- The American Medical Informatics Association (AMIA) hopes to guide the Centers for Medicare and Medicaid Services (CMS) toward a pragmatic approach for development of electronic clinical quality measures (eCQMs) as they relate to future policy and regulation strategies for value-based care reimbursement.
AMIA CEO Douglas Fridsma, MD, and Board Chair Thomas Payne, MD, detailed their views on behalf of the association in a Feb. 1 letter to CMS Acting Administrator Andy Slavitt. Their remarks responded to CMS’ Request for Information (RFI) on Certification Frequency and Requirements for the Reporting of Quality Measures under CMS Programs, which was published Dec. 31, 2015 in the Federal Register.
The letter co-authors indicated that CMS missed the mark in its RFI questions by focusing on certification as a potential solution to refining the agency’s quality measure reporting strategy. Such questions “do not address the fundamental deficiencies and challenges with the process of generating eCQMs as well as reporting the measures,” they wrote.
The AMIA officials asserted that certification enhancements would not address existing problems with quality measurement:
“Providers have very little, if any, confidence in eCQM accuracy and completeness; health IT developers spend an inordinate amount of resources devoted to eCQMs, which represents an opportunity cost for other customer priorities; and there is little time for the stakeholders to incorporate updates into their products and workflows. In short, the task of gathering and reporting eCQMs overshadows the benefits of tracking measures in many instances.”
AMIA called on CMS to rework how eCQMs are developed and conceptualized, and recommended pilot testing and “assessment of how implementable” new measures would be for Medicare providers. The association further urged CMS to consider eCQMs as they would apply to longitudinal views of patients and populations.
Specific components of the recommended overhaul would include:
- Reaching consensus on how to construct eCQMs based on the capabilities of EHRs in use, as well as other health IT tools used for data collection and reporting.
- Developing and implementing methods to estimate the cost of data collection, along with the likely benefits to patients of any new measure.
- Considering a separate endorsement path for electronically specified measures that would account for the feasibility of workflow implementation (including pilot testing for a measure’s intended practice setting).
- Building stability and consistency in what is measured and reported across CMS program and in coordination with other payers.
- Investing in the infrastructure for thorough and effective testing of measures (e.g., enhancing test data and testing tools).
- Allowing healthcare teams and/or multiple clinicians who coordinate care for a patient to report eCQMs as a group.
AMIA acknowledged CMS’ recent indications that the agency would work with medical specialty societies to help determine the evidence-based quality measures that would be important to track for their patient populations, but recommended more work to ensure that such specialties use a consistent set of data standards and formats in their quality measures.
“This will simplify how EHRs collect quality measurement data” for different specities, the AMIA officials noted.