Meaningful Use Attestation and CQM Reporting

Electronic Submission of CQM for Meaningful Use

It is there in black and white on page 68 of the Final Rule “Therefore, for the Medicare EHR incentive program beginning in CY 2012 we proposed that an EP using a certified EHR technology or beginning in FY 2012 an eligible hospital or CAH using a certified EHR technology, as appropriate for clinical quality measures, must submit information on clinical quality measures electronically…”.

We knew that for 2011 for the purpose of meeting Stage 1 Meaningful Use standards we could attest the clinical quality measures by simply inputting numbers during the web based attestation process (Final Rule: “Therefore, for 2011, we proposed that Medicare EPs, eligible hospitals, and CAHs use an attestation methodology to submit summary information to us on clinical quality measures as a condition of demonstrating meaningful use of certified EHR technology, rather than electronic submission.”).

Long ago, in the early days of 2011 we knew that we didn’t have to worry about electronic submission but in the back of our minds we kept thinking about the requirement that electronic submission would be required in 2012. Electronic submission in 2012? How is that going to work? All we could do was shrug our shoulders hoping somebody would figure it out.

The wisdom of the Final Rule did provide an escape clause to the mandated 2012 electronic submission of clinical quality measures: “We stated in the proposed rule that should we not have the capacity to accept information on clinical quality measures electronically in 2012, we would inform the public of this fact by publishing a notice in the Federal Register and providing instructions on how this information should be submitted to us.”

And that is exactly what happened. The escape hatch opened and we all crawled through. Neither CMS, EHR vendors, nor providers were ready for electronic submission and so for 2012 we have the option of participating in an electronic reporting pilot program or attestation. CMS has advised: ” EPs, eligible hospitals, and CAHs that choose not to participate in the pilot will be able to continue to use an attestation methodology for reporting CQMs for payment year 2012.”

We better not get too dependent on these escape hatches. Somewhere down the road we are going to have to really do this, and it might be called Stage2.

Jim Tate is a nationally recognized expert on the CMS EHR Incentive Program, certified technology and meaningful use and author of The Incentive Roadmap® The Meaningful Use of Certified Technology: Stage 1.