An association of hospital chief information officers is warning the CMS that reporting of complete and accurate clinical quality measures through electronic health records systems is “nearly impossible” for many healthcare organizations given the state of record-keeping workflows and technology.
The comments from the College of Healthcare Information Management Executives came in response to a CMS “request for information” from hospital and health IT system vendor leaders that asked them to assess the readiness of their organizations for electronic submissions of clinical quality measures for the CMS' Hospital Inpatient Quality Reporting program created under the Medicare Prescription Drug, Improvement, and Modernization Act (MMA) of 2003.
CHIME, however, did not confine its comments to that program alone, since Stage 2 of the federally funded EHR incentive payment program under the American Recovery and Reinvestment of 2009 also requires reporting of quality measures. The starting date for the first year of Stage 2 for hospitals that have completed two or three years at Stage 1 is the beginning of the federal fiscal year, Oct. 1, 2014.
In a news release, CHIME praised the CMS
for seeking to harmonize the reporting of clinical quality measures, but “also warned that current technology and workflow burdens make accurate and complete quality data reporting through the EHR nearly impossible.”
In a six-page response letter (PDF)
addressed to acting CMS Administrator Marilyn Tavenner and jointly signed by CHIME President and CEO Richard Correll and board Chairman George Hickman, the executive vice president and CIO at Albany (N.Y.) Medical Center, the CHIME leaders said that even EHRs tested and certified to the 2014 Edition criteria for use in Stage 2 “will be incapable of generating complete and accurate CQM reports.”
That's because quality data for reporting, currently obtained in many instances by data abstractors, “are often found in dictated reports or free form progress notes, not as structured data” in an EHR.
According to CHIME, “without making the entire record structured, discreet data or having mature test recognition software in place, one cannot extract all the data needed on every patient to create accurate quality metrics. If absolute accuracy is required by Stage 2 (e.g. reflective of what is reported manually through abstraction) then most current systems will fail to meet the required reporting criteria.”
And even if EHRs tested and certified to 2014 Edition standards operated flawlessly, the CHIME leaders doubted that many providers will have the updated software “until well into 2014.” To date, there are no complete EHR systems that have been upgraded, tested and certified to 2014 Edition criteria on the market and may not be until after Feb. 15, at least in part because of glitches
in key testing tools being developed by government contractors.