Yes. Because the practice has only one clinician, practice-level data would be the same as clinician-level data, and therefore count for both.
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Yes. Use of PHQ-2/PHQ-9 meets the requirement if practices demonstrate its use in monitoring depression treatment and provide an example of the tool’s implementation in clinical care and decision making at the point of care. The intent of KM 20 A is to implement clinical decision support during treatment, not for screening or diagnosis of a mental health condition. Practices that use an evidence-based tool built into the EHR or as part of a workflow in accordance with clinical guidelines can meet the requirements if they demonstrate the guideline and an example of the guidelines implementation (i.e., the tool’s use).
No. For KM 16, the practice must both (1) generate a report that demonstrates more than 50 percent of patients have documentation in their medical record that they were assessed and provided education on new prescriptions and (2) demonstrate evidence of the process, which could include showing a patient medical record during virtual review. It is up to the practice to determine the best method for sharing new medication information with patients, and the practice should consider patient language, literacy and health literacy in providing information or materials.
Practices must collect and document information on what may influence a patient’s overall safety, risk factors, health and well-being. The practice should consider all potential social determinants of health when collecting information from patients; however, practices are not required to have a complete list of every possible social determinant of health assessed for every patient. The purpose of this requirement is to collect information on areas that may be influencing/affecting a patient's health and well-being, many of which could be observed by the clinician/care team. Each practice is unique and there may be social determinants of health that are more common for their patient population as compared to others. Therefore, the practice may want to consider identifying common areas and develop standard questions to ask patients. However, the practice should not limit the assessment to just the most common areas or fields provided in their EHRs, to ensure all relevant information is documented in the patient's medical record.
No. While advance care planning could include a completed advance directive, it’s not required to meet KM 02. The practice must demonstrate that it documents results of advance care planning discussions with patients to meet this requirement. If a practice has an advance directive on file and documented in the patient medical record, that would also meet the intent.
No. The requirement to provide new information applies to all new medications prescribed to a patient, especially for patients identified in Concept CM as needing care management. Patients may have multiple comorbidities and medications, so it is crucial that they receive information about all medications prescribed to them
No. Practices must ask about all medications prescribed to the patient and assess their efficacy, especially for patients identified in CM 01 as needing care management. Patients may have multiple comorbidities and medications, so it is crucial to evaluate their response and barriers to adherence for all medications prescribed to them.
Practices could use a variety of methods to collect language needs information on a large patient population. They may collect data from all patients and their families to create a report showing language needs or obtain data from an external source (e.g., data about the local community or its patient population).
Patients who do not speak English and patients from racial/ethnic minority groups may be less inclined to provide this information. Care should be taken to request the information using methods that respect multi-cultural differences.
Resource: NCQA’s 2010 Multicultural Health Care Standards (Abbreviated) E-Pub: http://store.ncqa.org/index.php/2010-mhc-standards-and-guidelines-electronic-pub.html
No. PQRS reports and Medicare Shared Savings Program (MSSP) would not meet the requirement. For KM 13, practices must demonstrate they participate in an external program that assesses practice-level performance, using a common set of specifications to benchmark results. The external program should also publicly report results and have a process to validate measure integrity.
PQRS is not a performance-based recognition program and is being rolled into MIPS under the Quality Performance category. The MSSP makes data on Accountable Care Organizations (ACOs), rather than at the practice level, publicly available. Because this criterion is not eligible for shared credit, data is required to be at the practice level.
While participation in these programs does not meet KM 13, practices can use participation in MSSP to meet QI 19. Practices in Track 1 MSSP, would be eligible for QI 19 A (1 credit), and practices in Track 2 MSSP would be eligible for QI 19 B (2 credits).
Yes. Medication reconciliation (KM 14) includes the process to check for drug and condition interactions in addition to confirming the list of medications with the patient (KM 15). The evaluator may probe for the practice’s process to confirm the same report can be used.