CMS Guidance on Telehealth Encounters in eCQMs

In June 2020, the Centers for Medicare and Medicaid Services (CMS) released guidance on including telehealth encounters in electronic clinical quality measures (eCQMs) for the 2020 and 2021 quality reporting performance periods. Here is what you need to know about this new policy as an eligible professional or eligible clinician.

COVID-19 Has Increased Telehealth Use

Many physician offices canceled or severely restricted routine ambulatory appointments during the early months of the coronavirus pandemic. During this period, telehealth visits increased substantially. The Centers for Disease Control and Prevention has recommended expanding telehealth to ensure access to essential services during the COVID-19 pandemic. The US Department of Health and Human Services (HHS) has also taken steps to make it easier to provide telehealth services, including expanding allowable telehealth services under Medicare and Medicaid and providing HIPAA flexibility.

The new CMS guidance allows eligible professionals and eligible clinicians to include telehealth encounters in eCQMs for the 2020 and 2021 quality reporting performance periods. This guidance furthers the goal of encouraging telehealth by ensuring that telehealth encounters count toward meeting quality performance thresholds. 

CMS Has Released Telehealth Guidance for Electronic Clinical Quality Measures (eCQMs)

The new CMS guidance provides a list of telehealth encounters that eligible professionals and eligible clinicians may include in eCQM reporting for the 2020 and 2021 quality reporting performance periods. The guidance applies to eligible professionals and clinicians in both tracks of the Quality Payment Program (QPP): the Merit-Based Incentive Payment System (MIPS) and the Advanced Alternative Payment Models (Advanced APM). The telehealth-eligible eCQM guidance also applies to participants in the Comprehensive Primary Care Plus (CPC+) Alternative Payment Model, the Primary Care First Alternative Payment Model, and the Medicaid Promoting Interoperability Program for Eligible Professionals.

The guidance also lists the eCQMs for which telehealth encounters are not appropriate in 2020 and 2021, including those requiring in-person measurements like blood pressure screening, body mass index (BMI) screening, or vision screening after cataract surgery.

How the eCQM guidance Applies to You

If you or your group is eligible for MIPS, participates in an Advanced APM, or participates in the CPC+, Primary Care First, or the Medicaid Promoting Interoperability Program, the new eCQM guidance provides a pathway for including telehealth encounters in your quality reporting for the 2020 and 2021 performance periods. By including telehealth encounters in eCQMs, you may be able to meet QPP or other performance benchmarks that would be unattainable with just in-person visits. Therefore, including telehealth encounters in eCQMs may preserve your eligibility for positive payment adjustments and/or quality bonuses in 2022 and beyond.

In both the 2020 and 2021 quality reporting performance periods, CMS notes that the majority of eligible professional and eligible clinician eCQMs are based on CPT and HCPCS codes that are appropriate for use in billing telehealth or in-person encounters. Currently, the eCQM logic and value sets do not differentiate between telehealth and in-person visits when these telehealth-eligible codes are used. Therefore, you can include these encounters in eCQMs, whether they were provided in-person or via telehealth.

As an eligible professional or eligible clinician, you are responsible for determining whether you can complete all aspects of an eCQM-measured quality action during a telehealth encounter, or if in-person follow-up is needed.

An Overview of the Telehealth-Eligible eCQMs

For the 2020 quality reporting performance period, CMS has identified 42 eCQMs for which you may include telehealth encounters. This includes the vast majority of the 47 eCQMs for 2020. Telehealth-eligible eCQMs are calculated based only on Medicare telehealth-eligible CPT and HCPCS codes. The telehealth-eligible eCQMs include:

• Patients’ receipt of selected preventive care and screening like cancer and depression

• Functional status assessments for knee replacements, hip replacements, and congestive heart failure 

• Diabetes management

• Cognitive assessments

The guidance also lists five eCQMs for which you may not include telehealth encounters in the 2020 quality reporting performance period. These eCQMs are focused on the following: 

• High blood pressure screening

• BMI screening

• Quantification of oncology pain intensity

• Avoiding overuse of bone scans in low-risk prostate cancer patients

• Visual acuity within 90 days following cataract surgery 

For these eCQMs, even if Medicare telehealth-eligible codes form part of the eCQM value set, you may include only in-person encounters. 

A complete list of the telehealth-eligible eCQMs for 2020 is available here. A comprehensive definition of each 2020 eCQM, including specifications and telehealth eligibility, is available here.

For the 2021 quality reporting performance period, CMS has identified 39 eCQMs for which you may include telehealth encounters out of a total of 47 eCQMs. The telehealth-eligible eCQMs for 2021 are similar to those in 2020, with 38 telehealth-eligible eCQMs in common across the two years. Overall, four eCQMs for which you could include telehealth encounters in 2020 will no longer allow telehealth encounters in 2021. These include eCQMs focused on diabetic retinopathy, children with dental decay, urinary symptom scores in benign prostatic hyperplasia, and optic nerve evaluation in primary open-angle glaucoma. In contrast, you may include telehealth encounters in the quantification of oncology pain intensity eCQM in 2021, though that eCQM was telehealth-ineligible in 2020.

A complete list of the telehealth-eligible eCQMs for 2021 is available here. A comprehensive definition of each 2021 eCQM, including telehealth eligibility, is available here.

How TempDev Can Help

If you are an eligible professional or clinician and need help determining when and how to include telehealth encounters in your 2020 and 2021 eCQMs, TempDev can review the regulatory requirements and advise you on the best course of action. The QPP consultants at TempDev can also help you optimize workflows to meet or exceed MIPS and Advanced APM performance thresholds in 2020 and 2021, even during the COVID-19 pandemic. 

Call us at 888.TEMP.DEV, or contact us here to get started reviewing your 2020 and 2021 eCQM reporting options.