The future of EHR certification and electronic clinical quality measures have much to gain the experiences of hospitals with EHR use and quality reporting over the past several years.
That is the message from the American Hospital Association to the Centers for Medicare & Medicaid Services in response to a request for information on EHR certification frequency and quality reporting programs at CMS.
The problem lies in hospitals remaining unable to see how their work with certified EHR technology and quality reporting have helped guide the federal agency’s decision-making over the years.
“Since 2013, CMS has launched demonstrations and pilots to encourage electronic submission of eCQMs,” writesAHA Senior Vice President Ashley Thompson. “The 2013 Medicare EHR Incentive Program Electronic Reporting Pilot data was expected to inform the development and testing of the eCQM data collection process, as well as monitoring process. Lessons learned from this two-year pilot were anticipated to inform the development of eCQM policy. In 2015, CMS launched an eCQM validation pilot.”
“To date, CMS has not shared insights from these efforts,” she continues. “We do not know the number and characteristics of the hospitals participating in the pilots and demonstrations, the number and variety of certified EHRs represented in each pilot or demonstration, and the number of successful or failed submissions. Additionally, the criteria used to define success and failure also are unclear.”
The association is seeking access to CMS data from these previous eCQM demonstrations and pilots prior to the publishing of future regulation.
Another activity found lacking by AHA is provider education about EHR certification and quality reporting by CMS and the Office of the National Coordinator for Health Information Technology (ONC).
“A collaborative learning environment that offers layers of educational content on the quality measures, the technology supporting data capture, calculation and reporting, and the submission methods will benefit CMS, providers and vendors in efforts to improve the entire eCQM process,” states the letter to CMS Acting Administrator Andy Slavitt.
In light of recent claims that meaningful use is entering a transitional phase, AHA is asking CMS to address future electronic quality reporting during the transition from fee-for-service to value-based reimbursement.
“Beginning in 2019, physician requirements under the Medicare EHR Incentive Program will be folded into the new Merit-based Incentive Payment System (MIPS) and alternative payment models (APMs),” Thompson explains. “In our response to a request for information on how to implement these new physician payment models, we urged CMS to adopt a system that measures providers fairly, minimizes unnecessary data collection and reporting burden, focuses on important quality issues and promotes collaboration across the silos of the health care delivery system.”
At minimum, AHA is pursuing alignment across the various electronic quality reporting programs under CMS’s watch. (Perhaps reporting burnout is a thing as well.)
As for the specifics of the RFI, AHA envisions recertification of certified health IT when new versions of eCQM specifications become available. “The certified health IT vendor timeline to revise their software to support eCQM specification updates is different than the hospital timeline to implement the new eCQM specification and new software,” the letter states.
According to the association, hospitals are reporting a 24-month timeline for implementing new quality reporting measures.
AHA also contends that certified EHR technology be able to support electronic quality reporting considering that some do not.
“The current mismatch in vendor and provider requirements results in providers identifying the eCQMs that their certified EHR supports and then confirming the availability of the data required to meet the measure reporting requirements, rather than selecting measures that reflect their patient populations and the areas they have prioritized for quality improvement,” writes Thompson.
Lastly, AHA is requesting that CMS allow for more testing of eCQMs and that eCQM testing adheres to reporting requirements set by CMS.
AHA echoes the input of the American Medical Informatics Associations heard last week.
