By making hospital quality of care information public, the Hospital Inpatient Quality Reporting (IQR) program is designed to help patients make informed decisions and encourage hospitals and physicians to improve the quality of inpatient care.  Under the Hospital IQR program, hospitals submit clinical quality data to the Centers for Medicare and Medicaid Services (CMS) and CMS makes the information available to consumer Hospital Compare website.  Hospitals that fail to report quality data face a reduction in their Medicare Part A payments.

Today, most of the data are manually abstracted from patient medical charts.  CMS is interested in knowing whether hospitals are ready, starting in CY 2014, to use data from electronic health record (EHR) systems to report data on clinical quality measures that are currently manually chart-abstracted.  Beginning in 2014, all providers, regardless of whether they are in Stage 1 or Stage 2 of meaningful use of a EHR system, will be required to report on the 2014 CQMs finalized in the Stage  2 rule.

This is a great opportunity to improve data quality, reduce reporting burden on hospitals, speed the process for public reporting, facilitate the use of new quality measures, and encourage the adoption and use of electronic health records. Specifically, for all the various quality reporting programs, CMS has five objectives for aligning quality measurement and reporting:

  1. Streamline our quality reporting programs through automatic collection and reporting of data on clinical quality measures (CQMs) using certified electronic health record technology (CEHRT).
  2. Reduce burden to hospitals by allowing them to use EHRs to submit data on CQMs that are adopted for both the Hospital IQR Program and the EHR Incentive Program.
  3. Develop a single set of electronic specifications for CQMs adopted under multiple quality reporting programs.
  4. Support quality care improvement.
  5. Adopt data standards to facilitate hospitals’ capturing, transmitting, and formatting data elements consistently and clearly.

To this end, CMS is soliciting advice and information from hospitals and EHR system vendors.  CMS questions for hospitals, EHR vendors, and other interested stakeholders include:

  • How do hospitals and vendors perceive the alignment of EHR-based reporting and hospital quality reporting programs? What are the foreseen benefits and challenges?
  • Do hospitals and vendors envision being able to meet the criteria for reporting clinical quality measures electronically for the EHR Incentive Program as set forth in the EHR Incentive Program – Stage 2 final rule (77 FR. 53968) and any related guidance issued? If not, what are the issues in meeting the requirements and what additional information is needed?
  • Is the hospital planning to adopt EHR technology that has been certified to the 2014 Edition EHR certification criteria during or before calendar year (CY) 2014?
  • Is the hospital aware of the payment adjustments authorized under the HITECH Act beginning in FY 2015 for failing to demonstrate meaningful use under the Medicare EHR Incentive Program?
  • Is the hospital planning to electronically report CQM data – specifically venous thromboembolism (VTE) and stroke (STK) and emergency department (ED) measures – under the Medicare EHR Incentive Program in FY 2014?
  • Is the hospital already participating in or planning to participate in the 2013 Medicare EHR Incentive Program Electronic Reporting Pilot for Eligible Hospitals and Critical Access Hospitals (CAHs)? The pilot provides eligible hospitals and CAHs with an opportunity to meet the CQM reporting requirements of the Medicare EHR Incentive Program through electronic submission of CQM data. The pilot is a voluntary electronic reporting method used to satisfy the CQM reporting requirements for the Medicare EHR Incentive Program. If not, what barriers prevent the hospital from participating?
  • Does the hospital plan to report data leveraging any state health information exchange (HIE) initiative?
  • Does the hospital plan to report data leveraging the Nationwide Health Information Network (NwHIN) Exchange, which is now the eHealth Exchange?
  • Will the hospital use a third party to report quality data required under the EHR Incentive Program?
  • Are there operational challenges to electronically reporting quality data? If so, does the hospital have mitigation plans to overcome these challenges?
  • Has the hospital chief information officer (CIO) and/or chief operating officer (COO) prioritized electronically reporting quality data over the next 3 years (2013 through 2015)?
  • Are there any evaluation or data validation methodologies that have been used by the hospital to assess the accuracy and reliability of clinical process of care quality data using Quality Reporting Document Architecture (QRDA) category I standards?
  • What barriers and opportunities would be created by including sampling criteria for electronically reported measures under the EHR Incentive Program?

CMS is also specifically soliciting comments from EHR vendors and other interested parties in the following areas:

  • Is the EHR vendor’s technology currently certified under the Office of the National Coordinator for Health Information Technology (ONC) Health Information Technology (HIT) Certification Program to the 2001 Edition EHR Certification Criteria?
  • Does the vendor intend to have its EHR technology certified to the 2014 Edition EHR Certification Criteria? If so, when?
  • What are the top three operational challenges facing EHR vendors over the next 3 years (2013 through 2015)? Of those identified, does the EHR vendor have mitigation plans to overcome these challenges?
  • Are there any evaluation or data validation methodologies that have been used to assess the accuracy and reliability of clinical process of care quality data using QRDA category I standards?
  • Have vendors included random sampling functionalities in currently certified systems? If yes, what guidance for random sampling has been employed, if any? If no, what barriers are presented by adding this functionality to your currently certified systems?

Responses to CMS’ RFI (CMS-3278-NC) are now due by 5 pm EST on Friday, February 1, 2013 (extended from Tuesday, January 22, 2013).  To read the RFI, click here.