The comment period for the proposed inpatient prospective payment system (IPPS) rule for 2017 ended last week, and while many of the 1,419 comments received are not posted as of this writing, a number of major stakeholders have weighed in on the Centers for Medicare & Medicaid's ideas to change the electronic clinical quality measure (eCQM) reporting obligations.
The rule, issued April 27, proposes to require electronic reporting of 15 CQMs for a full year in 2017. Currently, hospitals report on four eCQMs for just a quarter. The rule would also winnow out 13 eCQMs from the inpatient quality reporting (IQR) and Meaningful Use programs.
Comments that I’ve seen so far have been relatively similar:
- Stakeholders appreciate the softening of some of the measurements.
- However, the proposed requirements are still too much for providers to handle.
- Certified EHR technology is not yet capable of meeting the proposed requirements, so providers aren’t going to be able to comply.
- The reporting requirement should be only 90 days, not 365.
- The rule has been released so late that there isn’t enough time to ramp up and comply with the new obligations by the start date.
- The rule is forging ahead to meet data collection desires without really improving patient care.
- This next stage of requirements should be delayed as a result.
Sound familiar? If one didn’t know that these comments pertained to the eCQMs in the IPPS, you’d swear you were reading comments about the Meaningful Use program.
Let’s look:
- Stakeholders appreciate the softening of the hardship requirements and measurements of Meaningful Use (they appreciate the reduction of eCQMs).
- However, EHRs aren’t able to meet interoperability requirements of Meaningful Use (they aren’t able to meet the eCQM reporting requirements in the proposed rule, since they’re only designed to report four of them, not 15).
- Providers aren’t prepared to report Meaningful Use objectives for 365 days (they’re not prepared to report eCQMs for 365 days).
- Providers only had a few months to prepare for the increased Meaningful Use obligations; (providers have only a few months to prepare for the increased eCQM reporting obligations).
- The Meaningful Use objectives don’t necessarily improve patient care; (the eCQMs don’t necessarily improve patient care).
- Meaningful Use should be delayed; (these eCQMs should be delayed).
To quote one of my favorite songs, "same trailer, different park."
Why are we on this merry-go-round? Didn’t the Meaningful Use program’s missteps teach the government anything? The stakeholders have some pretty valid points. If certified EHR technology can’t yet report 15 eCQMs, and vendors and providers have only months to reconfigure, test and implement the changes, doesn’t that set the providers up for failure, with the ensuing “payment adjustments?"
And wasn’t it problems like this that caused pressure on CMS to soften the Meaningful Use rules not once but several times? And for Congress to weigh in more than once, even now calling for the program to be softened further?
CMS itself acknowledge that hospitals still struggle to use their EHRs to accurately report eCQMs in a recent report. It found that eCQM data was incomplete and inaccurate because EHR processing procedures were not yet mature enough to handle the reporting. For some measures being compared, the match rate was a dismal 12 percent; the best match rate wasn’t even 50 percent. CMS noted that it would provide more outreach and education, and that it has modified the specifications of two measures. That doesn’t sound like enough to help providers meet the mandates in the proposed rule.
The proposed eCQM requirements are part of the transition from Meaningful Use reporting to eCQM reporting. But there’s no need to make the same mistakes that were made before.
We need to get off this merry-go-round. Otherwise, we’re going nowhere. - Marla (@MarlaHirsch and @FierceHealthIT)