- In a recent letter to CMS Administrator Seema Verma, HIMSS recommended several ways the federal agency can improve electronic clinical quality measure (eCQM) development, implementation, and reporting to reduce administrative burden on providers and more accurately reflect the quality of care delivery.
First, HIMSS suggested CMS refrain from adopting claims-only quality and outcomes reporting.
“Measurement programs should select the form of measurement that best measures the appropriateness and quality of care of the organization being measured,” stated HIMSS representatives in the May 31 letter.
HIMSS explained claims-based codes used for reporting support reimbursement optimization rather than care quality improvements.
“Overall, HIMSS supports a transition to more eCQMs and decreasing the utilization of claims codes for quality measure reporting,” stated HIMSS.
“While there is a decrease in the burden of reporting with claims coded for quality and outcomes, we believe the inherent incongruities between claims codes and the quality of care provided to the patient are much greater when using eCQMs than other methods of quality reporting,” HIMSS continued.
The society also suggested CMS quality reporting policies enhance the value proposition of participating in quality reporting programs and ensure quality measures are actually useful for improving patient health outcomes.
“We agree with the recent shift by CMS to more outcomes measures, and encourage CMS to work to support the development of outcomes-driven clinical quality measures that can be extracted from electronic clinical data,” wrote HIMSS.
“In addition, eCQMs selected for HHS programs should be actionable, meaning that reported clinical quality measure data can be utilized to identify gaps in care, conduct workflow analysis and root cause analysis for performance outcomes, and trigger change management to adjust workflows and best practice guidance that will drive improved outcomes,” continued the society.
By enabling providers to access clinically relevant data, CMS can ensure measurement reporting holds value beyond merely confirming that providers comply with federal regulations.
HIMSS advised that CMS implement measures that promote accurate provider attribution for quality measures to ensure equity in value-based payments across care settings and public reporting.
“One of the most important goals in CQMs is for providers to be able to measure and evaluate their own quality improvement without being overly burdensome to collect and report data,” emphasized HIMSS.
In an effort to further reduce administrative burden, HIMSS recommended CMS use information already collected for care in quality reporting to reduce the strain of data reporting on providers, hospitals, and health IT developers.
“We encourage CMS to select eCQMs that are proven to be feasible across all care delivery environments and ensure that eCQMs accurately reflect the quality of care delivered,” stated HIMMS. “HIMSS believes eCQMs have the potential to achieve the critical goal of providers measuring and evaluating their own quality improvement without being overly burdensome to collect and report data.”
Additionally, HIMSS urged CMS to allow providers an appropriate amount of time to implement and test measures before making certain measures mandatory.
Specifically, HIMSS advised CMS to ensure measures related to 2015 edition certified EHR technology (CEHRT) are properly tested, field tested, and verified for comparable and consistent results before inclusion in a quality measure set as part of the Merit-Based Incentive Payment System (MIPS).
“The time required for vendors and providers to implement any single eCQM can be highly variable, depending on the complexity of the measure, the extent to which new eCQM authoring tools and representation approaches have been used, and the scope to which the measure draws on data elements already collected in EHRs,” noted HIMSS.
Finally, HIMSS suggested CMS continue to improve post-regulatory guidance offerings through the electronic clinical quality improvement (eCQI) Resource Center to help stakeholders implement and field test new eCQMs and make changes to measure specifications.
“It is absolutely critical for CMS and partner organizations to create broader awareness among frontline clinicians to understand the vision and mission of what electronic clinical quality measurement can accomplish, how accurate quality reporting benefits providers and patients, and how CMS and stakeholders are planning to overcome current barriers to effective reporting and utilization of eCQMs,” stated HIMSS.
These and other recommendations are intended to optimize the effectiveness of eQCM reporting while also ensuring reporting requirements do not detract from patient care delivery or put undue strain on healthcare organizations.