The Office of the National Coordinator for Health IT (ONC) has developed criteria for Meaningful Use of Electronic Health Records (EHRs). An HHS-certified EHR (and remember, there are no current HHS-certified EHRs, since that process is yet to be finalized), when used in a “meaningful” way, will allow clinicians to access stimulus money from the Centers for Medicare and Medicaid Service (CMS), as per the ARRA HITECH section’s provisions. These incentive bonuses will be paid out over several years, and can total up to $44,000 per clinician, or more if they serve a high percentage of Medicaid patients.
While the ONC has undergone an impressive deliberative process in order to put together Meaningful Use criteria, it is still not clear precisely how a physician will actually report the data to CMS.
A number of the criteria – e.g., the percentage of diabetics with glycohemoglobin (HbA1c) levels under control – are similar to Physician Quality Reporting Initiative (PQRI) measures, used by CMS in their pay-for-performance (P4P) programs. Many have speculated that Meaningful Use reporting will parallel what has been done for PQRI – both are reporting methods to CMS, and it makes sense that CMS will not want to “re-invent the wheel” when it comes to collecting Meaningful Use data.
For PQRI data reporting, the most common method of submitting quality metrics is through billing. There are data-reporting billing codes – CPT II codes – that can be added to bills that are sent to CMS.
There are also two other options for reporting PQRI data: (1) registry-based submission, and (2) EHR-based reporting. A number of organizations and EHR vendors have created registries to facilitate PRQI reporting, but the number of measures reportable through this avenue varies from one registry to the next. Vendors that have offered this pathway to customer-physicians often levy fees – one vendor charges a $350 “processing fee” to submit data from their registry to CMS.
Surprisingly, direct reporting from EHRs does not seem to have been taken up by EHR vendors as of yet. Direct reporting requires a more difficult set-up between EHRs and CMS, and since traditional EHRs have been local client/server installations, a connection between each installation and CMS would have been needed. Because of these challenges, EHR vendors have instead favored the registry-based option – registries have the ability to gather PQRI data directly from a client’s EHR, or can be populated manually from paper via a web portal, and then uploaded from this central repository to CMS on a periodic basis.
The difference between PQRI and Meaningful Use, though, is that PQRI reporting does not necessitate the use of an EHR – many practices participate in PQRI P4P bonus payments using claims-based CPT II codes, and do not have an EHR. Meaningful Use, by definition, implies that an EHR is in place. Manual reporting methods make less sense.
As the ONC makes recommendations to CMS, it is important for CMS to expand its reporting avenues for registry-based submission, and (especially) for EHR-based submission. The best way for CMS to do this would be to make available web-based interfaces (an API) for Meaningful Use reporting. A web service can be very secure, like internet-based e-commerce, where a web site can pass data in a structured way to a bank’s API, and the bank’s back-end keeps track of account balance information.
Creating web-based APIs would be a more useful way of interacting with CMS than other, more legacy-based methods such as HL7 file submission. HL7 files are structured text files that are intended to be a “universal” way for different systems to talk to each other. Unfortunately, HL7 files are used differently by different vendors, so “HL7 integration” is far from universal, and requires a “specification document” that details how a vendor uses their particular version of HL7. This approach, though favored historically, is less consistent with modern, web-based technology. However, regardless of the method, our hope is that CMS will be able to create an easily-interfaced way by which EHRs can facilitate physician reporting of Meaningful Use data.
Creating APIs for data connectivity with CMS (or the CDC, for that matter) requires a new build-out for the government. It is not a trivial task, but one that can readily be accomplished (like e-commerce, and Health 2.0 companies have done). Practice Fusion is willing to work with CMS to create such connectivity, as we believe that all vendors, large and small, will benefit from such universal, modern connectivity platforms.
We’re ready to roll up our sleeves.
Robert Rowley, MD – Chief Medical Officer, Practice Fusion, Inc.