In the MIPS Final Rule, CMS points out the legislative direction received from congress to encourage adoption of the new QCDR participation. And in fact, CMS does so.
The "encouragement" is limited to providing one or two CPIA (Clinical Practice Improvement Activities) as a reward. This appears to be a hollow encouragement, given the ease with which providers can comply with CPIA apart from Quality. See our blog on the topic, titled "CPIA looks deceptively simple. What's the catch?"
There is a bigger incentive, on a different Quality Submission method, which could open the door to easier, competing options. CMS is encouraging "End to End CEHRT" submission, by providing bonus points to providers selecting this technique. Remember in a prior article how we identified Quality as the biggest differentiator? In essence, extra points on Quality can boost a provider ahead of competitors for MIPS Funding more decisively than any other category scoring.
End to End CEHRT Submission requires that Qualilty data is obtained from CEHRT using ONC Adopted Standaards, and the Qualified Registry, QCDR or other HIT vendor electronically performs aggregation, calculation, filtering and reporting. This sets up creation of CQM data without human intervention, based completely on EHR data.
Potentially, this seems to qualify all methods for End to End CEHRT. However, in those cases where CEHRT data is good enough to qualify for the end to end bonus, what is the "value added" of additional (QCDR or Registry) software tools? Under the new regulations, providers could simply submit data directly from CEHRT, similar to current Meaningful Use Batch Attestation.
It begs a new question. If Quality data can be submitted from EHR directly, what is the value of big investments in third party software that reads cllinical data to create CQM content just to send off to CMS, or to a registry?
Download our annotated copy of the MIPS Rule, and navigate to page 28256, where this topic is clearly highlighted. Then start analyzing your own expenditures on CQM generation tools.