Dear Tony Trenkle:

We haven’t ever met and I know you must be a busy man. Especially with all eyes on your office as you develop the meaningful use definition. I feel compelled to throw in my two cents. I’ve got a feeling I’m not the only one, but here goes.

Please don’t create another quality measures reporting program. CMS already has quality measure reporting programs for eligible professionals (PQRI) and for hospitals (RHQDAPU which we all call The Core Measures).
Instead, enable those programs for “reporting from an EHR” first.

Then, add more quality measures. Do make sure those are enabled for “reporting from an EHR” and vetted, of course, through the established channels.

Definitely don’t ask us to report new quality measures before there are specs for EHR reporting. That was clearly not the intent of congress when they added that part about the Secretary not requiring electronic reporting of information on clinical quality measures unless the Secretary has the capacity to accept the information electronically. I don’t think they meant keying in some data on a website.

If you insist on quality measures in Stage 1, couldn’t you just use satisfactory reporting through the existing programs while you get the “reporting from an EHR” part worked out?

By the way, can you define “reporting from an EHR” a little better? Does that mean that every element of the quality measure has to be in a data field in the EHR? In a standard format? I’m sure you already know this – but there are large gaps in the standards necessary for quality measure reporting from an EHR. For example, allergies, exclusions, patient level education and communication are missing or inadequate for quality reporting. And, the standards that are approved, those aren’t fully implemented.

Does registry reporting count? If the data is interfaced or extracted from the EHR and submitted by a registry, is that “reporting from an EHR?”

On to something else: CPOE. 10% for hospitals? Eeek. That seems a bit low, but whatever. It’s easy for us to say since we implemented CPOE back in 2003. But, the part about the nurse, what’s that? If a physician calls in an order and the nurse enters it, does that count?

On the other side of the coin, 80% for eligible professionals is awfully high if that means the physician has to physically do the entry. In our clinics, for example, we ask the nurses to review health maintenance with patients during intake. “Ma’am, I see you are due for a mammogram. Would you like for us to schedule that while you are here today?” That suggested order is accepted and queued for the physician’s signature. Does that count as CPOE, or not?

Moving on to some of those other measures. How the heck are we supposed to get the denominator for the ones where they include items NOT in the EHR? For labs, if we get a paper result that includes a CBC and an A1c, is that one? Or two?  Or 22? Are we supposed to count the pages of paper?!?!?

And finally, won’t that lab measure encourage duplication. If the EP is penalized for having paper results and the patient brings one in, what’s the EP to do? “Sorry, lady, that will count against me for meaningful use. I’ll have to redo that lab test using my interfaced lab so the result will go into my EHR. I know it sounds crazy, but it is worth $44,000 to me.”

As I said, I know you must be busy. Thanks for taking the time to listen.