The American Hospital Association called for a revised process for electronic specifications for clinical quality measures in the electronic health record incentive program in a letter sent Tuesday, addressed to acting Centers for Medicare & Medicaid Services Administrator Marilyn Tavenner and National Coordinator for Health IT Farzad Mostashari.
AHA Executive Vice President Rick Pollack referred to the overall regulatory process as "rushed," citing that the EHR certification process for Stage 1 only calls upon vendors to verify that their products can "electronically produce numerators, denominators and exclusions in the required standardized format."
"The certification process for EHRs does not include testing the accuracy of the embedded measure calculations, nor does it look to see if the needed data are, in fact, available in the EHR," Pollack said. "ONC and CMS are to be commended for including infrastructure improvements in the Stage 2 final rule … however, the process for including CQMs in the EHR remains problematic."
Pollack published the following timeline of events outlining the process leading up to the final publication of updated electronic specifications for CQMs:
- 9-4-2012: Stage 2 Meaningful Use rule published, including CQMs reported starting in 2014
- 10-24-2012: Final CQM electronic specifications published
- 11-2-2012: Draft test procedures for the 2014 Edition EHR certification criteria released
- 12-7-2012: Interim final rule announcing changes to electronic specifications published
- 12-14-2012: Final test procedures for the 2014 Edition EHR certification criteria released
- 12-21-2012: Updated electronic specifications for CQMs published
Pollack said the AHA wants to see a revised timeline for the regulations that allows "electronic specification vetting, testing and evaluation of test results prior to their inclusion in final rulemaking," adding that hospitals are pouring "considerable financial and human capital" investments into the implementation of EHRs.
"[They] need certainty that the technology supports the development of valid, reliable and feasible automated measurement," Pollack said.
In September, Linda Fishman, VP of public policy analysis and development with the AHA, sent a letter to Agency for Healthcare Research and Quality director Carolyn Clancy regarding the use of IT for healthcare quality measurement. In that letter, a response to a request for information by the AHRQ from July, Fishman said that EHR stakeholders had "little reason to trust the data integrity" of CQMs from certified EHRs.
"[W]e encourage AHRQ to work with all stakeholders to ensure that automated measures are valid, reliable and feasible to collect," Fishman said. "If automated quality measurement is to become widely used, it is more important to get a small number of measures right before moving on to more measures or moving too quickly."
In this week's letter, Pollack said that AHA supported the revisions to the Stage 2 final rule for adopting a minimum case number threshold exemption for quality measures reporting for eligible hospitals and critical access hospitals.
To learn more:
- read the letter (.pdf)