"Comment: Some commenters requested that CMS clarify the proposal to eliminate the need to track and report duplicative quality measures by modifying its proposal to require that if quality is reported in a manner acceptable under MIPS or an APM, it would not need to be reported under the Medicaid EHR Incentive Program. The commenters were concerned the programs could potentially cause the same conflict CMS specifically noted MIPS and APMs were intended to correct.
CMS Response: We thank the commenters and have worked to eliminate duplicative measures between MIPS and other programs where possible. We intend to continue to align MIPS and the Medicaid EHR Incentive Program to the greatest extent possible. As we have noted in section II.E.5.g. of this final rule with comment period, the requirements for the Medicaid EHR Incentive Program for EPs were not impacted by the MACRA. There is a requirement to submit CQMs to the state as part of a successful attestation for the Medicaid EHR Incentive Program. While the MIPS objectives for the advancing care information (now called Promoting Interoperabilty) performance category are aligned to some extent with the Stage 3 objectives in the Medicaid EHR Incentive Program, they are two distinct programs, and reporting will stay separate.