CMS clarifies eCQM requirements for eligible professionals (EPs) under the Medicaid Electronic Health Record (EHR) Incentive Program for 2018 reporting.

March 26, 2018 - 9:54am

The Centers for Medicare & Medicaid Services (CMS) is writing to clarify the electronic clinical quality measure (eCQM) requirements for eligible professionals (EPs) under the Medicaid Electronic Health Record (EHR) Incentive Program for 2018 reporting. 

The number of eCQMs that EPs must report remains the same as 2017.  Specifically, EPs must report any six available eCQMs relevant to their practice. 

The menu of eCQMs also remains the same 53 that were available to EPs in 2017.  Note that this will not exactly align with the eCQMs available to eligible clinicians under the Quality Payment Program (QPP).  Two changes were made to eCQMs for QPP 2018 reporting:

·       CMS645v1 was finalized for QPP, but is not available for EPs in the Medicaid EHR Incentive Program

·       CMS166v7 was removed from QPP, but is still available for EPs in the Medicaid EHR Incentive Program

Both of these exceptions are noted on the eCQI Resource Center: https://ecqi.healthit.gov/eligible-professional-eligible-clinician-ecqms.

 

As stated in the 2018 IPPS rule, at 82 FR 38486, the reporting period for eCQMs will remain one full year for EPs who have previously demonstrated meaningful use:

 

“We further explained that the CQM reporting period for the Medicaid EHR Incentive Program in 2018 for EPs that have demonstrated meaningful use in a previous program year would remain 1 full year (CY 2018) to align with the corresponding performance period in MIPS for MIPS eligible clinicians. If changes are made to the MIPS performance period through future rulemaking, we will revisit the Medicaid EHR Incentive Program policies to continue our alignment goals.”

 

The reporting period for EPs demonstrating meaningful use for the first time remains 90 consecutive days.

 

The relevant pages on the CMS website have been updated, specifically the document that outlines the requirements for eCQM reporting for Medicare and Medicaid EHR Incentive Programs in 2017 and 2018: https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/CQM_Table.pdf.

 

We are also taking this opportunity to reiterate our previous guidance on which eCQM specifications states should accept from providers:

 

Question: The eCQM specifications are updated each year. Which year(s) specifications can/should a state accept from providers?

 

Answer: Vendors are not required to update CEHRT each year to the latest specifications in order to remain certified (for more information see https://questions.cms.gov/faq.php?id=5005&faqId=8896 and https://www.healthit.gov/policy-researchers-implementers/42-question-06-13-042). Therefore, it is possible that Medicaid providers will have CEHRT that produce eCQMs specified to a variety of years.  States should always be able to accept the most recent version for each eCQM and must also allow providers to report on older versions (electronically or through attestation), if that is what their CEHRT is able to produce.

 

For example, CMS146 (Appropriate Testing for Children with Pharyngitis) was updated to version 5 in 2017 for 2018 reporting.  Because the earliest version of the eCQM that 2014 Edition CEHRT could be certified with is 2012 (CMS146v1), states must accept manual attestation from providers using 2014 Edition CEHRT who are able to produce CMS146v1-CMS146v5.  Note that each of these versions has one numerator and one denominator and therefore the logic in the state’s attestation system would not need to vary.  States may, but are not required to, gather information from providers about which version of the eCQM their CEHRT produces and they are reporting. If a state is collecting eCQMs electronically, the state must be able to collect the latest version (CMS146v5) and may choose how many previous versions they wish to collect.  For example, a state may decide that the previous two years of specifications will still provide useful data and therefore collect CMS146v3-CMS146v5 electronically, but providers whose 2014 Edition CEHRT can only produce CMS146v1-CMS146v2 would have to attest manually. Note that the earliest eCQM specifications that 2015 Edition CEHRT could have been certified to is 2016.

 

Note that for QPP, CMS requires the most recent published specifications applicable to the reporting period to be used. The eCQM specifications for Eligible Professionals and Clinicians published on the eCQI Resource Center in May 2017 and the applicable addendum published in September 2017 must be used for the 2018 reporting period.

 

Last Updated: March 26, 2018