CMS and ONC administrators -

Immediate information is needed on how hospitals are going to be able to meet the CCDE reporting requirements for the narrow time specifications you have defined for the July 1, 2023 - June 30, 2024 reporting period.  You are asking hospitals to report data that is outside normal workflow for the diagnosing, care, and proper management of patients. While you want to understand the patient's condition to better understand readmissions and mortality risk, you are missing the first sets, and often the most critical, of lab and vital sign data that is obtained. Patient care and treatment does not start at the time of the transition to inpatient, but in the majority of cases, it starts hours prior, and that can be > 24 hours to the start of the inpatient encounter.  Holding hospitals accountable to obtain these data results within your time specifications comes with significant impacts.  Per your specifications contained within the clinical recommendations statement, "The logic is not meant to guide or alter the care patients receive. The purpose of this core clinical data elements logic is to extract clinical data that are already routinely captured in EHRs from encounters for hospitalized adult patients. It is not intended to require that clinical staff perform additional measurements or tests that are not needed for diagnostic assessment or treatment of patients." 

But yet, hospitals are actively trying to change workflows to meet your specifications. Who is going to pay for additional CBCs and CHEM panels to be drawn in order to meet the time specification? The patient population we are reporting on typically has vascular issues that can impact obtaining lab specimens, and now you are wanting hospitals to repeat that specimen. This is a disservice to patients and can inflict unnecessary pain on the patients we serve. Does it make sense to repeat blood work that was identified as normal 24 hours prior, unless warranted by the medical professionals assessing the patient and monitoring their care?  In the post-pandemic environment that we are working in, hospital resources should be considered. Should we be adding duplicative tasks to healthcare workers?  Repeating labs on Medicare patients would burden hospital laboratories. Repeating weights places burden on nursing staff.  Weighing a patient at the beginning of their hospital encounter, no matter their encounter status, is necessary for proper medical care. This important initial weight is used to assess nutritional status of the patient, determine dose weighting for medication administration, and necessary for providers and pharmacist to evaluate medication orders. At many hospitals, dispensing of medication requires a weight. This is done for patient safety. Ordering and obtaining daily weights makes medical sense for patients with heart failure or who are on dialysis or are observed to have large fluid shifts.  It does not make sense for many of the other patients cared for in hospitals. The same could be said of obtaining a temperature or O2 saturation at specifically defined times. Please consider the value of having the first set of data on patients, and not a time specific data point.  Think of the patient and their safety. Think of reducing redundancy. Do not create additional and unnecessary burden on hospitals and their valuable resources. 

Not having a timely HSR report for a hospital to use at this time to gain additional insight in ways they can improve on meeting the hybrid measures is difficult and challenging. The current reporting period (FY24) will be over by the time our hospitals, that did voluntarily report FY23 data, have feedback to evaluate.   

Please consider altering the required time specifications of data as well as the impact to any hospitals APU payment based on meeting a >90% threshold for the CCDEs being submitted for these new hybrid measures.