CMS Requests Comments on Redundant Reporting of Clinical Quality Measures

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CMS is seeking input regarding ways in which eligible professionals might use clinical quality measures (CQM) data reported to medical boards, specialty societies, regional health care quality organizations or other non-federal reporting programs to satisfy the requirements of the Physician Quality Reporting System (PQRS) and the Electronic Health Record (EHR) Incentive Program.  CMS is seeking this input to assess how alignment of certain requirements of both federal and non-federal CQM reporting programs could eliminate redundancies, thereby reducing the burden on eligible professionals and accelerating quality improvements.  Specifically, CMS is requesting comments on the following:

  • Similarities and differences between current PQRS and 2014 EHR Incentive Program reporting requirements and those already established for the American Board of Medical Specialties (ABMS), specifically those requirements that are duplicative and whether these reporting programs can be integrated;
  • Examples of other non-federal programs under which eligible professionals report quality measures data;
  • Benefits and shortcomings of allowing third-party entities to report quality data to CMS on behalf of physicians and other eligible professionals;
  • What entities have capacity to report quality data similar to those reported under PQRS, Value-Based Payment Modifier and/or EHR Incentive Programs, and what requirements CMS should include to ensure high quality data if these entities were to report such data to CMS; and
  • How CMS should change/evolve these quality reporting programs over time to reduce the reporting burden on eligible professionals while still receiving robust clinical quality data.

In addition to those high level areas, CMS is also seeking responses to specific questions regarding registry reporting requirements for entities that report via a registry under the PQRS for 2014 and subsequent years or the EHR Incentive Program if registry reporting is established as a reporting method for that program in future years.  For a copy of the February 7, 2013 Federal Register Notice, please click here

Reporter, Kerrie S. Howze, Atlanta, +1 404 572 3594, khowze@kslaw.com.

DISCLAIMER: Because of the generality of this update, the information provided herein may not be applicable in all situations and should not be acted upon without specific legal advice based on particular situations.

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