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In 2017, many wound care practitioners failed MIPS Quality Measures because the EHRs they paid good money for didn’t do their freaking job.
In 2017, the US Wound Registry (USWR) reported Merit Based Incentive Payment Program (MIPS) data on behalf of wound care practitioners and podiatrists using electronic health records (EHRs) from 22 different vendors. Those EHRs, which the practitioners and/or hospitals paid good money for, were supposed to be able to transmit quality measure data to a CMS-recognized registry. Registries like the USWR enable providers to participate in MIPS by transmitting quality measure data to CMS, among other responsibilities.  In this case, the measures we are talking about are standard, national measures like screening for tobacco use or high blood pressure.
There’s a basic set of quality measures (QMs) that nearly all wound care EHRs can report – or, at least, they are supposed to be able to report. Quality Measures are like exam test questions – everyone has to be presented with exactly the same test question or it’s not fair. The test questions are the “measure specifications” and they are updated each year (for example, the definition of “high blood pressure” keeps changing, for goodness sake). Whether a practitioner passes or fails a measure is determined by a lot of math – but you can’t report the measure without the details such as the number of patients who should have been considered in the measure and the number of patients who passed it.
Here’s what the USWR ran into:

  • 68% of EHRs had out-of-date quality measure specifications – that’s right, more than half the EHRs didn’t have current QM specifications for standard MIPS measures programmed into them – Why?
    • Because the EHR hadn’t updated its specifications
    • Because the doctor hadn’t updated to the latest version of the EHR (in some cases because this cost more money)
  • 32.5% of EHRs did NOT provide QRDA* files because:
    • The EHR was unable to generate a QRDA file (which is the data submission standard for reporting quality measures)
    • The EHR vendor was going to charge the provider for generating these files
    • The provider had to set up a “quality dashboard” within the EHR and had not done this
    • EHR vendor never responded to requests from the registry (so we have no idea whether they could have sent us the files).

Just to be clear, it was possible to pass a quality measure without a QRDA file, but what was happening is that doctors were having to take screen captures of the data coming out of their EHRs and then send us that photograph! We didn’t have access to the raw data and couldn’t check things for them, and this means that they also didn’t get the bonus money for “end to end” electronic reporting because there had to be a human in the middle inputting data by hand! How silly is that when the first word in “EHR” is “ELECTRONIC”?
Note that in several cases, the real problem was that there were hidden fees associated with submitting quality measure data – and we are talking about basic MIPS measures, not special QCDR measures. That is, the wound care EHR vendor was going to charge for updates. In other cases, it was the fine print the doctor didn’t know about, like NEEDING an update, or setting up a quality dashboard.
That doesn’t even begin to address the fact that the majority of EHR’s couldn’t or wouldn’t transmit Continuity of Care Documents (CCDs), which is the basic unit of exchange for healthcare data. And that’s not even the worst of it.
The worst of it are the number of wound care EHRs that just flat out refuse to transmit data to the registry on behalf of the providers that use them. In some cases the wound care EHR would agree to transmit CCDs, but only if the doctor paid an amount of money that was not reasonable. This is a particular barrier for hospital-based physicians, like those who work in hospital based outpatient clinics.
The 21st Century Cures Act was supposed to make data blocking illegal. The ONC is supposed to come out any day with its draft  policy to enforce this law, which I await with great anticipation.
*The Quality Reporting Document Architecture (QRDA) is the data submission standard used for a variety of quality measurement and reporting initiatives.

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