Association Voices Objections to Patient-Level Data Reporting Rules

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The HIMSS Electronic Health Record Association is asking the Centers for Medicare and Medicaid Services (CMS) to reconsider a proposal to require the submission of patient-level data as it pilots electronic submissions of clinical quality measures.

Responding to proposed rules for the Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System for 2012, the EHR Association—a group of 42 electronic health record (EHR) vendors—expressed in comments to CMS Administrator Donald M. Berwick, MD its concerns about the complexity and overhead of reporting discrete patient-level data for quality measures, rather than summary data, as is the case today.

Specifically, the association wants CMS to reconsider its decision not to use the Physician Quality Reporting Initiative (PQRI) XML format to convey aggregate quality measures data from EHRs for electronic reporting as part of the EHR incentive program. Rather, its constituents request the use, for the pilot (and likely beyond the pilot), of a relatively untested measure electronic submission format that focuses on patient-level data.

Also on the wish list are other changes to their proposed pilots that would encourage wider participation.

"In the current environment, providers must understand and comply with several new programs, so it’s important that elements that are proven and operational be maintained in order to minimize uncertainty and maximize the value of prior technology investments,” states Leigh C. Burchell, vice president of government affairs for Allscripts, and chair of the association’s public policy workgroup.

The comments also elaborate upon the association’s support of certain aspects of the proposed changes for 2012. Some changes, the association believes, “make a lot of sense" – for example allowing eligible professionals to use either a qualified e-prescribing system or a certified EHR for reporting.

Moreover, the comments indicate, the EHR Association strongly supports CMS’ plans to align the Medicare Physician Quality Reporting System (PQRS) and EHR incentive program quality measures and reporting approaches, as well as the general intent to pilot electronic reporting of quality measures and the continuation of the current EHR incentive program attestation approach for quality measure reporting.

For the full text of the association’s comments, click here: http://www.himssehra.org/ASP/index.asp.