The Federation of American Hospitals supports goals outlined by the CMS to harmonize reporting of clinical quality measures, but warned that selected measures should be field-tested before being implemented as part of national quality reporting and payment programs.
The Washington, D.C.-based federation, which represents for-profit hospitals, also challenged the CMS to heal its own data-collection ills.
It also called for postponing the requirement that quality measures be reported electronically until the national conversion to the ICD-10 family of diagnostic codes and procedures is complete.
The federation's position was spelled out in a four-page letter to CMS Acting Administrator Marilyn Tavenner
by federation President and CEO Chip Kahn. The letter is a response to a CMS request for information on the state of hospital and vendor readiness to electronically report clinical quality measures.
“We believe that quality reporting through EHRs has the potential to reduce burden on providers, improve the quality of the data and improve access to quality information within institutions,” Kahn wrote, adding that, “a number of technical challenges” must first be met and solved.
“Once nationwide implementation begins, it becomes too late to temporarily stop the process and address the issue often resulting in 'Band-Aid' type fixes that do not fully address the issue,” Kahn said. “Moving forward we recommend that all eMeasures undergo field-testing with an adequate number of hospitals and EHR vendors to ensure the accuracy of data capture requirements and the validity of the data generated, as well as to identify and address gaps in eMeasures specifications.”
Kahn noted that hospitals have not yet seen specifications on how to submit patient-level measures to the CMS, and asked, “Is CMS ready with the infrastructure to facilitate the collection of eMeasures data? Several examples suggest otherwise. For example, there is currently no defined process for clarifying electronic measure specifications.”
Kahn also noted that the CMS “has experienced multiple errors in the downloadable Hospital Compare database on a quarterly basis.”
Rather than switching from reporting manually abstracted quality measures to electronically reported measures all at once, the federation also recommends transitioning to e-reporting “measure set by measure set” to avoid “unintended consequences” of an abrupt conversion.
It also recommended that new measures be kept on a “secure website” for viewing by participating hospitals for a full year before they are made public. “This process will provide hospitals and vendors with insight into potential gaps” before the data impacts payments.
Finally, Kahn urged “postponing the move to electronic reporting until the move to ICD-10 is complete,” noting that the shift to ICD-10 “will be resource intensive both for providers and for CMS.”