HIMSS Recommends Incentives for Hospital Participation in Quality Measure Testing in CMS IPPS Proposed Rule Response

In a move to improve patient safety, the Centers for Medicare and Medicaid Services (CMS) recently released CMS 1785-P, the Inpatient Prospective Payment System 2024 proposed rule. It includes proposals to introduce three new electronic clinical quality measures (eCQMs) to the CMS Inpatient Quality Reporting Program.

These new steps looks to boost patient safety by focusing on the reduction of acute kidney injuries and patient falls; and while preserving image quality, discourage unnecessarily high radiation doses, a risk factor for cancer.

Healthcare and Information Management Systems (HIMSS), in a public comment letter submitted to CMS on June 9, 2023, called on CMS to identify new strategies to incentivize end-user participation in real-world testing for new eCQMs. HIMSS is a global advocate for digital health transformation. HIMSS also recommended CMS use the convening power of the agency to identify common clinical quality measures with private payers and accreditation bodies to eliminate duplicative reporting burden. The key points of the HIMSS response include:  

• HIMSS applauds CMS adoption of an 18-month implementation period for the inclusion of new eCQMs to CMS reporting programs. In past public comments, HIMSS indicated that on average, healthcare stakeholders needed 18 months from the moment that a new measure’s specifications and code sets are available to implement the measure within clinical workflow. That time is necessary to collect the data in a manner to produce comparable and consistent results with the measure’s intent. This policy by CMS ensures more accurate and actionable quality data will be available to hospitals to improve care.

• HIMSS applauds CMS for publishing data on the number of testing sites and participating electronic health record (EHR) developers; and evaluate their performance on each proposed new measure as part of the proposed rulemaking.

• The testing data shared by CMS highlights a larger challenge -- the lack of enough participants for testing to ensure eCQMs would generate comparable, consistent, and accurate measures of clinical care quality upon national implementation. Each proposed measure was tested using two EHR at most at less than 25 hospitals. HIMSS shared that hospitals and health systems often have unique configurations despite using the same EHR, resulting in significant variation in clinical documentation workflows from one EHR to another and from one healthcare organization to the next.

• At the moment, there isn’t a strong business-sense argument for some health facilities to participate in an eCQM real-world testing. This is especially true for safety nets and small hospitals that would need to devote significant resources (i.e., fulltime staff with expertise on CQL, data and terminology standards, Clinical/EHR workflows, data capture, mapping to local codes and data quality).

• HIMSS strongly recommends CMS ensure a larger cohort of real-world testing sites for eCQMs, including all potential EHR developers, and both large and small hospitals across a wide geographic and patient demographic spectrum. To ensure a higher level of participation, HIMSS recommend CMS adopt significant scoring bonuses to the Inpatient Quality Reporting (IQR) program for hospitals participating in measure testing. HIMSS further recommends CMS allocate sufficient funding facilitate testing, mapping, and implementing work for field testing at sites for measure development and testing contracts.

• Most of the burden from quality measure reporting for hospitals stem from duplicative reporting requirements for federal, state, private payer, and accreditation bodies. The proposed rule includes several steps where the same measure must be captured with different numerators and denominators the to meet state and private payer requirements.

• To mitigate these burdensome quality reporting challenges, HIMSS recommends CMS leverage the agency’s convening power to improve the alignment of clinical quality measures and reporting requirements across payers, accreditation bodies, and the federal government.

HIMSS is encouraged by CMS’ proposed steps to improve the accuracy and actionability of clinical quality reporting data.

Using wide ranging data sources in the future, CMS will continue its transition to reporting digital quality measures (dQMs), and HIMSS welcomes an ongoing dialogue with the agency to make federal clinical quality reporting more accurate and meaningful – all to drive improved care delivery and less burdensome data collection and reporting.