The Centers for Medicare & Medicaid Services (CMS) is providing more detailed guidance for how healthcare providers should report electronic clinical quality measures for telehealth encounters. A total of 39 electronic clinical quality measures (eCQMs) were recently published for the 2021 performance period.1

Any eligible professionals or eligible clinicians participating in CMS quality reporting programs for the 2020 performance period can use these updated telehealth-eligible CQMs for the Merit-based Incentive Payment System and Advanced Alternative Payment Models, Comprehensive Primary Care Plus, Primary Care First, and the Medicaid Promoting Interoperability Program for Eligible Professionals, according to CMS.

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.” 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,” CMS says.

CMS has identified 50 telehealth-eligible CQMs and 42 telehealth-eligible eCQMs for clinicians for 2020 performance period reporting, says Lauren Patrick, president of Healthmonix, a healthcare analytics company based in Malvern, PA. These are measures that represent quality actions that can be performed remote to the patient, Patrick explains.

Some examples of these measures include Advance Care Plan, Pneumococcal Vaccination Status for Older Adults, Documentation of Current Medications in the Medical Record, Screening for Depression and Follow-Up Plan, and Controlling High Blood Pressure.

These are quality measures that existed prior to the COVID-19 pandemic and were developed to include telehealth visits in their patient population. Because of the shift to telehealth in 2020, there has been a renewed interest in understanding which measures can and should be tracked for these visits.

“Healthcare providers and organizations have exponentially increased the use of telehealth in their practices during the public health emergency brought on by COVID-19. Since they are required by the QPP [quality payment program] to report quality measures, [providers] need to understand which measures are relevant to these telehealth visits,” Patrick says. “Many of the quality measures require the inclusion of telehealth visits in their reporting. Providers need to understand this, and work to ensure that these quality actions are met in the telehealth visits.”

If the quality measures are not met during telehealth visits, they will negatively affect the providers’ quality score in the QPP and other quality and value-based programs, Patrick cautions.

Telehealth visits cannot be excluded in the quality measure reporting. They will be scored as “quality not met” when they are not handled during these visits. Telehealth visits need to conform to standard clinical workflows and patterns of care. This new modality of patient care needs to incorporate all aspects of the established in-patient visits that can support the quality measures.

It is important to ensure quality measure actions are included in the workflows for telehealth visits, just as they are included for in-person visits, Patrick says.

“The ultimate purpose of any medical care is to maintain or improve health and well-being. Thus, how clinical applications of telemedicine affect the quality of care and its outcomes is a central evaluative question, as it is for any health service,” she says. “CMS should continue to evaluate and evolve quality measures to reflect and reinforce new technology that can assist in patient care. Note that if we find that quality is trending downward when viewing telehealth visits, this could be used as an argument to reduce telehealth visits.”

As a point of reference, Patrick notes that when studying quality data in years past and comparing the performance against in-person visits, one could see a significant decrease in the performance of those measures. “It can be difficult to ensure that these quality measures are met as providers transition to telehealth workflows and/or the patients are remote,” she says. “Ensuring that the quality actions and documentation of such are included in the workflows for telehealth visits provides a path to better performance.”


  1. Centers for Medicare & Medicaid Services. Telehealth guidance for electronic clinical quality measures (eCQMs) for eligible professional/eligible clinician 2020 quality reporting.