FAQ Directory: Patient-Centered Medical Home (PCMH)

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5.24.2018 KM 02 G What are the expectations for assessing a patient’s social determinants of health? How many social determinants are required for each patient? Are any specific social determinants required to be collected?

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.

PCMH 2017

5.24.2018 KM 12 B What are examples of adult immunizations?

Examples of immunizations for an adult patient population include flu shots, pneumonia vaccine, shingles vaccine and tetanus.

PCMH 2017

5.24.2018 KM 03 Clarify the language in the guidance stating, “screening for adults for depression with systems in place to assure accurate diagnosis, effective treatment and follow-up.”

The U.S. Preventive Services Task Force (USPSTF) states that adults and adolescents should be screened for depression when a practice has access to services that can be used for follow-up, if there is a positive result (i.e., mental health providers within the practice or external to the practice to whom the practice can refer patients). To meet KM 03, practices are expected to have an approach to follow up and act on results.

PCMH 2017

5.24.2018 KM 14 Can the same report be used if the practice does medication reconciliation at least annually? How is KM 14 different from KM 15?

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.

PCMH 2017

5.24.2018 KM 13 Do PQRS reports or practices who participate in MSSP meet the reporting requirement for KM 13?

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).

PCMH 2017

5.24.2018 KM 17 May practices assess response only to medications treating a specific disease of interest?

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.

PCMH 2017

5.24.2018 KM 02 What if the patient answers “No” or does not want to provide information?

Medical records should clearly indicate that the patient has been asked about the specific item by including a notation that the patient answered “No” or declined to answer. Practices do not lose credit if the patient says “No” or declines to answer as long as it is documented. 

PCMH 2017

5.24.2018 KM 20 What types of evidence are acceptable as examples of demonstrating implementation of clinical decision support?

Use of flow sheets, demonstration of EHR prompts or other evidence of guideline implementation with which the provider is alerted when a specific service or action is needed at the point of care, based on evidence-based guidelines, would meet the intent of KM 20. In addition to the evidence, practices must also provide information on the condition addressed by the clinical decision support and the source of the evidence-based guideline on which the clinical decision support is based. 

Flow charts, copies of guidelines or empty templates do not demonstrate implementation of clinical decision support. These items show the guideline, but do not demonstrate its use at the point of care

PCMH 2017

5.24.2018 KM 02 What is the required frequency for a patient health assessment

NCQA does not prescribe a frequency; practices determine the time frame for conducting and updating patient health assessments according to a protocol that suits their patient population, aligns with evidence-based guidelines and allows for meaningful evaluation of data.

PCMH 2017

5.24.2018 KM 20 A Does use of the PHQ-2 or PHQ-9 meet the requirements of KM 20 A?

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).

PCMH 2017

5.24.2018 KM 12 Are practices required to provide a separate letter, phone script or other method for each service needed?

No. Practices may demonstrate the same evidence if:

  • The same method of outreach is used for each service.
  • Practices demonstrate an example of the outreach used. 

Practices must provide information about how the letter, phone script or other method is modified for each service reminder. 

PCMH 2017

5.24.2018 KM 20 G What qualifies as an overuse or inappropriateness issue?

KM 20 G requires evidence-based guidelines on appropriate use of services, which could include a prompt at the point of care to consider appropriateness of laboratory test ordering, avoidance of MRI as a first-line diagnostic test for back pain, appropriateness of antibiotics use, or appropriateness of specific referrals. 

NCQA encourages practices to look at ABIM’s Choosing Wisely website for more information on overuse/appropriateness (www.choosingwisely.org).

PCMH 2017