Tables 55 & 56: Measures Available for EHR Reporting

The AMA commends CMS for expanding the measures available for EHR reporting and specifically supports inclusion of PCPI measures for EHR reporting.

Tables 57-69

The AMA supports the continued inclusion of the proposed measure groups for PQRI 2011.
Tables 55 & 56: Measures Available for EHR Reporting

The AMA commends CMS for expanding the measures available for EHR reporting and specifically supports inclusion of PCPI measures for EHR reporting.
Tables 57-69
The AMA supports the continued inclusion of the proposed measure groups for PQRI 2011.
Table 70: Proposed Measures for the Asthma Measures Group

The AMA supports the proposed addition of an Asthma Measures Group. However, the measures proposed for inclusion in the Asthma Measures group do not lend themselves to a measures group, due to the fact that measures #53 and #64 are for the ambulatory setting, and the two new proposed measures (Assessment of Asthma Risk and Asthma: Discharge Plan) are for use in the ED or inpatient settings only. Because of the variation in care setting among the measures, the AMA does not recommend these four measures be included in a measures group. One alternative would be to consider the following measures for individual reporting (claims, registry) and for the Asthma Measures Group that were submitted to CMS for consideration during the “Call for Measures for PQRI 2011”:
•    Asthma: Tobacco Use- Screening -Ambulatory Setting.
•    Asthma: Tobacco Use- Intervention -Ambulatory Setting.
In addition to the measures that were proposed for PQRI 2011, we respectfully request that CMS consider the following measures for inclusion in the PQRI 2011 program:
These measures were submitted to CMS for consideration during the call for measures, but were not included in the measures proposed for PQRI 2011. All three of these measures are being recommended for NQF Endorsement:
•    Otitis Media with Effusion: Antihistamines or Decongestants- Avoidance of Inappropriate Use.
•    Otitis Media with Effusion: Systemic Microbials- Avoidance of Inappropriate Use.
•    Otitis Media with Effusion: Systemic Corticosteroids- Avoidance of Inappropriate Use.

The AMA urges publication of detailed specifications for individual measures and measures groups by November 15, 2010. The agency has until December 31, 2010 to post detailed measure specifications. To ensure physician practices have the requisite time to identify clinically relevant measures and understand their specifications before day one of the program (January 1, 2011), detailed measure information must be posted by November 15, 2010.
Qualification Requirements for EHR Vendors and Products
CMS proposes that previously qualified vendors and new vendors will be required to incorporate any new EHR measures (measures electronically-specified) added to the PQRI for the reporting year in which they wish to maintain their PQRI qualification. Vendors must also update their electronic measure specifications and data transmission schema, should either or both change. The AMA urges that CMS work to align measure specifications across programs and vendors, so that physicians feel comfortable with their ability to accurately and consistently report quality measures.

The AMA applauds CMS’ decision to reduce the reporting sample requirement from 80 percent to 50 percent for FY 2011. At the December 17, 2009, Practicing Physicians Advisory Council meeting, CMS discussed the PQRI reporting rate threshold options and presented data on the potential impact of a modified reporting threshold. According to the presentation, 82 percent of PQRI TIN/NPI participants in 2008 reported on at least 50 percent of their patient cases for at least one measure. CMS estimates that if a 50 percent reporting threshold had been applied for 2008, approximately 66 percent of PQRI TIN/NPI participants would have been incentive eligible. AMA also urged CMS, in a letter dated April 30, 2010, to use its authority to establish a 50 percent threshold for successful participation, as it would better reflect the current realities of the PQRI reporting environment for participating physicians. The AMA urges CMS to also use its existing authority to apply the new 50 percent threshold retrospectively to the 2010 reporting year.
For registry-based reporting in 2011, in contrast to prior program years, CMS proposes to require that the minimum patient numbers or percentages must be met by Medicare Part B fee-for-service patients (FFS) exclusively and not non-Medicare Part B FFS patients. The rationale for this is the difficulty of analyzing data CMS receives from registries, which include patients other than Medicare Part B FFS patients. The AMA understands that the requirements for registries to be considered “qualified” include the ability to separate out and report on Medicare Part B FFS patients. The same requirement exists for qualified EHRs. If CMS requires that the minimum patient numbers or percentages be met by only Medicare Part B FFS, many specialties may not be able to meet the minimum patient numbers to be considered a successful PQRI participant. For hospital reporting, CMS receives data from all payers, which indicates that CMS should be able to capture data on both Medicare Part B FFS and non-Medicare Part B FFS. Limiting the patient population will skew the results for some physicians depending on their patient population and severely limit the value of the results for quality improvement and payment incentive. As a result, PQRI participation may be viewed as a “regulatory requirement” by physicians instead of a tool to support quality improvement.

CMS proposes that qualified registries use “PQRI measure specifications and the CMS- provided measure calculation algorithm to calculate reporting rates or performance rates …if aggregated measures data is continued for 2011 PQRI registry reporting.” The AMA recommends that CMS involve the measure developers who maintain the measures included in the PQRI program in this process. This will ensure that the calculation of algorithms, including performance and exception (exclusion) rates are calculated consistently with the intent of the measure as originally developed and subsequently endorsed by the NQF. CMS should work with measure developers, such as the AMA-PCPI, to solicit feedback on program algorithms.

Throughout the proposed requirements for registries, CMS refers to the submission of numerator and denominator data. The AMA recommends that exception data be added as a requirement and that registries be required to report to CMS a physician’s numerator, denominator, and exception data. The addition of exception data is consistent with the approach included in the Final Rule for Stage 1 of the CMS EHR Incentive Program (meaningful use).

Proposed Measures for the Asthma Measures Group

The AMA supports the proposed addition of an Asthma Measures Group. However, the measures proposed for inclusion in the Asthma Measures group do not lend themselves to a measures group, due to the fact that measures #53 and #64 are for the ambulatory setting, and the two new proposed measures (Assessment of Asthma Risk and Asthma: Discharge Plan) are for use in the ED or inpatient settings only. Because of the variation in care setting among the measures, the AMA does not recommend these four measures be included in a measures group. One alternative would be to consider the following measures for individual reporting (claims, registry) and for the Asthma Measures Group that were submitted to CMS for consideration during the “Call for Measures for PQRI 2011”:

•    Asthma: Tobacco Use- Screening -Ambulatory Setting.
•    Asthma: Tobacco Use- Intervention -Ambulatory Setting.
In addition to the measures that were proposed for PQRI 2011, we respectfully request that CMS consider the following measures for inclusion in the PQRI 2011 program:
These measures were submitted to CMS for consideration during the call for measures, but were not included in the measures proposed for PQRI 2011. All three of these measures are being recommended for NQF Endorsement:
•    Otitis Media with Effusion: Antihistamines or Decongestants- Avoidance of Inappropriate Use.
•    Otitis Media with Effusion: Systemic Microbials- Avoidance of Inappropriate Use.
•    Otitis Media with Effusion: Systemic Corticosteroids- Avoidance of Inappropriate Use.
The AMA urges publication of detailed specifications for individual measures and measures groups by November 15, 2010. The agency has until December 31, 2010 to post detailed measure specifications. To ensure physician practices have the requisite time to identify clinically relevant measures and understand their specifications before day one of the program (January 1, 2011), detailed measure information must be posted by November 15, 2010.

Qualification Requirements for EHR Vendors and Products

CMS proposes that previously qualified vendors and new vendors will be required to incorporate any new EHR measures (measures electronically-specified) added to the PQRI for the reporting year in which they wish to maintain their PQRI qualification. Vendors must also update their electronic measure specifications and data transmission schema, should either or both change. The AMA urges that CMS work to align measure specifications across programs and vendors, so that physicians feel comfortable with their ability to accurately and consistently report quality measures.

The AMA applauds CMS’ decision to reduce the reporting sample requirement from 80 percent to 50 percent for FY 2011. At the December 17, 2009, Practicing Physicians Advisory Council meeting, CMS discussed the PQRI reporting rate threshold options and presented data on the potential impact of a modified reporting threshold. According to the presentation, 82 percent of PQRI TIN/NPI participants in 2008 reported on at least 50 percent of their patient cases for at least one measure. CMS estimates that if a 50 percent reporting threshold had been applied for 2008, approximately 66 percent of PQRI TIN/NPI participants would have been incentive eligible. AMA also urged CMS, in a letter dated April 30, 2010, to use its authority to establish a 50 percent threshold for successful participation, as it would better reflect the current realities of the PQRI reporting environment for participating physicians. The AMA urges CMS to also use its existing authority to apply the new 50 percent threshold retrospectively to the 2010 reporting year.
For registry-based reporting in 2011, in contrast to prior program years, CMS proposes to require that the minimum patient numbers or percentages must be met by Medicare Part B fee-for-service patients (FFS) exclusively and not non-Medicare Part B FFS patients. The rationale for this is the difficulty of analyzing data CMS receives from registries, which include patients other than Medicare Part B FFS patients. The AMA understands that the requirements for registries to be considered “qualified” include the ability to separate out and report on Medicare Part B FFS patients. The same requirement exists for qualified EHRs. If CMS requires that the minimum patient numbers or percentages be met by only Medicare Part B FFS, many specialties may not be able to meet the minimum patient numbers to be considered a successful PQRI participant. For hospital reporting, CMS receives data from all payers, which indicates that CMS should be able to capture data on both Medicare Part B FFS and non-Medicare Part B FFS. Limiting the patient population will skew the results for some physicians depending on their patient population and severely limit the value of the results for quality improvement and payment incentive. As a result, PQRI participation may be viewed as a “regulatory requirement” by physicians instead of a tool to support quality improvement.

CMS proposes that qualified registries use “PQRI measure specifications and the CMS- provided measure calculation algorithm to calculate reporting rates or performance rates …if aggregated measures data is continued for 2011 PQRI registry reporting.” The AMA recommends that CMS involve the measure developers who maintain the measures included in the PQRI program in this process. This will ensure that the calculation of algorithms, including performance and exception (exclusion) rates are calculated consistently with the intent of the measure as originally developed and subsequently endorsed by the NQF. CMS should work with measure developers, such as the AMA-PCPI, to solicit feedback on program algorithms.

Throughout the proposed requirements for registries, CMS refers to the submission of numerator and denominator data. The AMA recommends that exception data be added as a requirement and that registries be required to report to CMS a physician’s numerator, denominator, and exception data. The addition of exception data is consistent with the approach included in the Final Rule for Stage 1 of the CMS EHR Incentive Program (meaningful use).