In February, the Centers for Medicare & Medicaid (CMS) asked stakeholders for input regarding ways it might better align clinical quality measure reporting under the Physician Quality Reporting System (PQRS), the Electronic Health Record (EHR) Incentive Program and other reporting programs. The deadline to respond was April 8, and the American Hospital Association and several specialty societies made suggestions of changes CMS could make.
The AHA’s letter notes that it believes that the federal quality measure endorsement process must be followed for measures reported to federal programs, including any measures reported via EHRs or registries. Measures that are not National Quality Forum-endorsed or Measure Applications Partnership-recommended should be removed from any federal health program, AHA said. Electronic-specified measures should be separately reviewed and endorsed, it added.
AHA claims that the experience in Stage 1 of the EHR Incentive Program indicates that the current approach to automated quality reporting leaves a lot to be desired. “Providers and vendors have encountered significant issues with the electronic specifications, which contain known errors and were never field tested. For example, the existing electronic CQMs require a level of clinical documentation and the use of coded data fields that are far more extensive than the meaningful use Stage 1 requirements will produce.”
The AHA added that the certification process for EHRs specifically does not include testing the accuracy of the embedded measure calculations, nor does it examine if the needed data are, in fact, available in the EHR.
The American Society of Hematology’s letter recommends that CMS be flexible with respect to the types of measures, including outcome and process measures. “Any system that only bases payment on the outcome of care rendered needs to recognize the wide difference in the nature of the disease processes treated by various specialties, which will of course affect patient outcomes, including morbidity, mortality and complication rates.” ASH recommends that CMS ensure a transition of at least five years to allow for stable and predictable reporting.
The American Association of Neurological Surgeons (AANS) wrote that it envisionsa situation in which specialty societies, working within broad guidelines established by CMS for quality improvement activities, would develop specialty-specific parameters for acceptable quality improvement projects that could ultimately be used across public and private sector programs, including PQRS and EHR as well as those established by third-party payers.
“CMS should establish a process so physicians are able to meet data reporting requirements under Medicare’s quality improvement programs through their participation in “deemed” quality reporting and measurement activities,” AANS wrote. Under this concept, CMS would “deem” participation in clinical data registries or other quality improvement programs such as regional quality collaboratives or enhanced maintenance of certification, as meeting CMS’ quality data collection and reporting requirements.
The neurosurgery group believes that CMS can, and should, play a greater role in facilitating the use of clinical data registries by encouraging the development of standards for sharing data between EHRs and registries. “Presently, practices are forced to manually enter data into a registry because no streamlined process exists, and because of the proprietary nature of health information technology products.”
Now it is up to CMS to respond to the feedback as it seeks to push the envelope on increased quality reporting that health information technology makes possible while making sure it is not swamping providers with too many bureaucratic reporting requirements.