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What is the Eligibility Measure Applicability (EMA) Process?

Friday, December 11 2020

To receive points in the Quality performance category, MIPS-eligible clinicians and groups are generally required to submit six quality measures. One of the quality measures should be an outcome measure (outcome measures show how a healthcare service or intervention affects patients’ health status); however, if no outcome measure is available­­, a high priority measure [1]should be reported. In recognition of the fact that some specialists may not be able to identify six clinically relevant quality measures to report, specialists have the option of reporting a full specialty measure set, which can contain fewer than six measures. This option prevents specialists from being penalized for submitting less than six quality measures.

When a clinician or group submits fewer than six measures or does not submit an outcome or high-priority measure, CMS will use the Eligibility Measure Applicability (EMA) process to determine if the clinician or group could have submitted additional clinically relevant quality measures. The EMA process is also used to adjust scoring to reflect the number of clinically relevant measures.

The EMA process applies to:

  • Small practices that submit MIPS quality measures through Medicare Part B claims; and
  • Any MIPS clinician working with a third-party intermediary to collect and submit MIPS Clinical Quality Measures (CQMs)

The EMA process has two steps:

  • Step 1: CMS determines whether there are additional measures that are clinically related to the quality measures the clinician did submit. CMS also determines whether there were any clinically relevant outcome or high priority measures that could have been reported. Keep in mind that if you submit the full specialty measure set, EMA won’t apply to you.
  • Step 2: CMS determines whether the clinician met the minimum threshold test by verifying that at least 20 denominator-eligible cases exist for identified measures.

If CMS finds that a clinician or group submitted all of the clinically relevant quality measures possible, the clinician can receive full points in the Quality performance category. If CMS does identify additional relevant quality measures, but there were fewer than 20 eligible cases for that measure, the clinician can still receive full points in the Quality performance category. However, if CMS does find additional measures that could have been reported that meet the minimum case threshold, the clinician will receive zero measure achievement points for each missing measure.

If you are reporting MIPS measures via claims or Qualified Registry (QR) and cannot find six relevant measures to report, your first step should be to find your CMS Specialty Measure Set in the Explore Measures & Activities tool on the QPP website to verify which measures CMS considers clinically relevant for your specialty. You can also use the Single Source file found in the measure specifications and supporting documents zip file for your submission method (see links below). Single Source files enable you to enter your common billing codes and find relevant MIPS measures to report:

If you would like personalized assistance, we recommend reaching out to your regional Technical Assistance (TA) Contractor for assistance. You can also check out the CMS EMA Process Resources, as well as QSource’s helpful guide to the EMA Process.

[1] MIPS scoring policies emphasize and focus on high priority measures that impact beneficiaries. High-priority measures are not an additional measure type, but fall within these measure categories: Outcome (includes intermediateoutcome and patient-reported); appropriate use; patient engagement/experience;  patient safety;  efficiency measures;  care coordination; and opioid-related


Author: IMPAQ International with funds from a contract with the Centers for Medicare and Medicaid Services: TORP-RMADA-2017-0004, “Quality Payment Program Small Underserved and Rural Support (QPP SURS) Central Support." 

Tags: Quality Services

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