Eligible professionals and hospitals that purchase and implement EHR systems are entitled to financial incentives to the extent that they can demonstrate "meaningful use" of these systems. CMS recently announced that during 2012, those participating in this program could continue to use attestation rather than direct electronic reporting to report clinical quality measure (CQM) results for that year.
Under its July 2010 Final Rule, CMS permitted eligible professionals and hospitals (Submitters) to use attestation to submit summary information on CQM to demonstrate meaningful use of certified EHR technology for the 2011 payment year. To attest, Submitters must log into the CMS Medicare & Medicaid EHR Incentive Program Registration and Attestation System, fill in numerators and denominators for the meaningful use objectives and CQMs, and legally attest that they have successfully demonstrated meaningful use. Generally, a complete EHR system will provide a report of the numerators, denominators and other information needed to attest.
However, for 2012 and future payment years, the Final Rule required that Submitters electronically submit CQMs to CMS as calculated by their certified EHR technology by uploading the data through a CMS-designated portal. The Final Rule also required that the certified EHR technology calculate the CQM results and transmit this information under the Physician Quality Reporting Initiative (PQRI) Registry XML specification.
In two Proposed Rules issued in mid-July of this year, CMS acknowledged what many in the industry argued: "that it is not feasible to receive electronically the information necessary for clinical quality measure reporting based solely on the use of PQRI 2009 Registry XML Specification content exchange standards as is required for certified EHR technology." The data elements required for the 2009 PQRI Registry submission are not well suited to allow compliance with the Final Rule. As a result, CMS has postponed the need for program participants to use direct electronic reporting of CQM results until 2013.
CMS also proposed a voluntary pilot program for the 2012 payment year through which the Submitters may report CMQs electronically using their certified EHR technology. However, CMS did not provide any financial incentives to participants in this pilot program.
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