Provider Organizations Call on CMS to Reconsider Expanded Quality Reporting Requirements

June 20, 2016
A number of healthcare provider organizations are calling on the Center for Medicare & Medicaid Services (CMS) to reconsider requiring hospitals to submit 15 electronic clinical quality measures (eCQM) in 2017.

A number of healthcare provider organizations are calling on the Center for Medicare & Medicaid Services (CMS) to reconsider requiring hospitals to submit 15 electronic clinical quality measures (eCQM) in 2017.

As previously reported by Healthcare Informatics, CMS released the proposed Medicare Inpatient Prospective Payment System rule in April, and in the rule, CMS proposed mandatory full-year electronic clinical quality measures (eCQM) reporting in 2017. CMS has proposed to mandate the electronic reporting of 15 clinical quality measures for 365 days using electronic health records (EHRs) in 2017. The proposed rule suggests eliminating 13 of the 28 eCQM from the hospital Inpatient Quality Reporting (IQR) program and the Meaningful Use program.

Several healthcare provider organizations submitted comments specifically highlighting their concerns about the proposal to make reporting of all 15 available eCQMs required, rather than voluntary, in 2017. Most the provider organizations recommend CMS continue to use 2016 reporting requirements for the (IQR) program, which requires eligible hospitals to report on four of the 15 available measures as a baseline to avoid the IQR payment adjustment.

The Healthcare Information and Management System Society (HIMSS) wrote in its comments, “Despite the seeming simplicity proposed in the reduction from 29 to 15 eCQMs proposed by CMS, the eight month window between publication of the proposed rule and the January 1, 2017 start date of the performance period will not allow EHs, vendors and providers the appropriate implementation timelines necessary for systems to be updated, nor the appropriate care delivery workflows to be developed and incorporated for the purpose of accurate data capture for eCQMs that were not part of purchased CEHRT systems. Therefore, HIMSS asserts this requirement places an unfair burden on EHs and clinicians. Through no fault of their own, EHs and clinicians have targeted 2018 for mandatory electronic reporting of all measures; today, they do not have systems in which all 15 eCQMs certified.”

The American Hospital Administration (AHA) wrote in its comments, “While the AHA strongly supports the long-term goal of using EHRs to streamline and reduce the burden of quality reporting, we are concerned that there remain far too many questions about eCQM feasibility and accuracy for CMS to mandate an expanded reporting requirement in the IQR.”

In addition, AHA wrote that it recommends that CMS wait to expand eCQM reporting until it can analyze findings and experiences with 2016 reporting. “The AHA is troubled by CMS’s proposal, as it would increase the amount of data electronically submitted without the benefit of lessons learned from the first year of the electronic submission requirement. We also are concerned that the proposal is not realistic given the timeline for CY 2016 reporting, the eCQM update experience to date and the competing activities in 2017.”

And the Federation of American Hospitals (FAH) wrote in its comments, “The FAH supports the proposal to align the requirements for reporting of electronic measures in the IQR Program with the EHR Incentive Program. However, based on our member hospitals’ experience to date with reporting eCQMs, we believe that the proposal to require reporting of 15 eCQMs for purposes of both the IQR Program and the EHR Incentive Program in 2017 is overly ambitious.”

And, the FAH stated, “For 2016, hospitals must report four eCQMs and given the ongoing technical issues with vendor and CMS systems, we do not believe that it is feasible to require all participating hospitals to report 15 measures at this point. Problems with CMS’ technical ability to receive the measure data have led CMS to significantly delay reporting deadlines.”

The FAH recommends that for 2017 hospitals be required to report at least six electronic measures, “with the option of reporting all 15 measures.” “This will allow CMS and vendors more time to work out technical issues,” the organization stated.

The College of Healthcare Information Management Executives (CHIME) also responded, stating in its comments, “We appreciate CMS’ recognition that further harmonization of measures across hospital quality reporting programs is needed. We generally support the efforts the agency has taken to align Hospital Inpatient Quality Reporting (IQR) requirements and Medicare EHR Incentive Program quality measure reporting. However, we remain concerned that CMS significantly underestimates the complexity of generating valid, reliable and accurate eCQMs without human intervention.”

As noted in this week’s CHIME Washington Debrief, CHIME is calling on CMS to “maintain voluntary electronic submission until both providers and policymakers agree on the maturity of eCQM specifications,” and continue the policy of four eCQMs for 2017.

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