THE NATIONAL QUALITY MEASUREMENT AND IMPROVEMENT AGENDA

Transcription

1 THE NATIONAL QUALITY MEASUREMENT AND IMPROVEMENT AGENDA REUTERS/Tim Shaffer LOUIS H. DIAMOND, MD VP AND MEDICAL DIRECTOR, THOMSON REUTERS HEALTHCARE AND SCIENCE APRIL 22, 2010

2 DISCLOSURE Louis Diamond works for the Healthcare and Science business of Thomson Reuters. No products will be discussed during the presentation.

3 ACRONYMS AQA- Ambulatory Care Quality Alliance ARRA American Recovery and Reinvestment Act (a.k.a. the stimulus bill ) CDS Clinical Decision Support CPOE Computerized Provider Order Entry EH- Eligible Hospital as defined by the CMS EHR Incentive Program EHR Electronic Health Record EP- Eligible Provider as defined by the CMS EHR Incentive Program HIE Health Information Exchange HIT Health Information Technology HQA - Hospital Quality Alliance MU- Meaningful Use NPRM Notice of Proposed Rule Making NQF- National Quality Forum ONC- The Office of the National Coordinator for Health Information Technology PHI Protected Health Information PI Process Improvement PQRI - Physician Quality Reporting Initiative RHQDAPU - Reporting Hospital Quality Data for Annual Payment Update

4 OBJECTIVES Participants will be able to describe The national quality and performance improvement enterprise The objectives of the MU proposed rule The various MU quality measures Key regulatory dates impacting MU quality reporting The steps to take to comply with the MU quality measures

5 Steps for Improving Health Care Quality & Value: Who s Making it Happen?

6 PERFORMANCE MEASUREMENT AND QUALITY IMPROVEMENT SYSTEM Measure Development PCPI & Specialty Assoc. NCQA/JC CMS Evidence and CPG Generation Measure Adoption NQF Measure Implementation AQA, HQA, QASC Physician & Hospitals, etc. Health Plans and CMS HIT vendors HIT Support CME/CPPD Evaluation AQA-AQA CME-Continued medical evaluation CPG-Clinical practice guidelines CPPD-Continued physician professional development HIT-Healthcare Information Technology HQA-Hospital Quality Alliance NCQA/JC-National Committee on Quality Assurance/Joint Commission QASC-Quality Alliance Steering Committee

7 HEALTH INFORMATION TECHNOLOGY: NATIONAL ENTERPRISE Office of the National Coordinator (ONC) Standards Development Organizations (SDOs) Policy Committee HIT Standards Panel (HIT SP) * Standards Committee* *Measure Developers NQF HITEP Panel 2 EHR Vendor/Developer coalitions Certification Commission* HIT (CC HIT)

8 * NQF PRIORITIES PARTNERSHIP - NATIONAL PRIORITIES Chaired by Don Berwick and Peggy O Kane 28 Partners; consumers, providers, practitioners, accreditors, quality alliances, purchasers and insurers Builds on prior efforts by the IOM* and NQF Articulates performance measures, goals and action steps Describe steps to engage and facilitate adoption Recommends overarching and disease specific priorities Covers quality and cost of care/efficiency A CAMPAIGN; NOT A LIST *Institute of Medicine

9 NATIONAL PRIORITIES Improve the Health of the Population Engage Patients and Families in Managing Health and Making Decisions about Care Improve the Safety of America s Healthcare System Ensure Patients Received Well-Coordinated Care across all Providers, Settings, and Levels of Care Guarantee Appropriate and Compassionate Care for Patient with Life-Limiting Illnesses Eliminate Waste While Ensuring the Delivery of Appropriate Care

10 USE/QUALITY MEASURES SPECTRUM Increasing Level of Evidence Clinical Actionability Process - Outcome Linkage Norms Administrative data Standards + Pharmacy data + Enrollment data + Lab data Use Measure Quality Indicator Quality Measure Adm/1000 CABG/ CA risk pop. Avoid Adm CPM Lite CPM Better CPM Product/Value Differentiation CPM = Clinical Performance Measures

11 NPRM vs. FINAL RULES This presentation discusses a NPRM and not the final rules. The reader is cautioned that the final rules will likely differ from the current drafts published in the federal register on January 13, The NPRM published on in the Federal Register contains slight differences from the NPRM released by CMS on including pagination and page numbers.

12 MU GOALS Improve quality, safety, efficiency and reduce disparities Engage patients Improve coordination of care Ensure privacy and security of PHI Improve population health and interact with public health programs

13 THE HITECH ACT S FRAMEWORK FOR MEANINGFUL USE OF ELECTRONIC HEALTH RECORDS (EHRs) Blumenthal D. N Engl J Med 2009; /NEJMp

14 REGULATORY TIMELINE: January 13, 2010: Official publication in the Federal Register of: NPRM: Medicare and Medicaid Programs; Electronic Health Record Incentive Program IFR: Health Information Technology: Initial Set of Standards, Implementation Specifications, and Certification Criteria for Electronic Health Record Technology these become effective 30 days post publication regardless of comments! March 15, 2010: Comment submission periods for the NPRM & IFR close March April 2010: Anticipate the final rules on the CMS Electronic Health Record Incentive Program will be published By April 15, 2010: Specifications related to the quality measures By July 1, 2010: Specifications for how to submit quality measures Early 2010 ONC has stated they will issue a separate Notice of Proposed Rulemaking (NPRM) to describe the process for authorizing certification bodies to conduct the testing and certification of Complete EHRs and EHR Modules Key take away no one is officially recognized to certify your EHR today!

15 OUTLINE OF THE ISSUES COVERED BY THE NPRM Defines eligible hospitals ( EHs) and eligible professionals ( EPs) Establishes payment years & reporting periods Creates 3 Stages of implementation Provides details on Stage 1 goals and requirements covering 2011 and 2012

16 MU NPRM STAGES Stage Focus Date Range Stage 1 Data capture, basic functions, measure reporting Starting in 2011 Stage 2 Expands on stage 1, covers disease management dimensions Starting in 2013 Stage 3 Promotes PI, enhanced CDS, population health and support for public health Starting in 2015

17 STAGE OF MEANINGFUL USE CRITERIA BY PAYMENT YEAR First Payment Year Payment Year Stage 1 Stage 1 Stage 2 Stage 2 Stage Stage 1 Stage 1 Stage 2 Stage Stage 1 Stage 2 Stage Stage 1 Stage Stage 3 Note: For the first payment year only, CMS proposes to define the term EHR reporting period to mean any continuous 90-day period within a payment year in which an EP or eligible hospital successfully demonstrates meaningful use of certified EHR technology. Starting with the second Payment year and any subsequent payment years for a given EP or eligible hospital, CMS would define the term EHR reporting period to mean the entire payment year.

18 MU STAGE 1 COMPONENTS Our Focus Quality Measures Reporting CPOE Data collection problem list, medication list, allergy list, demographics, vital signs, smoking status, test results Functions---drug screening, reminders to patients, summary of each visit, generate patient lists; 5 CDS rules, medication reconciliation HIE to patients, to public health agencies Protect health information

19 EHs MU NPRM QUALITY MEASURES REPORTING REQUIREMENTS 35 quality measures (all 35 adopted by NQF; 25 adopted by HQA) Clinical quality measures selected from those endorsed by the NQF or have previously been selected for the RHQDAPU program. Existing Core Measures requirements and financial incentives (APU) remain in place in parallel to ARRA incentives Of the 35 quality measures included in the proposed rule All may not be included in the final rule ~7 are overlapping with existing Core Measures Specifications related to these quality measures will be made available on or before April 1, 2010 A certified EHR (or module) must be used to capture the measures

20 EH QUALITY MEASURES FROM TABLE 20 Example: First 5 EH Quality Measures

21 EPs MU NPRM QUALITY MEASURES REPORTING REQUIREMENTS Two measure sets: A core set for all and an applicable specialty group There are over 90 Quality Measures (79 Endorsed by NQF, 5 endorsed only by AQA, 6 not endorsed by any external entity) Clinical quality measures primarily selected from those endorsed by the NQF or have previously been selected for the Physician Quality Reporting Initiative (PQRI) program. Existing PQRI requirements and financial incentives remain in place in parallel to ARRA incentives Of the 90 quality measures included in the proposed rule All may not be included in the final rule ~59 are overlapping with existing PQRI Measures Specifications related to these quality measures will be made available on or before April 1, 2010 A certified EHR (or module) must be used to capture the measures

22 FIRST SET: ALL EPs MUST SUBMIT QUALITY MEASURES FROM TABLE 4

23 SECOND SET: EPs TO SUBMIT INFORMATION ON AT LEAST ONE OF THE SETS LISTED IN TABLE 5 THROUGH 19 AS SPECALITY GROUPS Example: Table 5: Cardiology Specialty Measure Group

24 MU QUALITY MEASURES REPORTING The specific quality measures and reporting processes will differ in Stage 1 depending on Medicare or Medicaid incentive reporting EP or EH Characteristics of the EH or EP By year (submit summary for 2011 and details for 2012+) Must report EHR incentive clinical quality measures for all applicable cases, without regard to payer Specifications for how to submit quality measures will be released by July 1, 2011

25 STAGE 1 QUALITY REPORTING COMPLEMENTS BUT DOES NOT REPLACE EXISTING QUALITY REPORTING Eligible Hospitals ~7 overlapping measures Eligible Providers? overlapping measures Meaningful Use 35 Core Measures (RHQDAPU) ~38 Meaningful Use 4 core + specialty PQRI At least 3 Key Note Through at least Phase 1, EHs and EPs will need to address multiple Federal quality reporting programs with separate requirements and financial implications

26 SUBMITTING QUALITY MEASURES There are several potential routes to report quality information outlined in the proposed rules including: 1. Use the CMS portal to perform upload process based on specified structures and accompanying templates produced as output from your certified EHR module 2. Submit the required clinical quality measures data using certified EHR technology through Health Information Exchange (HIE) / Health Information Organizations (HIO) 3. Accept submission through registries This is dependent upon the future development of the necessary capacity and infrastructure to do so using certified EHRs Attestation on achieving meaningful use will be required as part of the submission Specifications for quality submissions will be developed by July 1, 2011

27 MU QUALITY COMPLIANCE STEPS (pg. 1 of 5) 1) Are you an eligible professional or hospital? EPs by law there are significant eligibility differences for providers between Medicare Vs. Medicaid eligibility so check both By law, hospital-based EPs who furnish substantially all their services in a hospital setting are not eligible for incentive payments. There are a lot of questions around how this will be defined which will likely trigger revisions / clarifications in the final rule EHs by law there are significant eligibility differences for providers between Medicare Vs. Medicaid eligibility so check both In general the Medicare eligibility rules are more inclusive then the Medicaid rules for hospitals Key Note It is possible to be a Eligible Professional or Hospital under Medicare, Medicaid, both or neither. So check carefully!

28 MU QUALITY COMPLIANCE STEPS (pg. 2 of 5) 2) Assess the financial implications Costs of complying vs. incentives & eventual penalties o The calculations for incentive payments under Medicare and Medicaid are different. Don t forget to figure your payments under both! When you plan to demonstrate meaningful use? o It is possible to demonstrate Phase 1 compliance as late as 2014 and still receive incentive payments! Determine Medicare, Medicaid or Both o For EPs determine Medicare vs. Medicaid incentive decision o For EHs hospitals may qualify to receive payments from both the Medicare and Medicaid EHR incentive programs To quote a wise CEO: This is not another un-funded federal mandate; it is just an under-funded one!

29 MU QUALITY COMPLIANCE STEPS (pg. 3 of 5) 3) Form a team to focus on implementation and roll out Clinical, technical and process resources need to be on the team. - Make sure you include team members who work on / understand P4R, P4P, PQRI, Core Measures, and RHQDAPU Empower the team to drive process changes needed to comply 4) Determine which measures will be reported to whom and if any currently being reported [Current State] Do not assume the measures specifications to be published later this year will exactly match your existing programs even if you already capture and report a quality measure additional work may be needed to achieve EHR meaningful use

30 MU QUALITY COMPLIANCE STEPS (pg. 4 of 5) 5) Assess patient flow and integrated information input assessment, including provider layout and placement of computer terminals Where are we going to electronically capture With What system(s) are we going to electronically capture 6) Determine path to certify your relevant EHRs / EHR Modules Will you leverage vendor(s) or pursue internal system certification? Given the overlap of quality measures reporting between multiple federal programs and the goal to harmonize the measures over time consider options to expand existing quality reporting tools vs. implementing new ones

31 MU QUALITY COMPLIANCE STEPS (pg. 5 of 5) 7) Identify detailed data input requirements to fulfill measure specifications [What] Specifications are to be released by April 1, ) Pilot test the entire process internally and establish internal tracking and reporting systems Don t assume your certified EHR module will capture and report out the needed data verify it for yourself! Revise your internal management quality reporting processes to include MU metrics and compliance tracking Specifications for how to submit your data to be released by July 1, 2010

32 Given the rules are not finalized, specifications are not yet published and official certification of EHRs/modules will not occur until later this year What should we be doing right now? Understand your eligibility and get knowledgeable about the measures / metrics that are applicable to you Evaluate your workflows in relation to capturing measures and talk with your relevant vendors about their plans to support MU Submit your comments /questions to CMS regarding the NPRM and IFR

33 DRIVING TO ACHIEVE RESULTS Payment Infrastructure (Information Technology & Workforce) Accreditation & Certification COLLABORATIVE, ACTION-ORIENTED STRATEGIES Performance Measurement Research & Information Dissemination Public Reporting

34 ADDITONAL RESOURCES HIMSS: ONC: includes a link to electronically submit your comments Link to the Federal Register MU NPRM:

35 CONTACT INFORMATION Louis Diamond