NHIT Comments on MU Stage 2 & 3 Clinical Quality M

HIT Stakeholders Submit Meaningful Contributions to Quality Measures Workgroup
Thank you for this opportunity to respond to the Clinical Quality Measures Concepts for Stage 2 and 3 Meaningful Use. The National Health IT Collaborative for the Underserved (NHIT) commends the Quality Measures Workgroup for providing such a robust set of concepts and measures to guide the next stages of meaningful use of health information technology (HIT) for the improvement of health and health care quality. NHIT shares the Workgroup’s commitment to quality enhancement, with emphasis on the underserved, particularly communities of color, and those who care for them, and we see the meaningful use (MU) of HIT as an essential tool to achieve that goal.

We offer general observations and illustrative comments about selected measure concepts at this point and would welcome other opportunities to present additional recommendations to the Workgroup. Having enthusiastically endorsed the requirement for the collection of demographic data (race, ethnicity, primary language and gender) in Stage 1 of MU as a prerequisite to reduce/eliminate health disparities, NHIT urges the Workgroup to maintain that visible focus in Stages 2 and 3. At present, there is only one measure that specifically addresses health equity. However, each of the measure concepts offers an opportunity to collect and report data using Stage 1 demographic variables at a minimum. Indeed, it would be important to know how minorities and other priority populations fare in Stages 2 and 3 with respect to Patient and Family Engagement, Care Coordination, Patient Safety and Population and Public Health. Disaggregated reporting in each of these categories may have been the Workgroup’s intention, but we would urge that intention to be made explicit.

Generally, the measure concepts are clinically based and only a few (12 out of 40) make reference in the concept definition to HIT, suggesting how the measure might integrate or implicate HIT. The absence of an explanation of HIT’s specific relationship to the measure concepts requires the reviewer to make assumptions about the intended use of HIT in these contexts. As such, efforts to illustrate meaningful use are diluted without such clarity. In several cases, the EHR, PHR, a registry or other type of HIT tool or application potentially could be used as a data source, or to monitor and track information, or to support data collection activities; however, such use is not stated.

Relative to the content of selected measures, we recommend further refinement of definitions. We also believe it will be important to reflect how parameters will be assessed and how HIT will be implicated. Illustrative examples follow:

#1, 2 and 3. There is a need to concretize the phrase: “led in the ‘right direction’” through the provision of tangible support for patient self-management, shared decision-making and the observance of patient preferences. Possible measures could address the availability of culturally and linguistically- appropriate materials and services (e.g., interpretation), geared to the literacy level of patients.

#8. (Measures assessing ambulatory care-sensitive preventable admission) – The definition states, “This measure concept relates to admissions caused by unaddressed ambulatory conditions at the onset of symptoms due to multiple reasons such as inappropriate clinical management of inefficient system issues.” This concept may also be influenced by a patient’s access to primary care, a medical home or insurance. In this instance, it is not clear how other potentially confounding factors will be addressed. It is also not clear how HIT is to be implicated in this measure.

#12,13,15 The appropriate/efficient use of medications may be influenced by provider instructions to the patient and/or patient knowledge and understanding of how much medication (dosage) to take at a given time (frequency) over a specified period of time (duration). Such information could be tracked by various components of the EHR, PHR or other HIT tool. Here, too, the availability of culturally and linguistically appropriate services and materials has relevance and could serve as an appropriate measure of effectiveness.

Again, our appreciation for your leadership with respect to this important work!
Author: Ruth Perot and Brenda Leath

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Disclaimer: The views and opinions expressed in this blog are those of the author and commenter alone, and do not represent an official position of the National Health IT Collaborative for the Underserved or its funders.