CHIME Submits Comments on Meaningful Use Comments filed with both the Centers for Medicare & Medicaid Services (CMS) and Office of the National Coordinator for Health IT (ONC) identified concerns related to the proposed Stage 2 EHR reporting period as well as CMS’ varying approach to clinical quality measures (CQMs). CHIME also made recommendations on all 42 proposed objectives for Eligible Professionals, Eligible Hospitals and Critical Access Hospitals.
CHIME recommended that CMS allow EPs, EHs and CAHs to demonstrate Meaningful Use during a continuous 90-day EHR reporting period for their first payment year in Stage 2, mimicking the approach used in Stage 1. “To allow adequate time for application development, provider adoption and testing, CMS should follow the precedent set in Stage 1,” CHIME said. “And similar to Stage 1, the EHR reporting period would be any continuous 90-day period within the first payment year of Stage 2 and a 365-day reporting period for all subsequent payment years within Stage 2.”
In both letters, to CMS and ONC, CHIME commented on the challenges involved with clinical quality measures. “The accurate reporting of quality measures is one of the most daunting challenges faced by providers today,” CHIME said. “Through our experiences with Stage 1, we found that although EHR products were able to automatically produce CQM reports, the data was inaccurate and largely incomparable across different providers.” As part of Base EHR certification, CHIME urged ONC to require certification of EHR products to all CQMs needed to meet Meaningful Use in each setting. CHIME wrote that “certification should include all CQMs for associated settings. And in order to minimize the costs of development and implementation, we recommend that ONC work with CMS to limit the total number of CQMs associated with each setting.”
CHIME’s comments to CMS can be found here.
For CHIME’s letter to ONC, visit here.
Senators Shine Anti-fraud Spotlight on CMS Despite a fairly constant flurry of news clippings regarding federal efforts to combat fraud in Medicare and Medicaid, prominent Senators want more “tangible results” from CMS to improve program integrity. In an “open letter to stakeholders” Senate Finance Committee Chairman Max Baucus (D-MT), ranking member Orrin Hatch (R-UT) and Sens. Tom Coburn (R-OK), Charles Grassley (R-IA), Ron Wyden (D-OR) and Tom Carper (D-DE) ask for white papers in three categories:
· Program integrity reforms to protect beneficiaries and prevent fraud and abuse;
· Payment integrity reforms to ensure accuracy, efficiency and value; and
· Fraud and abuse enforcement reforms to ensure tougher penalties against those who commit fraud
“Today we are announcing an effort to solicit ideas from all interested stakeholders in the health care community, regarding solutions and suggestions for how to better prevent and combat the multibillion dollar problem of waste, fraud and abuse in the Medicare and Medicaid programs,” the letter said.
For its part, the Obama administration says it’s hauling in record amounts of recovered fraud and sending record amounts of perpetrators to jail for fraud related to Medicare and Medicaid.
MU Trends for CQMs, Exclusions Highlighted in Auditor’s Report A report issued this week by the Government Accountability Office (GAO) said that CMS could do more to assess and mitigate the risk of improper payments and to improve program efficiency. To this effect, the GAO recommended that CMS should:
· Establish time frames for expeditiously implementing an evaluation of the effectiveness of the agency’s audit strategy for the Medicare EHR program.
· Evaluate the extent to which the agency should conduct more verifications on a prepayment basis when determining whether providers meet Medicare EHR program’s reporting requirements.
· Collect the additional information from Medicare providers during attestation that CMS suggested states collect from Medicaid providers during attestation.
· Offer states the option of having CMS collect meaningful use attestations from Medicaid providers on their behalf.
HHS officials disagreed with the fourth recommendation, believing instead, a more “compelling challenge” would be “designing a way for providers to report clinical quality measures electronically from their EHRs to the states and CMS.” HHS said that CMS was working through pilots that are intended to help providers leverage existing infrastructure to electronically exchange data on clinical quality measures directly from their EHRs to CMS.
The GAO report also highlighted interesting trends based on the number and type of exemptions claimed, finding that
· 72.4 percent of professionals and 79.6 percent of hospitals claimed exemptions from reporting at least one mandatory Meaningful Use measure.
· The measure to provide patients with an electronic copy of their health information, was the least frequently reported measure with an exemption (providers can claim an exemption on this measure if no patients request a copy of their health information).
· The recording of smoking status was the most frequently report measure for which there is an exemption.
In addition to exemptions, GAO found that 41.3 percent of professionals and 86.9 percent of hospitals reported at least one clinical quality measure based on seven or fewer patients.
Journal Article Refutes Reasons for ICD-10 Delay An article published on the Journal of AHIMA website refutes several claims made by prominent figures on the Health IT Standards Committee in a recent Health Affairs’ article on ICD-10. As reported in the Advocacy Corner in March, five health standards guru’s argued for a delay in implementing ICD-10 because “the ICD-10-CM conversion is expensive, arduous, disruptive and of limited direct clinical benefit.” The Journal of AHIMA article counters many of the claims made in the Health Affairs article on issues related to cost-benefit; delay impact; development and maintenance of ICD-10-CM Diagnosis Codes; benefits of more detailed procedure and clinical data; and they claim that waiting for ICD-11 is simply not a serious option. “The earliest the U.S. could move to ICD-11 would be 2025, or 13 years from now,” the article says, and the authors go on to claim that more integration with SNOMED or other touted benefits of ICD-11 are speculation at this point. Despite the numerous counterpoints made in the Journal of AHMIA article, refuting why a delay of ICD-10 will prove more harmful than beneficial, the authors acknowledge political reality. In response to a recent notice of proposed rulemaking, the article concludes with, “Although no delay is preferred, the proposed one-year delay strikes a reasonable balance between providing sufficient time for small providers and small hospitals to become compliant, minimizing the financial burden on entities that have been actively planning and working toward being compliant.”