The HIMSS Electronic Health Record Association has requested that the Centers for Medicare & Medicaid Services reconsider a proposal to require the submission of patient-level data as it pilots electronic submissions of clinical quality measures.

Responding to proposed rules for the Medicare Physician Fee Schedule (MPFS) and the Hospital Outpatient Prospective Payment System for 2012, the EHR Association asked CMS Administrator Donald M. Berwick, MD, to think again.

The association, a trade group of 42 electronic health record vendors, cited among other reasons, the burden the rules would impose on providers

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“Our comments on these lengthy proposed rules focus on issues related to electronic health records,” said Mark Segal, vice president, government and industry affairs at GE Healthcare IT, an EHR Association past vice chair and member of its executive committee. “Although we’re supportive of many of the proposed changes, we have serious concerns about the complexity and overhead of reporting discrete patient-level data for quality measures, rather than summary data, as is the case today."


He did add, however, that "other aspects of the proposed changes for 2012 make a lot of sense" – for example allowing eligible professionals to use either a qualified e-prescribing system or a certified EHR for reporting.

The EHR Association also expressed strong support for CMS’ plans to align the Medicare Physician Quality Reporting System (PQRS) and EHR incentive program quality measures and reporting approaches, as well as the general intent to pilot electronic reporting of quality measures and the continuation of the current EHR incentive program attestation approach for quality measure reporting.

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“In the current environment, providers must understand and comply with several new programs, so it’s important that elements that are proven and operational be maintained in order to minimize uncertainty and maximize the value of prior technology investments,” said Leigh C. Burchell, vice president of government affairs for Allscripts, and chair of the association’s public policy workgroup.

For that reason, she said, "we would like CMS to reconsider its decision not to use the Physician Quality Reporting Initiative (PQRI) XML format to convey aggregate quality measures data from EHRs for electronic reporting as part of the EHR incentive program, and instead to use for the pilot (and likely beyond the pilot) a relatively untested measure electronic submission format that focuses on patient-level data. We also ask CMS to make other changes to their proposed pilots that would encourage wider participation."
 
The full text of the association’s comments on both the physician and hospital proposals at himssehra.org.