There seems to be a consensus among CIOs that the clinical quality measures are potentially the most important aspect of meaningful use, but they have also been by far the biggest challenge in Stage 1. McColm calls the measures “premature, non-standard and un-owned.” She says the measures do not appear to have been piloted or field-tested and don’t include any guidance for implementation. “Some of the clinical quality measures are half-baked and there is no one to ask about them, no stewards,” she adds. The Joint Commission should be the owner, she suggests. “I think CMS should have waited a year to do clinical quality measures. They would have been better off if they had identified stewards.”
Thomas Smith, CIO at NorthShore University HealthSystem in Evanston, Ill., agrees with McColm about the need to improve the clinical quality measures. “I talked to our quality staff, and they felt the meaningful use definitions were not well thought out,” he says. “ONC needs to work with other agencies. CMS has whole divisions that have spent years working on this.”
Although four-hospital NorthShore attested to meaningful use for both its hospitals and physicians on day one, Smith has stressed to policymakers that the program requires too much reporting. He estimates that approximately 70 percent of the 36,000 employee hours spent on Stage 1 has been on reporting and not on quality improvement. “Seventy percent of the effort shouldn’t be on reporting.
They require us to use a certified EHR that passes certain minimum requirements and that makes sense,” he says. But EHRs in general are not designed to do mass reporting, he notes. CMS could have made some sort of exception for data warehouses to do the number crunching. “We could use the EHR for collecting and using the data but then use a calculating machine that is 10 times stronger. Instead, some of these monthly reports take 12 days to run and we have people here on weekends.”
That data warehouse certification issue is an example of something that should be relatively easy for ONC to go back and revisit, says Kevin Burchill, a director at Beacon Partners, a consulting firm in Weymouth, Mass. “Hopefully, as in Stage 1, what comes out after the public comment period will be better for it and will reflect these types of concerns.”
Another common refrain from CIOs is that CMS has to do a better job of harmonizing all the quality-reporting programs it has in place, including meaningful use, those related to the medical home and to the accountable care organizations program, and Medicare’s Physician Quality Reporting Initiative (PQRI), as well as the requirements coming out of the Washington, D.C.-based National Committee for Quality Assurance (NCQA), and other programs. Each program has its own specific goals, Smith says. “On the surface they may look exactly the same, but when you get into it, what gets included and excluded in the measures is slightly different, so it is a difficult thing for IT to write reports for each. It might be smart to have some sort of CMS portal where we submit all this quality reporting data,” he adds, “and they sort it out on their end.”
Hospitals that are implementing new systems or switching vendors in 2012 to meet meaningful use are doubly challenged, says Burchill. The provider organizations get in queues with vendors, but then have to line up both internal and consulting resources when planning implementation. “So there are capital planning and operating expense considerations, and matching those up is an art,” he adds.
Curt Kwak would agree. The CIO for Providence Health’s Western Washington region, which encompasses three hospitals and a service area that includes 65 Providence-owned clinics, is in the midst of switching EHR vendors. “It will be a challenge to get to Stage 1 next year,” he admits, “but we plan to get through Stage 2 by the end of 2013. We have a team dedicated to meaningful use and have developed a tool to track our progress on all fronts. We also have an informatics office to help define workflow requirements.”

Curt Kwak
Stage 2: 'Aggressive and Ambitious’
Even though providers that attested to meaningful use in 2011 are expected to have until 2014 to phase in Stage 2, they will still be kept busy, because many of the new measures are ambitious. First, all Stage 1 menu measures would become core measures, and would be required of all providers. Medication orders must be automatically tracked via electronic medication administration record (eMAR) in at least one hospital unit. (That requirement has huge patient safety improvement implications, but is an implementation challenge to introduce, McColm notes.) Hospital labs must provide structured electronic lab results to outpatient providers for more than 40 percent of electronic orders received.
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