The reporting of Clinical Quality Measures is one of the criteria for Meaningful Use, and (like all the other Meaningful Use criteria in 2011) is reported by Attestation this year. The original plan for Stage 1 of the Medicare EHR Incentive Program (Meaningful Use) was that these quality measures would be reported electronically beginning in 2012.
In a new proposed rule, the Centers for Medicare and Medicaid Services (CMS) will be postponing the electronic submission of CQM data for a year – therefore, in 2012 (just like in 2011), CQM reporting will be by Attestation. This proposal, buried in the physician fee schedule for 2012, will be published July 19, but is available here for review now.
The plan was to use the same format for Meaningful Use CQM reporting as has been used for the Physicians Quality Reporting System (PQRS – formerly PQRI). The PQRS reporting of quality measures is governed by a separate law, and has included quality metric reporting by 3 different methods: (1) claims-based reporting, using CPT-II codes, (2) registry reporting for those wanting to load their data manually into a registry web site, often at a cost, and (3) direct reporting out of an approved EHR. Registry reporting and EHR reporting both use the PQRI 2009 Registry XML Specification – a defined format with which to assemble and send CQM reports.
Rather than re-invent this wheel, Meaningful Use CQM reporting was intended to use the same reporting format. However, CMS was not ready to receive such reports on the Meaningful Use quality measures in 2011 (which are different than the PQRS measures, though there is some overlap), and therefore laid out CQM reporting to be by Attestation.
Apparently, CMS has stated that “Since the publication of the final rule, we have determined that it is not feasible to receive electronically the information necessary for clinical quality measure reporting based solely on the use of PQRI 2009 Registry XML Specification content exchange standards as is required for certified EHR technology.”
Bottom line – just like in 2011, CQM reporting for Meaningful Use will continue to be by Attestation in 2012. Interestingly, Certified EHR products (like Practice Fusion) have the ability to create these CQM reports – it’s just that CMS is not yet ready to receive them.
We will keep you informed as this, and other developments, unfold in the roll-out of Meaningful Use and its 3-Stage implementation.