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9/6/2011
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EHR Vendors Pan Medicare Quality Reporting Approach

Plan to require submission of patient-level, rather than aggregate, data would cost too much and be too complex, say Electronic Health Record Association members.

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The Healthcare Information and Management Systems Society's Electronic Health Record Association (EHRA), representing most of the top electronic health record (EHR) vendors, has asked the Centers for Medicare and Medicaid Services (CMS) to reconsider its plan to require detailed data on individual patients--rather than summary data for groups of patients--in its upcoming pilot of electronic quality data submission.

"From a cost-benefit standpoint, we see no real incremental benefit and a number of direct and indirect costs of going down that road," Mark Segal, a member of EHRA's executive committee and VP of government and industry affairs for GE Healthcare IT, told InformationWeek Healthcare.

For some time, EHR vendors that operate registries of clinical data and some individual providers have been sending aggregated EHR data to CMS' Physician Quality Reporting System (PQRS). In addition, physicians and other eligible professionals can use their certified EHRs to calculate the quality data required for Meaningful Use and enter the numbers manually on the CMS attestation website, Segal pointed out.

The problems in reporting patient-level data, in EHRA's view, fall under two headings: cost and complexity.

According to EHRA, CMS' approach entails extra data storage and transmission, which can be costly. "Once you get to patient-level data, the files for data transmission can be quite large, cumbersome to send, and maybe not easy to process," Segal said. "You can flesh those things out in a pilot, but they might also discourage participation in a pilot."

Additionally, vendors would have to rewrite their software for EHR users to report at the patient level. Segal couldn't say how much that would cost, but he said it would be substantially more than CMS' estimate of $2,000-$10,000 average per vendor. Moreover, he pointed out, vendors already had to enable their products ability to output aggregate quality data to obtain their current Meaningful Use certification.

As for complexity, CMS would require the use of a new transport standard--an HL7 document called Quality Reporting Document Architecture (QRDA)--to send the patient-level data electronically to its data warehouse. "For a pilot of the electronic submission, that's a fairly complex and untested format," Segal noted. "If they were continuing to use the aggregate-level information, they could do a pilot test of the electronic submission using the format that EHRs were certified for--the PQRI [Physician Quality Reporting Initiative] XML."

EHRA also objects to CMS' plan to require registry vendors that get their data from EHRs to send patient-level information if they participate in the pilot. Right now, some registries are designed to collect billing data from practices to make it easier for those practices to submit quality data to PQRS. In EHRA's view, Segal said, it's unfair that those registries could keep on sending CMS aggregate data while registries that gather EHR data--some of them maintained by EHR vendors--would have to move to a completely different method.

EHRA also thinks CMS is making a mistake in requiring eligible providers (EPs) who want to participate in the pilot to attest to Meaningful Use for a full year, even if they're in their first year of showing Meaningful Use. Since first-year attesters have to collect data for only 90 days before attesting, this approach would penalize those who chose to participate in the pilot by delaying their incentive payments for several months.

Overall, Segal pointed out, CMS should encourage maximal participation in order to get solid data on what works best in electronic data submission.

The EHRA reacted positively to three points in the CMS proposal:

-- CMS' decision to pilot data submission methods, instead of just making rules;

-- alignment of quality reporting between the EHR incentive program and the QPRS; and

-- continuation of the current attestation method through 2012.

Besides addressing CMS' proposals for quality reporting by EPs, EHRA sent the agency a separate letter in which it made essentially the same points about reporting by hospitals. "We support electronic reporting," concluded Segal. "We just want it to be done right."

Find out how health IT leaders are dealing with the industry's pain points, from allowing unfettered patient data access to sharing electronic records. Also in the new, all-digital issue of InformationWeek Healthcare: There needs to be better e-communication between technologists and clinicians. Download the issue now. (Free registration required.)

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