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OQR eCQMs - Outpatient Quality Reporting
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Resolution: Answered
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Moderate
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None
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None
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Andrew Heiler
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University of Michigan- Michigan Medicine
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CMS0996v5
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CMS0996v4
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Invalid data, countless hours trying to justify and rationalize poorly designed measures that have no clinical utility and divert resources away from valid measures.
CMS issues for OP-40/ CMS996:
1. Acute cases that come in with an initial clinical concern/ clinical impression for STEMI quite often are seen by a specialist and ruled out for MI despite ST elevations. In these occurrences, an intervention is not indicated and therefore an ICD10 PCS code is not assigned and results in a failure due to the indiscriminate nature of the eCQM logic.
Example: Patient comes in with a seizure, has ST elevations of EKG, clinical impression is seizure and STEMI. Patient goes to cath lab for possible intervention, but cardiologist reviews and signs off that EKG is consistent with benign early repolarization. Case fails due to no intervention and no ability to negate clinical impression for this measure.
Recommendation: remove clinical impression or implement negation logic. PCI is only useful if it is indicated in the first place.
2. Old problem list diagnosis being used to determine who will be evaluated for STEMI is primed for errors. Even the exclusions based on the same problem list relevant times are widely known erroneous sources of data.
Recommendations: Remove problem list as a source for both inclusions and exclusions. A more appropriate and accurate approach would be a matching mechanism after collecting all billed STEMI's then applying exclusions based on historically billed diagnosis and timeframes.
3. HAR is the only reasonable place to accurately electronically pull an appropriate population for STEMI, since in part there is a reasonable expectation that hospitals will also want to code appropriately for the diagnosis.
4. If OPPS starts validation at the clinical level, how will an old problem list inclusion be "validated"? Is validity related to the data or the clinical determination of the clinician? Is it clinically wrong? The data is accurate, is the clinical issue then invalid?
As an example: A case qualifies only via a problem list dx of STEMI from 2020 that did not have an abatement time. No other evidence of STEMI on the current encounter, and this case fails the measure and is placed in the denominator. How far back should problem lists be remedied?
Recommendation: further guidance is needed on all validation and what that means in the context of an eCQM? Validation at the level of data present makes sense. Can one assume that any clinical validation would not make inferences about what should have happened, but rather given what is documented, did the right intervention take place?