Comment on FR Doc # 2012-04430

Regarding CQM Certification Criteria Data Capture in III.A.5.a: There is a great deal of discussion in the proposed rule regarding the gap between current CQM specifications and current EHR capabilities, and potential methods for resolving this gap. To reiterate, even fully Certified EHRs currently cannot accurately capture each and every data element required by the CQMs, and some degree of manual chart abstraction is required for results to be 100% accurate. Among the several potential approaches described, the most likely to be successful would the creation of the “style guide” to identify data types that could reasonably be expected to be captured. The measure stewards would then limit CQMs to those that can be constructed using only these data types. Please note however, that it is not sufficient that these data types be captured in the Certified EHR – it is critically important that that the style guide exclude data types that may be captured in the EHR but that may also be captured elsewhere. The greatest challenge for the CQMs is not that the data cannot be captured in the EHR but rather that additional paper or free text notes may contain additional or conflicting information. Until HIEs are fully functional in all regions and transfer patients do not arrive with any paper documentation whatsoever, there is always the possibility of a contradictory note in the paper chart. Even when all facilities are fully electronic and fully networked, free text is unlikely to be entirely eliminated, as there will always be new, unique clinical scenarios that occur that were not anticipated in the design of discrete fields in electronic notes. It is likely that some degree of manual abstraction will always be required, though of course this should become minimal. It will defeat the purpose of quality reporting, however, if reported measures are not 100% accurate based on the ENTIRE medical record, discrete, non-discrete, and paper.