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Comments on NPRM for EHR Incentive Program: Clinical Quality Workgroup Insights

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This document outlines the insights and recommendations from the Clinical Quality Workgroup regarding the Notice for Proposed Rule Making (NPRM) on the Electronic Health Record (EHR) Incentive Program and the Interim Final Rule (IFR) for EHR standards. Key members such as Janet Corrigan and Floyd Eisenberg discuss the adequacy of proposed measures and standards, including recommendations for medication reconciliation and the exchange of clinical information. A detailed review of unique ambulatory and hospital measures is included, addressing concerns about granularity and specialty measures.

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Comments on NPRM for EHR Incentive Program: Clinical Quality Workgroup Insights

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    1. HIT Standards Committee Clinical Quality Workgroup Comments & Discussion on the Notice for Proposed Rule Making (NPRM) Electronic Health Record Incentive Program and the Interim Final Rule (IFR) on Initial Set of Standards, Implementation Specifications, and Certification Criteria for EHRs Janet Corrigan, National Quality Forum Floyd Eisenberg, National Quality Forum February 24, 2009 1

    2. 2 Clinical Quality Workgroup Members Janet Corrigan, Chair, National Quality Forum Floyd Eisenberg, National Quality Forum John Derr, Golden Living, LLC Judy Murphy, Aurora Health Marc Overhage, Regenstrief Rick Stephens, Boeing James Walker, Geisinger Jack Corley, HITSP John Halamka, Harvard Medical School

    3. Workgroup members were asked to respond to two specific questions: NPRM – review of measures listed with respect to those recommended by the Standards Committee IFR – review adequacy of IFT standards to support the requirements of measures in the NPRM Review Process 3

    4. 90 Unique Ambulatory Measures 43 Unique Hospital Measures List includes 15 of the 17 measures recommended by the Standards Committee NQF # 0097 – Medication Reconciliation NQF # 0489 – The ability for providers with HIT to receive laboratory data electronically directly into their qualified / certified EHR system as discrete searchable data elements Replaced by metrics for EHR reporting for reporting of exchange of clinical information, medication reconciliation and summary of care records, among others. Recommendations – Some concern about granularity of the metrics listed for EHR exchange of information. NPRM Review 4

    5. Specialties were addressed by the list of measures in the NPRM NPRM Review 5

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