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Type: EC eCQMs - Eligible Clinicians
Resolution: Answered
Priority: Moderate
Component/s: None
Labels:
None

Contact Name:
Molly Minehan
Contact Email:
molly.minehan@onegi.com
Contact Phone:
6036676996
Institution/Name:
OneGI
Solution:

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Thank you for your question regarding CMS50v14. The measure’s Guidance section states, “The clinician who refers the patient to another clinician is the clinician who should be held accountable for the performance of this measure.” However, the current logic cannot assign attribution to the provider. The measure determines whether the numerator requirements have been met based on information in the patient’s EHR. For patient-based measures, while a specific clinician may perform an action (or fail to) for a given patient, and thereby meet (or fail to meet) the numerator requirements, any clinician who has a qualifying encounter with that same patient, uses the same EHR, and reports on that measure can also receive credit (either favorable or unfavorable). In your situation, if the endocrinologist’s report is received timely, then both TIN A and TIN B (under the same EHR) would be able to report favorable performance on the measure. However, if the endocrinologist’s report is not received, then both TIN A and TIN B would report unfavorable performance on the measure.

We are also happy to assist with any additional questions you may have regarding the recent change made by your implementers which affected your denominator counts for this measure. Please provide more detail on the changes if you have outstanding questions.

Show
Thank you for your question regarding CMS50v14. The measure’s Guidance section states, “The clinician who refers the patient to another clinician is the clinician who should be held accountable for the performance of this measure.” However, the current logic cannot assign attribution to the provider. The measure determines whether the numerator requirements have been met based on information in the patient’s EHR. For patient-based measures, while a specific clinician may perform an action (or fail to) for a given patient, and thereby meet (or fail to meet) the numerator requirements, any clinician who has a qualifying encounter with that same patient, uses the same EHR, and reports on that measure can also receive credit (either favorable or unfavorable). In your situation, if the endocrinologist’s report is received timely, then both TIN A and TIN B (under the same EHR) would be able to report favorable performance on the measure. However, if the endocrinologist’s report is not received, then both TIN A and TIN B would report unfavorable performance on the measure. We are also happy to assist with any additional questions you may have regarding the recent change made by your implementers which affected your denominator counts for this measure. Please provide more detail on the changes if you have outstanding questions.
2025 Performance Period EC eCQMs:

CMS0050v13
Impact:

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The denominator being reported in the EHR changed drastically from one month to the next when they implemented a recent change in the logic for the aggregation of this measure. The YTD denominator through the end of June of 2025 was 381. The YTD denominator through the end of July of 2025 increased to 4,400 after a logic change was implemented on 7/23/25. The 2024 total denominator for this group of 14 providers was only 584.
The developers who made this change are referencing a 2020 JIRA ticket about this measure to explain the increase of roughly 4,100 denominator events in just 1 month. The JIRA ticket they are referencing is included in the description below.

Show
The denominator being reported in the EHR changed drastically from one month to the next when they implemented a recent change in the logic for the aggregation of this measure. The YTD denominator through the end of June of 2025 was 381. The YTD denominator through the end of July of 2025 increased to 4,400 after a logic change was implemented on 7/23/25. The 2024 total denominator for this group of 14 providers was only 584. The developers who made this change are referencing a 2020 JIRA ticket about this measure to explain the increase of roughly 4,100 denominator events in just 1 month. The JIRA ticket they are referencing is included in the description below.

I’m seeking clarification on how CMS50 – Closing the Referral Loop: Receipt of Specialist Report – applies in a scenario where a hospital and a specialty practice share the same EHR system but operate under separate Tax Identification Numbers (TINs).

Scenario:

A gastroenterology practice bills under TIN A and shares an EHR with a hospital that bills under TIN B.
Patient Jones has two qualifying office visits in 2025:

Visit 1: At the gastroenterology practice (TIN A), the provider initiates an outgoing referral to an endocrinologist.
Visit 2: At the hospital (TIN B), the patient sees a PCP, but no referral is generated during this encounter.

Question: Based on CMS guidance, the referring clinician is held accountable for the performance of this measure. Therefore, would it be correct to conclude that: [Quality ID...ist Report], [2025 MIPS...ipt of ...], [Closing th...ist Report]

Patient Jones is included in the denominator for TIN A because the provider at TIN A initiated a qualifying referral during a qualifying encounter.
Patient Jones is not included in the denominator for TIN B, since no referral was made during the encounter under TIN B, despite the shared EHR?

I want to confirm that the shared EHR does not affect denominator attribution, and that attribution is strictly tied to the referring provider’s TIN and the presence of a qualifying referral during the measurement period.

The developers who have made this logic change in the EHR referenced the Jira ticket linked below from 2020.

JIRA ticket