HIT Standards Committee Clinical Quality Workgroup Comments & Discussion on the Notice for Proposed Rule Making (NPRM) Electronic Health Record Incentive.

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HIT Standards Committee Clinical Quality Workgroup Comments & Discussion on the Notice for Proposed Rule Making (NPRM) Electronic Health Record Incentive Program and the Interim Final Rule (IFR) on Initial Set of Standards, Implementation Specifications, and Certification Criteria for EHRs Janet Corrigan, National Quality Forum Floyd Eisenberg, National Quality Forum February 24,

2 Clinical Quality Workgroup Members Janet Corrigan, Chair, National Quality Forum Floyd Eisenberg, National Quality Forum John Derr, Golden Living, LLC Judy Murphy, Aurora Health Marc Overhage, Regenstrief Rick Stephens, Boeing James Walker, Geisinger Jack Corley, HITSP John Halamka, Harvard Medical School

Workgroup members were asked to respond to two specific questions: –NPRM – review of measures listed with respect to those recommended by the Standards Committee –IFR – review adequacy of IFT standards to support the requirements of measures in the NPRM Review Process 3

90 Unique Ambulatory Measures 43 Unique Hospital Measures List includes 15 of the 17 measures recommended by the Standards Committee –NQF # 0097 – Medication Reconciliation –NQF # 0489 – The ability for providers with HIT to receive laboratory data electronically directly into their qualified / certified EHR system as discrete searchable data elements Replaced by metrics for EHR reporting for reporting of exchange of clinical information, medication reconciliation and summary of care records, among others. Recommendations – Some concern about granularity of the metrics listed for EHR exchange of information. NPRM Review 4

Specialties were addressed by the list of measures in the NPRM NPRM Review 5 Core3 Cardiology10 Endocrinology9 Gastroenterology6 Nephrology6 Neurology5 Ob/Gyn9 Oncology6 Ophthalmology3 Pediatrics9 Podiatry3 Primary Care29 Psychiatry6 Pulmonology8 Radiology7 Surgery/Procedures6

Concerns: –Medication allergy list No standard in UNII is listed as a candidate Stage II vocabulary. UNII describes allergies at the drug component level and not at the drug level. The Operations Workgroup of the Standards Committee specifically suggested allergies at the drug level. The component level is problematic for the near or mid-term if not the long term. Recommendations: –A medication allergy standard is required for quality measurement in This should be at the drug, not the component level. IFR Review 6

Concerns: –Vital signs – No standard vocabulary is adopted for Stage 1 (2011) CDA template is a candidate for Stage 2 Required for measures identified in the NPRM: –Vital signs, especially blood pressure –Body mass index (and percentile) –A vocabulary for vital signs and findings is therefore needed to compute the measures in a standard manner. Recommendations: –A vocabulary standard for vital signs and clinical findings is required for quality measurement in LOINC has been suggested in prior work of the Standards Committee. IFR Review 7

Concerns: –Units of Measure No units of measure are indicated in Stage 1 UCUM is a candidate standard for Stage 2 Standard units of measure are required to consistently calculate measures that require laboratory results, medication dosages, vital signs and observations. Recommendations: –Units of measure standards are required to consistently calculate quality measures for Stage 1. UCUM has been suggested previously by the Standards Committee and will add value. IFR Review 8