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Ask Dr. Mingle: eCQMs vs. CQMs for ACOs, Primary Care First attribution discrepancies, & more!

This week’s episode of Ask Dr. Mingle features questions about eCQMs vs. CQMs for ACO quality reporting, understanding Primary Care First attribution discrepancies, and advice for navigating MIPS as a small practice.

Click play to listen to this week’s episode right now:

Questions and Answers in this Episode

Maria Asks: “What if you are a small practice with one physician, and you have trouble finding measures you qualify for?”
  • Small practices receive a Small Practice Bonus of six points automatically added to your quality score.
  • Small practices continue to qualify for the three-point minimum for any measure. You cannot score less than three points for any measure, even if you do not meet data completeness or case minimum requirements.
  • Small practices can use the Eligible Measure Applicability (EMA) rules to submit specialty measure sets that apply to your specific situation.
  • If you are still struggling after the EMA rules and bonuses above (which does happen), an exception is an option. You can file for a Hardship Exemption before the Hardship Exemption Deadline. If you’ve passed the deadline, you can still ask CMS for a targeted review of your situation.
Emily asks: “We have noticed quite a discrepancy between patients on our panels and patients attributed to Primary Care First. Many of these patients had Annual Wellness Visits but were not attributed to PCF. Do you have any insights on that?”
  • In the first part of his answer, Dr. Mingle explained that in the Primary Care First attribution hierarchy, Annual Wellness Visits are not at the top. The one activity that supersedes an AWV for attribution is patient choice. If a patient goes to the CMS website and chooses their Primary Care Provider, this will overrule any AWVs.
  • Beyond patient choice, some billing irregularities can get in the way of attribution. Dr. Mingle explains that PCF program participation is specific to a practice’s Tax Identification Number (TIN), location, and provider. This means that if an Annual Wellness Visit is done in your organization but attributed to a provider that isn’t on your list of PCF providers, it will not count toward attribution. Similarly, if an AWV is attributed to a different (non PCF) location, it probably won’t count toward PCF attribution.
  • Finally, competition can come into play. If one of your patients has an Annual Wellness Visit in another organization, this can override the patient’s attribution to your organization in PCF.
George asks: “Our ACO is preparing to report the APM Performance Pathway (APP) eCQMs. There are nine different EHRs represented in our ACO. A string of missed deadlines and excuses makes me wonder if it can come together in time. Any advice?”
  • Many groups don’t realize that the APP can be satisfied using eCQMs or CQMs.
  • Typically, CQMs are much easier to provide to Medicare and are equally valid as eCQMs.
  • There are limitations to what an EHR can do with eCQM reporting. Additionally, your eCQM processes can be broken by system updates, adding new groups to your ACO, or groups changing EHRs within your organization.
  • In contrast, CQMs are more flexible and allow for a changing EHR environment.
  • CQMs don’t require development or implementation time – they work “right out of the box” – and allow you to adapt to complex processes that would typically be incompatible with eCQM reporting.

Send us your value-based care questions!

If you’d like to ask a question about MIPS, Primary Care First, ACO quality reporting, or any other Alternative Payment Model, you can reach out to us in three ways:

  • You can leave your questions in a YouTube comment under any episode of “Ask Dr. Mingle.”
  • On LinkedIn, leave your questions in a comment on any of our posts.
  • And you can reach out directly by sending an email to Please put “Ask Dr. Mingle” in the subject line when you submit your questions via email.
Want to learn more about Primary Care First?

Our Primary Care First success guide for 2022 is available today. In this webinar, Roxane Thacker, VP of Managed Clinical Services here at Mingle Health, provides an overview of what it takes to prepare and be successful in the program in 2022.

How to Succeed in Primary Care First
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