CMS Issues Telehealth Encounter Guidance for Quality Reporting Programs

by | Jul 3, 2020 | Meaningful Use & Quality Payment Program, Telehealth/Telemedicine

  • New telehealth encounter guidance is available for the Promoting Interoperability Programs and Quality Payment Program
  • There are 42 telehealth codes eligible for inclusion within the eligible professional/eligible clinician eCQMs for the 2020 performance period
  • For the 2021 performance period, 39 telehealth codes would be eligible, however, there are also additional eCQMs identified as not eligible for telehealth encounters

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New telehealth encounter guidance is available for the Promoting Interoperability Programs and Quality Payment Program.  The telehealth guidance applies to telehealth encounters for eCQMs for the following programs: 

  • MIPS and Advanced APMs
  • Comprehensive Primary Care Plus (CPC+)
  • Primary Care First (PCF) 
  • Medicaid Promoting Interoperability Program (for Eligible Professionals)

There are 42 telehealth codes eligible for inclusion within the eligible professional/eligible clinician eCQMs for the 2020 performance period, whether the encounter was provided in person or via telehealth.  The guidance also specifies those eCQMs which are not eligible for a telehealth encounter, including blood pressure and BMI screenings and follow-up, oncology, prostate cancer and cataract eCQMs.  

CMS notes, 

…there may be instances where the quality action cannot be completed during the telehealth encounter by eligible professionals and eligible clinicians. Specifically, telehealth-eligible CPT and HCPCS codes may be included in value sets where the required quality action in the numerator cannot be completed via telehealth. Therefore, it is the eligible professionals’ and eligible clinicians’ responsibility to make sure they can meet all other aspects of the quality action within the measure specification, including other quality actions that cannot be completed by telehealth.

For the 2021 performance period, 39 telehealth codes would be eligible, however, there are also additional eCQMs identified as not eligible for telehealth encounters, including related to primary open-angle glaucoma, children with dental decay/cavities, diabetic retinopathy, benign prostatic hyperplasia.  

The guidance comes as part of a larger effort by CMS to address expansion of telehealth coverage in the COVID-19 context as well as more permanently. HFMA reported in May that CMS is considering whether to make COVID-19 telehealth waivers permanent for Medicare.  CMS also recently finalized changes to Medicare Advantage and Part D which incentivize MA plans to contract with telehealth providers for specialities such as cardiology, primary care and psychiatry and published a Notice of Proposed Rulemaking on June 30 which, among other proposed changes, would make permanent certain telehealth and technology allowances for home health.  

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