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Guidance for Representing Telehealth Encounters in QRDA I Format for eCQMs

The Centers for Medicare & Medicaid Services (CMS) has posted additional guidance for using the Quality Reporting Document Architecture I (QRDA I) format to represent telehealth encounters for the Eligible Professional and Eligible Clinician electronic clinical quality measures (eCQMs) used in CMS quality reporting programs for the 2020 and 2021 performance periods. There is no change to the original guidance provided by CMS in July 2020.

Representing Telehealth Encounters in QRDA I format by using the Qualifier attribute:

To represent “telehealth-eligible” Current Procedural Terminology (CPT) and Healthcare Common Procedure Coding System (HCPCS) codes for eCQMs in QRDA I, submitters should use the optional qualifier attribute of the encounter code element to send the telehealth modifier code in addition to the primary “telehealth-eligible” CPT or HCPCS encounter code from the eCQM-specified value sets.

The qualifier attribute name is set to a fixed code virtual “VR” selected from the HL7 ActCode code system. The applicable telehealth modifier, such as modifier 95, will be in the qualifier attribute value. The updated guidance provides an example xml.

The updated guidance is available on the Electronic Clinical Quality Improvement (eCQI) Resource Center.

The Cypress Validation Utility + Calculation Check (CVU+) is being updated to follow this guidance to filter out telehealth encounters when calculating eCQMs not eligible for telehealth encounters, which are listed in Table 2 referenced in the 2020 and 2021 reporting guidance. This update will be made available in Cypress scheduled for release in Fall 2020.

Additional Resources:

To find out more about eCQMs, visit the eCQI Resource Center. To report questions or comments on the eCQM specifications, visit the eCQM Issue Tracker. Note that an ONC Project Tracking System (Jira) account is required to ask a question or comment.


Last Updated: May 24, 2023