Hospitals can request hardship exemptions from electronic clinical quality measure (eCQM) reporting for calendar year 2016. But, organizations better have compelling reasons for doing so and the documentation to prove it, according to the Centers for Medicare and Medicaid Services.
CMS recently issued eCQM guidance regarding extraordinary circumstances extension and exemption (ECE) requests under the Hospital Inpatient Quality Reporting Program. For calendar year 2016 reporting, hospitals have until April 1 to submit an ECE request. To qualify, they must demonstrate that these hardships prevented them from electronically reporting information.
The agency will consider infrastructure challenges such as hospitals that operate in areas without sufficient Internet access or unforeseen circumstances such as vendor issues outside of a hospital’s control including a vendor’s product losing certification. However, CMS says it evaluates ECE requests on a case-by-case basis to determine whether circumstances are in fact beyond a hospital’s control.
“ECEs have not typically been granted for issues such as staff members on leave, changes in staff, burst water pipes, or temporary electrical outages; CMS believes these kinds of events are manageable and within the control of the hospital,” states the agency’s guidance. “In previous cases, CMS has not considered issues related to performance by a vendor or changes in vendor as a circumstance beyond a hospital’s control because CMS believes hospitals have the ability to mitigate the impact of such issues through the negotiation of contractual terms with the vendor.”
Nonetheless, the agency acknowledges that the time and financial burdens of switching EHR vendors and upgrading EHR systems can be significant challenges to complying with the eCQM reporting requirements. As a result, CMS offers that it “will consider granting ECE requests related to EHR vendor transitions and upgrades,” while emphasizing that any request granted on the basis of EHR vendor issues will apply only to the submission of eCQM data.
“Hospitals have found it very challenging to report eCQMs, therefore this kind of hardship exemption is very important,” said Chantal Worzala, vice president of health information and policy operations at the American Hospital Association.
In a recent survey in which hospitals were asked whether their EHR vendors provide them with support to meet the eCQM requirements, 51 percent of respondents replied in the affirmative while 35 percent said they did not feel they would receive vendor support. In addition, many hospitals indicated in the survey that they will need to change EHR vendors to comply with the requirement.
Still, after eCQM reporting becomes more established and familiar to hospitals, the agency says it “intends to treat an EHR vendor change as part of a hospital’s routine business operations and no longer an extraordinary circumstance for the purposes of granting an ECE.”
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