The Centers for Medicare & Medicaid Services (CMS) has published an update of the 2021 Quality Reporting Document Architecture (QRDA) Category III Implementation Guide (IG), Schematrons, and Sample Files for Eligible Clinicians and Eligible Professionals Programs. The 2021 CMS QRDA III IG includes updates for the Merit-based Incentive Payment System (MIPS) Alternative Payment Model (APM) Performance Pathway (APP). This publication also includes relevant updates made for the Comprehensive Primary Care Plus (CPC+) and Primary Care First (PCF) Model.

The IG outlines requirements for eligible clinicians and eligible professionals to report electronic clinical quality measures (eCQMs), improvement activities (IA), and Promoting Interoperability (PI) measures for the calendar year 2021 performance period for these programs:

  • Quality Payment Program (QPP): MIPS
  • CPC+
  • PCF Model
  • Medicaid Promoting Interoperability (PI)

Updates to the 2021 CMS QRDA III IG includes:

  • Addition of Section 4.3.3 APM Performance Pathway (APP) to provide general APP information
  • Additional APP supporting updates:
    • Section 4.4 Identifiers
    • Section 5.1.1 informationRecipient
    • Table 3: QRDA III CMS Program Name
    • Section 5.1.4 documentationOf
  • Relevant updates for Section 4.1 Comprehensive Primary Care Plus Submissions and Section 4.2 Primary Care First (PCF) Submissions
  • Correction to PI_LVITC_2 Measure Exclusion Language as described in QRDA Known Issue QKI-3

Updates to the 2021 CMS QRDA III Schematron:

  • Updates to support conformance statement updates for APP reporting
  • Updates to disallow the PI Section for APP at the APM Entity Level, CPC+, and PCF reporting

Update to the 2021 CMS QRDA III Sample Files:

  • Added sample file with an example for APP

Additional QRDA-Related Resources:

Find additional QRDA-related resources, as well as current and past IGs, on the Electronic Clinical Quality Improvement (eCQI) Resource Center QRDA page. For questions related to this guidance, the QRDA IGs, or Schematrons, visit the ONC Project Tracking System (Jira) QRDA project.

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