Collaborating to Meet the Challenge of PQRS EHR-Based Reporting

Transcription

1 Collaborating to Meet the Challenge of PQRS EHR-Based Reporting The Centers for Medicare & Medicaid Services (CMS), as part of its current improvement initiatives, has charged the Quality Improvement Organizations (QIOs) with assisting eligible professionals (EPs) using an electronic health record (EHR) to participate in the 2012 Physician Quality Reporting System (PQRS) incentive program. This requires providers to submit their PQRS data using an EHR-based method either EHR-direct or via a data-submission vendor (DSV). Quality Insights of Delaware, the QIO for the First State, also serves as the Regional Extension Center. This paper describes the collaboration between Quality Insights of Delaware Regional Extension Center (QIDE REC), Mingle Analytics (a CMS-qualified DSV) and 12 Delaware practices to submit PQRS data on behalf of 51 eligible professionals for the 2012 reporting year. QIDE REC recruited EPs and determined their readiness for submission of three PQRS prevention measures to CMS: #110 Influenza Immunizations, #111 Pneumonia Vaccinations and #112 Screening Mammography. Background Quality Insights of Delaware initially worked with physician practices interested in using their current EHR system with a CMS-qualified EHR-direct vendor to submit for the 2011 and 2012 PQRS reporting years. Due to numerous barriers in that process, including the vendor choosing not to pursue qualification in 2012, Quality Insights had to change its recruitment strategy and seek out other EHR-direct options for Many of the 2012 qualified EHR-direct vendors were not ready in for the process in 2012 and thus encouraged EPs to submit via a registry. That left many practices in Delaware without an option to use EHR-direct submission since their EHR vendor had not been qualified. In 2012, CMS proposed another viable EHR-based method of PQRS submission the qualified PQRS DSV. This would meet the needs of a broader range of practice in Delaware. The DSVs were able to work with different EHR products or versions and with differing technical and clinical support requirements. 1

2 Vendor Selection and Recruitment Process In August of 2012, when the DSV list was released, Quality Insights of Delaware and QIDE REC went into high gear to recruit 24 EPs, as required by the QIO initiative with CMS. EPs consented to participate and the Quality Insights assisted in finding the most cost-effective vendor to meet the needs of the practices. Recruiting Challenges Challenges to recruiting eligible professionals included: 1. Many practices had already been successful using claims or registry submission and did not want to change their method of submission simply because there was a new alternative. 2. Not all vendors were interested in the PQRS program at the time. 3. The DSV option was new in The qualified DSV list was not released until August 3, Before participating, practices needed to know the associated costs. Getting pricing and other information necessary to select a DSV was a time-consuming process. Few practices had the resources to collect the information to make an informed decision. 5. A review of the qualified vendors revealed that many DSVs, though on the qualified list, were not ready to accept clients, did not have the information necessary for practices, were prohibitively expensive or had a waiting list. DSV Selection Quality Insights QIO researched all DSVs on the CMS-qualified vendor list to get pricing, ability to report via specific EHRs and timing of the availability of their product. Criteria for DSV Selection After reviewing all vendors by mid-october, Quality Insights made the decision to use the following criteria to select DSVs for EPs to submit their data: DSVs ready for deployment in DSVs that were responsive to phone calls and questions and would help with the process, one EP at a time. Compatibility between DSV and EHR in use by a large-enough cohort of practices in Delaware. Affordable for small practices. 2

3 DSV Selection Result Mingle Analytics was the only DSV that met all of the selection criteria. Recruitment Approach Once the DSV was identified, Quality Insights and QIDE REC used the following approach to recruit practices: 1. Identified a pilot site to work with Mingle Analytics to develop processes that could be rolled out to the other sites. The pilot site EHR was Allscripts Pro, which was an SQL data base. Mingle Analytics had experience with SQL reporting from Allscripts databases. Mingle Analytics reduced their fee for this pilot practice. 2. Identified additional practices with the same EHR as the pilot site. 3. Visited practices, in tandem when possible, with a QIDE REC representative. This approach allowed providers to see how both organizations could help them use health information technology for quality improvement projects. 4. Educated the EPs about the PQRS DSV option and gained consent to participate in the program. 5. Arranged conference calls and sometimes one-on-one calls between Mingle Analytics and the EPs to determine if they were capable of PQRS reporting through their EHR and if data could be exported using this DSV. Recruitment Result Quality Insights contractual responsibility was to recruit 24 EPs for PQRS EHR-based submission by the end of November Due to the difficulty of the task, Quality Insights planned for attrition and recruited 28 EPs altogether. An additional 23 EPs showed interest in the project and signed up for assistance. All but one practice shared the same EMR; some had different practice management (PM) systems. The different PM systems included Allscripts Pro PM, Mysis PM, and one practice was transitioning from a Legacy PM to Allscripts Pro. Submission Preparation Reports Once the practices were recruited, Quality Insights and QIDE REC built data reports in the EMR of each practice for each PQRS prevention measure. This data was monitored for quality improvement and to ensure the correct demographics, CPT, HCPS, and procedure codes were being captured in the EMR in preparation for PQRS reporting. 3

4 Starting in November 2012, Quality Insights and QIDE REC generated the first monthly data reports for each practice and entered them into the CMS Internal Quality Control database for analysis of each measure, data accuracy and improvement. Progress reports were sent to each EP to provide feedback regarding their data and to implement techniques for quality improvement. Data Planning CMS requires PQRS data to be delivered using a specific standardized HL7 data-submission format using Quality Reporting Document Architecture (QRDA) XML, which is an emerging capability of EMR systems. A full and accurate QRDA submission requires demographic and visit data that determines patient eligibility for the measures and clinical information to determine the performance for each measure. Continuity of care documents (CCDs), like QRDA, are an HL7 data exchange standard. CCD focuses on data for clinical use where QRDA is focused on data for quality measurement. CCDs are used in health information exchange (HIE) and are a valid starting point to build a QRDA. After testing the ability of the recruited practices to deliver either CCDs or QRDA files, Mingle Analytics and QIDE REC looked for an alternative method to collect eligibility and clinical data. Their approach was to determine, in each case, the most cost-effective way to receive data working within the technical capabilities of the client and the data delivery capabilities of the EMR. Their method was to collect demographic data from the PM system and clinical data from the EMR, either through reports or direct access to the database. Permission to Submit In order to submit the data, the vendor has to have permission from the eligible professional. Quality Insights worked with Mingle Analytics to ensure the permissions were collected and the TIN/NPI was verified since the wrong TIN and NPI information is one of the biggest reasons EPs do not earn incentives. 4

5 Reporting Barriers CCD records generated by the EMR systems were often incomplete. EMRs could only generate a single CCD at a time. They did not have the ability to generate multiple CCDs for a range of eligible patients. The QRDA output recoverable from systems proved, in all cases, to be incomplete. Either the clinical data or provider and practice identifiers needed to accompany the data were missing and sometimes both. On the PM side, in addition to the practices using a variety of PM systems, there were also different hosting solutions and types of databases. None of the systems had sufficient reporting capability to deliver the PM data using a canned report. The EMR-based reports that Quality Insights and QIDE REC had built did not include all the information needed to report the clinical data for PQRS purposes. In the case of Measure #110, the report could not deliver the date given for the flu shot. The vendor confirmed that this piece of information could not be reported through their reporting module without incurring significant additional cost. In some cases, hosting vendors would not grant access to Mingle Analytics or QIDE REC for direct reporting from the PM or EMR using SQL. In other cases, the PM system was not SQL-based and would have required the practice to purchase an additional module to be able to query and report from it directly. Even though most participants used the same vendor for their EMR, where and how the EMR was hosted made a big difference in gaining access to the database. Some hosting vendors granted access very easily, others only after a long struggle and repeated requests. Reporting Solution For the pilot practice, Mingle Analytics was given remote access to the Allscripts Pro PM and EMR databases to identify the tables and columns with the PM and EMR data necessary to report. Using this information, the team found that one of the practices was able use Excel with an Open Data Base Connection (ODBC) to their Allscripts Pro database to build the PM and EMR reports. Quality Insights and QIDE REC helped document the method and share it among participants. Starting in January, Quality Insights and QIDE REC held weekly Learning and Action Network (LAN) Webinars for all of the participating practices and Mingle Analytics. The purpose of creating the LAN was for all participants to share barriers, solutions and best practices. Participants were provided with education, support in dealing with hosting vendors and technical assistance via screen sharing. Quality Insights and QIDE REC staff provided onsite visits to the practices to assist with the process of data extraction. 5

6 Final Results Through LAN collaboration, 100 percent of the original practices that committed to DSV PQRS submission successfully submitted their data. That amounted to 43 eligible professionals from seven practices. Eight eligible professionals from the remaining five practices successfully made registry submissions using measure groups. Lessons Learned The QIOs can be a valuable resource to small practices by acting as an intermediary between the practices and the PQRS vendor community. QIOs assisting practices by working side-by-side with the DSV was imperative for finding solutions to database limitations and meeting the requirements for PQRS data delivery to CMS. The Learning and Action Network provides a platform for peer sharing and problemsolving, which are the vital ingredients to successful PQRS submission. Participants in the project gained valuable insight into the importance of access to their EMR data. The EMR vendor has much development work to do to make EMR data readily accessible for quality improvement reporting. Quality Insights and QIDE REC collaboration promotes credibility with the providers for both CMS incentive programs and the importance of health information technology. This process has presented an opportunity to spread the success and lessons learned to all QIOs through the CRISP model. This material was prepared by Quality Insights of Delaware, the Medicare Quality Improvement Organization for Delaware, under contract with the Centers for Medicare & Medicaid Services (CMS), an agency of the U.S. Department of Health and Human Services. The views presented do not necessarily reflect CMS policy. Publication Number: 10SOW-DE-IHPC-AF App.6/13