The American Medical Informatics Association recommends that CMS create measures based on existing EHRs and health IT rather than on ideal measures, and that it estimate the cost of implementing and reporting new measures.
This article originally appeared in Physician Practice Insider.
CMS missed the mark in its recent request for feedback on certification frequency and reporting requirements for quality measures, according to the American Medical Informatics Association (AMIA). While AMIA praised CMS for seeking information and opportunities for improvement to prepare for the Medicare Access and CHIP Reauthorization Act of 2015 (MACRA), the Request for Information (RFI) failed to address the most significant problems affecting EHRs and meaningful use.
The questions CMS asked in this RFI primarily dealt with enhanced certification and positioned such measures as a solution to current deficiencies with quality measurement. The RFI did not address the current issues and complexity of generating and reporting electronic clinical quality measures (eCQM), AMIA said in its statement released February 1.
Providers generally lack faith in the accuracy and completeness of eCQMs, and heath IT developers sink significant resources into eCQMs at the cost of other customer priorities, AMIA said. The benefits of eCQMs are often canceled out by the burden of gathering and reporting them. This problem will only be exacerbated by the predicted increase in quality measurements as part of the Merit-based Incentive Program System (MIPS) and Alternative Payment Models (APM) unless CMS overhauls its eCQM reporting guidelines.
Essential improvements should include pilot testing of measures and an evaluation of how practical new measures are in a real world environment, AMIA recommended. New measures should be certified based on how well they enhance patient experience, not simply whether CMS believes the measure is clinically appropriate. AMIA also urged CMS to rethink its definition of quality measurement and create a methodology that measures trajectories rather than thresholds and is more in line with care models described in MACRA.
In addition, AMIA recommended that CMS:
- Create measures based on existing EHRs and health IT rather than on ideal measures
- Estimate the cost of implementing and reporting new measures
- Test and certify the practical workflow of measures
- Make measures and reporting consistent across programs
- Allow practitioners who coordinate care on a patient to report CQM as a group
In direct response to the questions asked in the RFI, AMIA advised CMS to:
- Not change the frequency of recertification
- Work closely with ONC to develop new measures
- Create a consistent cycle of updates
CMS issued the RFI in December 2015 to explore options that might improve the certification and testing of health IT in general and EHRs specifically and reduce provider burden, according to CMS' statement.