thank you for your inquiry about CMS138v13 (performance period 2025). We will review the CPT codes and consider adding appropriate codes in a future annual update cycle. Clinically equivalent services can be mapped to the measure's value sets. If mapping is done, you should maintain documentation in case of a CMS audit.

      The eCQM measures do not reference modifiers because codes in the value sets meet criteria regardless of whether or not a modifier is present (unless a measure specification states otherwise).

      You may reference the "Telehealth Guidance for eCQMs for Eligible Clinician Quality Reporting" for additional guidance: https://ecqi.healthit.gov/sites/default/files/2025-EC-Telehealth-Guidance.pdf. This resource can be found on the eCQI Resource Center: https://ecqi.healthit.gov/ep-ec?qt-tabs_ep=ecqm-resources&global_measure_group=eCQMs.
      Show
      Thank you for your inquiry about CMS138v13 (performance period 2025). We will review the CPT codes and consider adding appropriate codes in a future annual update cycle. Clinically equivalent services can be mapped to the measure's value sets. If mapping is done, you should maintain documentation in case of a CMS audit. The eCQM measures do not reference modifiers because codes in the value sets meet criteria regardless of whether or not a modifier is present (unless a measure specification states otherwise). You may reference the "Telehealth Guidance for eCQMs for Eligible Clinician Quality Reporting" for additional guidance: https://ecqi.healthit.gov/sites/default/files/2025-EC-Telehealth-Guidance.pdf . This resource can be found on the eCQI Resource Center: https://ecqi.healthit.gov/ep-ec?qt-tabs_ep=ecqm-resources&global_measure_group=eCQMs .
    • CMS0138v13
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      It has been noted with certain CQMs and eCQMs, telehealth codes and modifiers are not aligned between the measure types.

      I have forwarded a message to the NCQA regarding OID: 2.16.840.1.113883.3.464.1003.101.12.1080 for Telephone visits in Tobacco, as its CQM does not mirror telehealth visit codes nor guidance. It is understood that measure types do not function in the same way as a means of reporting; however, the intent and guidance are being skewed do to misalignment in the area of telehealth.
      Show
      It has been noted with certain CQMs and eCQMs, telehealth codes and modifiers are not aligned between the measure types. I have forwarded a message to the NCQA regarding OID: 2.16.840.1.113883.3.464.1003.101.12.1080 for Telephone visits in Tobacco, as its CQM does not mirror telehealth visit codes nor guidance. It is understood that measure types do not function in the same way as a means of reporting; however, the intent and guidance are being skewed do to misalignment in the area of telehealth.

      It has been noted with certain CQMs and eCQMs, telehealth codes and modifiers are not aligned between the measure types.

      I have forwarded a message to the NCQA regarding OID: 2.16.840.1.113883.3.464.1003.101.12.1080 for Telephone visits in Tobacco, as its CQM does not mirror telehealth visit codes nor guidance. It is understood that measure types do not function in the same way as a means of reporting; however, the intent and guidance are being skewed do to misalignment in the area of telehealth.  The previously mentioned OID affects the following eCQMs/CQMs that we interact with:

      eCQMs using this data element:
      rCMS125v13 - Breast Cancer Screening
      CMS138v13 - Preventive Care and Screening: Tobacco Use: Screening and Cessation Intervention
      CMS156v13 - Use of High-Risk Medications in Older Adults
      CMS165v13 - Controlling High Blood Pressure
      CMS2v14 - Preventive Care and Screening: Screening for Depression and Follow-Up Plan

      MIPs measures that utilize telehealth codes:
      MIPS 47: ACP
      MIPS 134 CQM/Registry: Depression
      MIPS 144: Pain Care Plan
      MIPS 450: HER2 Positive Breast Cancer
      MIPS 451: RAS (KRAS and NRAS) Gene Mutation Testing
      MIPS 453: Patients who Died from Cancer in the Last 14 Days of Life
      MIPS 457: Patients who Died from Hospice in Less than 3 Days 
      MIPS 487: Screening for SDOH

      The eCQM OID use: 98966, 98967, 98968, 99441, 99442, 99443

      CQMs use: 98000, 98001, 98002, 98003, 98004, 98005, 
      98006, 98007. Some CQMs extend to 98016.

      CQMs include a modifier note that states the following: 
      NOTE: Patient encounters for this measure conducted via telehealth (including but not limited to encounters coded with GQ, GT, POS 02, POS 10) are allowable for Submission Criteria 1. Please note that effective January 1, 2025, while a measure may be denoted as telehealth eligible, specific denominator codes within the encounter may no longer be eligible due to changes outlined in the CY 2024 PFS Final Rule List of Medicare Telehealth 
      Services. 

      So for clarity of the issue being called out and for an example, please review the telehealth coding and guidance differences between the Tobacco measures CQM to eCQM and provide CMS' intent as to how providers are to address and bill telehealth in a consistent way without inadvertently excluding patients based on measure type. In some circumstances, we offer both collection types.

            Assignee:
            AIR EC eCQM Team
            Reporter:
            Vera Macon
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              Created:
              Updated:
              Resolved:
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