The proposed Stage 2 rule permits providers in group practices to attest using a “batch file process,” NCQA notes in a comment letter to the Centers for Medicare and Medicaid Services. “However, providers must still attest to meaningful use requirements on an individual basis, even under the proposed group reporting option.”
This limits the ability to take advantage of the alignment between NCQA’s Patient-Centered Medical Home Program for practices and meaningful use, the organization adds. “We strongly urge CMS to work with Congress, the HIT Policy Committee and other stakeholders to allow providers at recognized PCMHs to satisfy the corresponding meaningful use criteria. This would reduce burden on both providers and regulators, and encourage providers in PCMHs to seek meaningful use incentive payments.”
NCQA also recommends CMS further meaningful use alignment by standardizing physician clinical quality measures reporting across its programs, such as the Physician Quality Reporting Systems. “Under PQRS, physicians are required to report quality measures based on their Medicare population only; under meaningful use, physicians report on their entire panel of patients. This could complicate the process of combining CQM data and benchmarking physician performance. In addition, NCQA does not believe that providers change their practice based on payer and including all patients will only increase the accuracy of CMS’ quality reporting efforts. We urge CMS to update the PQRS methodology and allow physicians to report based on their entire panel of patients.”
The comment letter also includes a chart showing alignment between the meaningful use and PCMH programs, a crosswalk of Stages 1 and 2 requirements to the NCQA PCMH program, and a crosswalk of proposed clinical quality measures for eligible professionals and NCQA programs. The letter is available here, scroll down the left side.