Starting in 2014, physicians seeking meaningful use incentive payments will have to report data on clinical quality measures generated from clinical encounters to the Centers for Medicare & Medicaid Services or to state Medicaid authorities. This marks a change from the original stage 1 requirements for meaningful use, where physicians could simply attest to having collected the necessary data.
To provide physicians with electronic health record (EHR) technology that supports this data collection and reporting, vendors will have to make some changes to their systems and meet stricter certification standards, which could make achieving certification difficult for some. All providers who are beyond their first year of participation in the meaningful use program will have to begin reporting the new clinical quality measures (CQMs) in 2014, regardless of whether they are at stage 1 or stage 2 of meaningful use.
I think there is the potential that the smaller vendors that got into the business later may have difficulty with some of these.
director of certification, CCHIT
All EHR systems seeking certification under the 2014 rules must be able to capture, calculate and report CQM data electronically. Being able to report data straight from the EHR to the Centers for Medicare & Medicaid Services (CMS) is one of the main differences in the new rules. Under stage 1 rules, physicians submitted CQM data manually through the attestation portal.
In an October 24 conference call announcing the release of the new measures, Maria Michaels, technical program manager for the HITECH CQM program and policy, said the requirement that all CQM data be reported electronically is one of the biggest technological changes in the measures. Many vendors will need to upgrade their programs to support electronic reporting.
Vendors can test whether their systems are able to handle CQM data electronically by downloading an XML file from Cypress, a Web-based application developed by Mitre Corp. with funding from the Office of the National Coordinator for Health IT, or ONC. Cypress will also be used by all authorized testing and certification bodies to test whether systems meet the CQM provisions of the 2014 certification standards.
The 2014 CQMs place a much greater emphasis on standardizing data than the previous requirements did. The e-specifications list that accompanies the CQMs defines the technical languages in which data elements must be captured and reported. Various measures will be reported using the LOINC, SNOMED or RxNorm standards.
Increased regulations could be challenge for vendors
Patricia Becker, director of certification at the Certification Commission for Healthcare Information Technology (CCHIT), said the tighter requirements for electronic data reporting and standardization could make it difficult for some vendors to achieve EHR certification.
She pointed to the fact that the new CQMs require EHRs to capture actual clinical data, whereas previous rules allowed the use of administrative data. The difference might be subtle, but it will require EHR vendors to update their systems to ensure that quality data can be captured during patient encounters.
This is not likely to be a challenge for larger vendors, Becker said. The new CQMs require more intensive data capture and reporting, but there is nothing surprising about them. Government officials signaled early on that the meaningful use program would head in this direction.
Still, Becker feels that some smaller vendors with fewer resources might not be able to update their products, and that could eventually start thinning out the number of certified vendors. "If they planned appropriately, they should be prepared," she said. "The whole idea is to accelerate the implementation of electronic medical records more broadly, so it's not surprising from the provider side that they have to use the medical records more rigorously than in stage 1. [But] I think there is the potential that the smaller vendors that got into the business later may have difficulty with some of these."
Surveys conducted by CCHIT have shown that about one-third of EHR vendors are currently prepared to comply with the 2014 certification standards, including the CQM requirements, Becker said. However, this leaves a significant portion of vendors that aren't ready.
Timing is everything
Mamie Stalvey, R.N., principal at Impact Advisors LLC, said that EHR vendors have been waiting on the release of the updated CQMs for some time. Companies only have until 2014 to update their systems to reflect the new measures and reporting requirements.
Even though the vendor community knew it wasn't going to get the updated list of CQM requirements any sooner, it might still be difficult for some to catch up. "They are now on a tight timeline," Stalvey said. The electronic data reporting requirement could be one of the more difficult provisions for vendors to meet, she added. Some of her physician clients used systems to meet the stage 1 requirements that didn't report out data in standardized formats.