D.C. Report: Mostashari Endorses Stage 2 Delay, Quality Measure Reporting Pilot, e-Prescribing Under Fire

Stage 2 Delay Gets Mostashari Endorsement; Regulatory Process Remains
The Health IT Policy Committee (HITPC) held its 25th meeting this week in Washington. And while the Office of the national Coordinator (ONC) head Dr. Farzad Mostashari could not formally respond to all of HITPC’s recommendations, he agreed with the conclusion that Stage 2 Meaningful Use should be delayed one year for those attesting in 2011. “The last thing we want to do is provide disincentives for [eligible hospitals and eligible providers] to attest in 2011,” he said. He indicated that not accepting the recommended delay could negatively impact participation rates and that the extra time would help providers and vendors develop more robust systems. Dr. Mostashari also indicated that he wanted to maintain “the escalator” by making sure Stage 2 requirements were robust and vigorous enough to push early recipients of incentive payments. Despite Mostashari’s endorsement, the Centers for Medicare and Medicaid Serv ices (CMS) will have ultimate say through the normal regulatory process, scheduled to kick off with an NPRM towards the end of 2011 or early 2012.

Also reviewed during this month’s meeting was a presentation of issues (.pdf) being discussed by the ONC’s sister FACA, the Health IT Standards Committee (HITSC). HITSC is identifying key transport, content and vocabulary issues related to the HITPC’s Meaningful Use Stage 2 recommendations, as well as looking at more targeted issues such as metadata, patient matching and electronic lab reporting.

CMS Proposes Quality Measure Reporting Pilot for EHR Incentive Payments
According to a proposed rule released Friday by CMS, eligible hospitals and critical access hospitals would have another path towards meeting Meaningful Use requirements for clinical quality measures (CQMs) in payment year 2012. Under terms set for the Medicare EHR [Electronic Health Record] Incentive Program, eligible hospitals (EHs) or critical access hospitals (CAHs) can report CQM results as calculated by certified EHR technology through attestation, rather than submit the information electronically in 2011. For payment years 2012 and beyond, EHs and CAHs would have to submit CQMs electronically based on Physician Quality Reporting Initiative (PQRI) 2009 Registry XML, according to the final rule established by CMS. But last Friday, CMS said this technical approach was, a “not feasible” standard to use, and as a result, they have proposed to allow EHs and CAHs to continue reporting CQM results by attestation for future payment years.

Alternatively, the proposed rule sets terms for an Electronic Reporting Pilot that would allow eligible hospitals and CAHs to meet CQM requirements for Incentive Payments. The pilot parameters require EHs and CAHs to:
• Submit CQM data on Medicare patients only;
• Submit Medicare patient-level data from which CMS may calculate CQM results using a uniform calculation process, rather than aggregate results calculated by the EH or CAH’s certified EHR technology;
• Submit one full federal fiscal year of CQM data, regardless of the eligible hospital or CAH’s year of participation in the Medicare and Medicaid EHR Incentive Programs; and
• Use electronic specifications for transmission as specified by CMS, which we expect would be Level 1 Quality Reporting Document Architecture (QRDA).

CMS says they “would encourage participation in the proposed Electronic Reporting Pilot in view of our desire to adequately pilot electronic submission of CQMs and to move to a system of reporting where eligible hospitals and CAHs can qualify for CQM reporting for both the Hospital Inpatient Quality reporting (IQR) and Hospital Outpatient Quality Reporting (OQR) Programs, and the EHR Incentive Program.”

e-Prescribing Goes Under the Microscope
This summer has been tough for advocates of e-prescribing. Earlier last month, Rep. Renee Ellmers (R-N.C.) introduced the Stripping the E-Prescribe Arbitrary Mandates (STEAM) Act of 2011 .The STEAM Act would (1) repeal administrative penalties (payment adjustments) for eligible professionals who are not successful electronic prescribers, (2) remove e-prescribing as an element for demonstrating meaningful use of certified EHR technology, and (3) exclude e-prescribing from shared savings program reporting requirements. So far, the bill only has one co-sponsor and has been referred to the Energy and Commerce Subcommittee on Health.

In related news, the Journal of the American Medical Informatics Association ( JAMA) published a study finding that “About one in 10 computer-generated prescriptions included at least one error, of which a third had potential for harm,” and that “This is consistent with the literature on manual handwritten prescription error rates.” Media outlets instantly seized the report asking, “If you think electronic prescribing will solve the mistakes that occur when doctors hand-write prescriptions, think again.” But upon further review of the JAMIA report, one encounters a few important observations. Namely, that the analysis was conducted in 2008 (pre-Meaningful Use) and over 75 percent of the errors were due to “Omitted” or “Unclear” information. This should be interpreted as “user error” and it should be noted that part of Meaningful Use and the eRx Incentive program requires a force function that would not allow incomplete ‘scripts to be transmitted. The report went as far as to echo this by saying, “financial incentives will likely improve adoption of advanced electronic prescribing systems with forcing functions, which can be expected to result in better error-reduction rates.” However, it must also be said this report set an important benchmark, by which Meaningful Use can be measured in the coming months and years.