The Centers for Medicare & Medicaid Services (CMS) has published an update of the 2021 Quality Reporting Document Architecture (QRDA) Category III Implementation Guide (IG), Schematron, and Sample Files for Eligible Clinicians and Eligible Professionals Programs. The updated 2021 CMS QRDA III IG includes the addition of Merit-Based Incentive Payment System (MIPS) Alternative Payment Model (APM) Entity reporting for QRDA III submissions.

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: Merit-based Incentive Payment System (MIPS) and Advanced Alternative Payment Models (APMs)
  • Comprehensive Primary Care Plus (CPC+)
  • Primary Care First (PCF)
  • Medicaid Promoting Interoperability (PI)

The updated 2021 CMS QRDA III IG includes these changes:

  • Added a new CMS Program Name code “MIPS_APMENTITY”, which is required for MIPS APM Entity reporting.
  • Updated Section 4.3 – Merit-Based Incentive Payment System (MIPS) QRDA III Submissions, and Section 4.4 – Identifiers with relevant language for MIPS APM Entity reporting.
  • New conformance statements for MIPS APM Entity reporting.

Changes to the 2021 CMS QRDA III Schematron:

  • The addition of Conformance rules to support MIPS APM Entity reporting.

Update to the 2021 CMS QRDA III Sample Files:

  • Addition of a new sample file showing the use of MIPS_APMENTITY.

Additional QRDA-Related Resources:

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

About Author

Healthcentric Advisors
As the New England Quality Payment Program Support Center, Healthcentric Advisors assists New England-based physician and other eligible clinical practices to prepare for and participate in the new Quality Payment Program (QPP), established by the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA).