Can Medicare ACO submit eCQM?

I posted a document yesterday regarding the reporting options for Medicare ACOs in 2022. Barriers are present to start down the path of eCQM measure reporting unless you are a single TIN with a single EHR. Or multi-TIN with single EHR (not as common).

3 MIPS eCQM measures

Medicare ACOs may remit 3 eCQM measures instead of CMS Web Interface or as CQM measures. The measures:

1. Diabetes: Hemoglobin A1c (HbA1c) Poor Control (>9%)
2. Controlling High Blood Pressure
3. Screening for Depression and Follow-Up Plan?

If your Medicare ACO is a single TIN with a certified (CEHR) single EHR, then you may submit your file via QPP portal.

If your ACO is comprised of multiple TINs and EHRs, then you will have barriers so far unresolved by Medicare

• Duplication when you combine all the QRDA III files as not patient-level files.?Duplication may be solved by instead using QRDA I files and combining those into a QRDA III for final reporting; and
• When submitting eCQM the ACO will need to enter an EHR identifier and Medicare has not determined which identifier to use from the multiple TINs and EHRs.
• It is under review by Medicare if an ACO can aggregate the QRDA I into QRDA III.

Open to any feedback or questions from Medicare ACOs trying to make decisions early.

Kris Gates, [email protected], 480.912.1209

Definitions:

• ?QRDA I - Quality Reporting Document Architecture (QRDA) Category I file is an individual patient-level report. It contains quality data for one patient for one or more eCQMs.
• QRDA III - Quality Reporting Document Architecture (QRDA) Category III file is an aggregate quality report that contains quality data for a set of patients for one or more eCQMs
• SMART on FHIR - Patient Lookup EHR Connector to pull quality measure answers from EHR using SMART on FHIR technology.