On Feb.1, the American Hospital Association (AHA) sent a letter to the Centers for Medicare & Medicaid Services (CMS) stating that electronic health record (EHR) systems are not yet capable of meeting the requirements of the Hospital Inpatient Quality Reporting (IQR) program.
Congress established the EHR Incentive Programs in the 2009 American Recovery and Reinvestment Act to provide needed funds to accelerate the widespread adoption and use of EHRs to improve health and health care. Hospitals have demonstrated their commitment to successful participation in multiple Medicare payment and quality reporting programs that require reporting on nearly 90 quality measures.
In the letter, Linda Fishman, AHA senior vice president of public policy and development, wrote that AHA "strongly supports" the goal of using EHR systems for quality reporting. However, she added, "hospitals will not be ready to routinely report clinical quality measures through EHRs until measure developers and vendors build electronic specifications and EHRs that support efficient generation of accurate and reliable quality data."
In CMS’s hospital inpatient prospective payment system (PPS) proposed rule for fiscal year 2013, the agency sought feedback on two options for transitioning data collection to automated reporting from EHRs. One option would be to select a date after which chart-abstracted data would no longer be used in the hospital IQR program if it is possible to report the data via certified EHR technology. The other option would allow hospitals to submit the same measure for the hospital IQR program based on either chart abstraction or, when available, EHR-based reporting. In its June 2012 comment letter, the AHA urged CMS to allow the second option of reporting given that individual EHRs or hospitals may not be ready to report IQR measures electronically by a date certain.
In this letter, AHA details why it still believes the second option remains more realistic and viable as EHRs are not yet capable of routinely supporting reporting requirements under the hospital IQR program. Its reasons include:
- Experience in Stage 1 meaningful use indicates hospitals have been unable to generate useable clinical quality data out of the certified EHRs.
- Additional work on electronic specifications is needed before EHRs can support hospital IQR.
- EHRs are not yet supporting a broad group of clinical quality measures (CQMs) endorsed by the National Quality Forum (NQF).
- Variation in electronic measure specification must be constrained when included in quality reporting and payment programs.
- Tools supporting successful EHR reporting must be reviewed and tested prior to increasing the use of EHRs in quality measure reporting.
- CMS first should report the results of the EHR Incentive Program Electronic Reporting pilot program.
- The use of EHRs for quality reporting currently results in additional reporting burden compared to manual abstraction.
- The AHA believes the value of quality measurement and reporting requirements should be balanced with recognizing the significant burden the requirements place on hospitals and other providers.
The AHA recommends that CMS enhances outreach and collaboration opportunities for measure developers, vendors and providers early in the electronic specification for CQM process so that challenges can be identified by providers who are expected to report the measures and vendors who are expected to support accurate reporting. Fishman wrote that it is clear that considerable work needs to be done by measure stewards, developers and all health care stakeholders to make electronic CQMs valid and reliable.
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