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  1. eCQM Issue Tracker
  2. CQM-7279

STEMI OP 40 logic issues make the measure invalid

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    • Icon: OQR eCQMs - Outpatient Quality Reporting OQR eCQMs - Outpatient Quality Reporting
    • Resolution: Answered
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    • Andrew Heiler
    • University of Michigan- Michigan Medicine
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      Thank you for your inquiry for CMS996v4/v5: Appropriate Treatment for ST-Segment Elevation Myocardial Infarction (STEMI) Patients in the Emergency Department (ED). We have confirmed our understanding of your inquiries and recommendations and have included responded to each below.

      1. Our understanding is that the intent of your recommendation is to exclude cases from measure calculation in which a patient is initially diagnosed with a STEMI during the ED encounter, but ultimately does not receive PCI due to clinically valid reasons. This issue has previously been brought to CMS’s attention. The measure developer will consider further measure refinements during the Annual Update.

      2. Our understanding is that you’re describing a prior STEMI or denominator exclusion diagnoses identified through the problem list, and suggest using claims data instead, to ensure accurate information.

      First, the Quality Data Model does not prescribe the source of diagnosis data in the EHR. Diagnoses may be found in a patient’s problem list, encounter diagnosis list, claims data, or other sources within the EHR. As such, accurate EHR documentation is crucial.

      Second, the measure intends to capture STEMI diagnosis during the ED encounter and denominator exclusions in the specified lookback window. To differentiate between active and historic diagnoses in the problem list, it’s important for that both the onset and abatement times are populated in the EHR.

      Historic STEMI diagnosis should not be captured in the measure because: a) this runs contrary to the measure intent; and b) there is no ED encounter to link to. If a prior STEMI is documented as an active diagnosis or on the problem list within the EHR, it may erroneously count towards the measure population. We recommend working with your EHR vendor or internal IT staff to remove erroneous diagnoses.

      Further details on the measure specifications can be found here: https://ecqi.healthit.gov/sites/default/files/ecqm/measures/CMS996v5.html

      3. Our understanding is that your recommendation is to use Hospital Access Records (HARs) as a data source for this measure. Per CMS guidelines, eCQMs are measures specified in a standard electronic format that use data electronically extracted from electronic health records, not HARs.

      4. Similar to #2 above, it seems you’re describing a scenario in which the STEMI diagnoses and denominator exclusions are retrieved from diagnoses problem list and the information above hopefully clarifies. As stated above, onset and abatement should be captured in the EHR to document diagnoses that are active versus historic, based on clinical determination. Providers can validate eCQMs through internal processes, including collaborations between the EHR vendor and internal IT and QA teams to ensure clinical documentation is accurately captured in the EHR and that measure cases reflect measure specifications.

      Lastly, we want to acknowledge that these issues have previously been brought to CMS’s attention, and the measure developer will continue to identify future educational resources to support providers.
      Show
      Thank you for your inquiry for CMS996v4/v5: Appropriate Treatment for ST-Segment Elevation Myocardial Infarction (STEMI) Patients in the Emergency Department (ED). We have confirmed our understanding of your inquiries and recommendations and have included responded to each below. 1. Our understanding is that the intent of your recommendation is to exclude cases from measure calculation in which a patient is initially diagnosed with a STEMI during the ED encounter, but ultimately does not receive PCI due to clinically valid reasons. This issue has previously been brought to CMS’s attention. The measure developer will consider further measure refinements during the Annual Update. 2. Our understanding is that you’re describing a prior STEMI or denominator exclusion diagnoses identified through the problem list, and suggest using claims data instead, to ensure accurate information. First, the Quality Data Model does not prescribe the source of diagnosis data in the EHR. Diagnoses may be found in a patient’s problem list, encounter diagnosis list, claims data, or other sources within the EHR. As such, accurate EHR documentation is crucial. Second, the measure intends to capture STEMI diagnosis during the ED encounter and denominator exclusions in the specified lookback window. To differentiate between active and historic diagnoses in the problem list, it’s important for that both the onset and abatement times are populated in the EHR. Historic STEMI diagnosis should not be captured in the measure because: a) this runs contrary to the measure intent; and b) there is no ED encounter to link to. If a prior STEMI is documented as an active diagnosis or on the problem list within the EHR, it may erroneously count towards the measure population. We recommend working with your EHR vendor or internal IT staff to remove erroneous diagnoses. Further details on the measure specifications can be found here: https://ecqi.healthit.gov/sites/default/files/ecqm/measures/CMS996v5.html 3. Our understanding is that your recommendation is to use Hospital Access Records (HARs) as a data source for this measure. Per CMS guidelines, eCQMs are measures specified in a standard electronic format that use data electronically extracted from electronic health records, not HARs. 4. Similar to #2 above, it seems you’re describing a scenario in which the STEMI diagnoses and denominator exclusions are retrieved from diagnoses problem list and the information above hopefully clarifies. As stated above, onset and abatement should be captured in the EHR to document diagnoses that are active versus historic, based on clinical determination. Providers can validate eCQMs through internal processes, including collaborations between the EHR vendor and internal IT and QA teams to ensure clinical documentation is accurately captured in the EHR and that measure cases reflect measure specifications. Lastly, we want to acknowledge that these issues have previously been brought to CMS’s attention, and the measure developer will continue to identify future educational resources to support providers.
    • CMS0996v5
    • CMS0996v4
    • 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?

            aweber Mathematica EH eCQM Team
            aheiler Andrew Heiler
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