The federation in a comment letter to CMS calls on the agency to fully integrate the migration of electronic reporting across all relevant programs. “CMS also must recognize that hospitals will be required to continue to report chart abstracted data to other state and national entities such as the Joint Commission,” according to the letter. “Until all of those entities are in total alignment with the CMS requirements for electronic reporting of quality measures, the burden of chart abstraction will remain for many hospitals.”
While quality reporting through EHRs has potential to reduce burden, there are technical challenges to overcome. The federation urges that electronic measures work as intended before being implemented. “The eMeasures currently in use in the meaningful use program are largely re-tooled, chart-abstracted measures that have not been tested and were not developed with the capabilities of an EHR in mind,” the organization asserts. “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 the eMeasures specifications.”
Of particular concern to the federation is that the request for information CMS issued on hospital and vendor readiness for electronic reporting may be overly optimistic of the readiness. “The meaningful use program largely has been a test-bed for electronic quality reporting. We believe this is appropriate, given that the meaningful use program was intended to build functional capacity using EHRs. However, the RFI is suggesting EHR reporting for data that will be used in public reporting and payment programs. This requires a much more robust infrastructure and much higher levels of scrutiny regarding data validity, quality and completeness.”
The federation’s comment letter is available here.