HIMSS Submits Comments on CMS Policies Related to Digital Quality Measures and TEFCA

On June 17, HIMSS submitted comments on the Centers for Medicare & Medicaid Services (CMS) Proposed Regulation on the Inpatient Prospective Payment System (IPPS), focused on the thoughtful transition to digital quality measures (dQMs) as well as how the agency should examine opportunities around the use of the Trusted Exchange Framework and Common Agreement (TEFCA) moving forward. 

HIMSS stressed support for dQMs and how, when properly implemented, they will enable more holistic and meaningful assessment of the health of patients, which potentially can also reduce provider burden. At the same time, HIMSS expressed concerns that while digital measurement represents an ideal future state, several critical barriers and challenges must be addressed to ensure that dQMs facilitate improved care and not add to the administrative burdens on providers.

The comment letter emphasized that CMS needs to ensure that any new quality measures utilize data to present a meaningful and actionable assessment of patient care. In addition, any new quality measure should be lab/simulation tested, field tested and validated to produce comparable and consistent results against the measure’s intent.

In response to the request for information included in IPPS, HIMSS expressed support for dQM data that drives effective process change without overwhelming clinicians. HIMSS also continued to support CMS efforts to create a common portfolio of clinical quality measures across private and public payers and strongly recommended that decisions around measure alignment be driven by the needs of clinicians and specialty societies, not only payers.  Moreover, the HIMSS letter encouraged CMS to continue engagement with stakeholders to address challenges with data validation, mapping, stewardship and security prior to the next round of rulemaking.

The correspondence also includes recommendations that CMS develop a strategy for providing a rapid feedback loop to eligible hospitals (EHs) and providers on measure performance, share clinical insights based on the nationwide data collection of dQMs and flexibility across the agency with the deadline for launching dQMs.

HIMSS comments also addressed health-related social needs (HRSNs) to improve care access and quality for all people and the collection of social determinants of health (SDOH) data. HIMSS supports CMS taking the initial steps to create measures focused on screening patients to identify and incorporate SDOH data into risk stratification of patients and care decision-making and how that should be a best practice adopted by all health systems. 

For the specific IPPS proposed measures (Screening for Social Drivers of Health Measure and Screen Positive Rate for Social Drivers of Health Measure), HIMSS applauds CMS for encouraging hospitals and providers to collect and utilize HRSN data to support improving clinical care and care access for underserved communities. HIMSS also encouraged CMS to publish an action plan detailing a pathway for creating more actionable SDOH-driven measures and detail how the data collected as part of the two HRSN screening measures will be utilized to support the action plan.

On the topic of TEFCA, HIMSS expressed support for adding an option for EHs and critical access hospitals (CAHs) to use the “Enabling Exchange under TEFCA Measure” to meet the Medicare Promoting Interoperability Program Health Information Exchange Objective.

HIMSS also supports CMS exploring TEFCA as an option to advance CMS policy and program objectives in meeting the evolving data exchange needs of all health system participants. In addition, HIMSS recommended CMS continue to consult with the community about the future use of TEFCA and utilize the CMS Innovation Center to leverage TEFCA Network integration as it develops and tests new healthcare payment and service delivery models, particularly around value-based care.

Moreover, HIMSS reminded CMS of the important role TEFCA could play in CMS functions and how the agency could also serve as a major catalyst to help accelerate nationwide connectivity through TEFCA by healthcare providers and other stakeholders.  The comment letter recommended that both of these considerations be prioritized as CMS deliberations on TEFCA continue.