Thank you for the opportunity to provide feedback on the Influenza Immunization eCQM. We would like to provide feedback on the specific areas requested in the proposal guide. Our response to the posted questions are highlighted in red text.

• Whether the data elements can be captured in structured fields in an EHR; Yes, our current workflow related to influenza screening supports discrete data capture. All the data elements listed in the Value Sets either already exist or can be built into the EHR discrete data capture.
• Whether the current EHR specification records immunization status as accurately as possible given the possibility of conflicting documentation of immunization status and if not, how it might be improved; The algorhythm appears to accurately capture all the required data elements that would provide a realistic view of patient care. While there is always a chance of conflicting documentation with the availability of free text throughout the EHR, it is possible to create the necessary forms and workflows to accurately capture the data to support an accurate reflection of care provided.
• Whether a look back period for Guillain-Barre Syndrome (GBS) is necessary in the numerator; Memorial Hermann Health System (MHHS) does not believe a look back period is necessary. GBS status can be obtained from current medical history or added as a question to the influenza screening form. Both methods would support discrete data capture and clinical decision support rules without complicating the algorithm with a specified look back period. We recommend adding SNOMED Concept:128731000119101 “History of Guillain Barre syndrome” to the Value Set to reflect a history of GBS versus an active diagnosis that could be implied from only allowing the ICD-10 or SNOMEDCT problem. Capturing discrete data indicating that the history of GBS was within 6 weeks of a flu shot will be extremely challenging. While we understand that this is the Centers for Disease Control’s recommendation for not giving a flu shot, there is currently not a coded value to convey that as a historical data element. We highly encourage the eMeasure developer to clarify how the 6 week time period in relation to a previous flu vaccination will be captured. For example; patient states “about 10 years ago I had the flu vaccination and experienced an incidence of GBS about 2 weeks after the shot.” The way the measure is written, it would force a clinician to make up dates so the time period could be measured using discrete data elements (date: time of flu vaccination/ date: time of GBS diagnosis). Expecting a patient to remember these exact dates from 10 years ago or to ask a clinician to makeup dates is not feasible. If a SNOMED term indicating GBS within 6 weeks of flu shot can be created, then it is feasible. Until then, we recommend either accepting the current value set with the addition of the GBS past history coded values as the only required data element for the numerator.
• Feasibility of data collection and submission for the purpose of public reporting under CMS’s quality reporting programs; Data collection appears to be feasible as proposed. Issues of data collection for this particular are typically due to challenges in clinical workflow.
• Usefulness of the measures to assess the quality of care for Medicare or Medicaid beneficiaries; MHHS supports the practice of ensuring all eligible for the influenza vaccination receives it in a timely manner. This measure also supports population health.
• Appropriateness of the measure to assess performance of hospitals. MHHS supports this measure as part of Inpatient Quality Reporting program. This measure is an accurate reflection of the care provided to our patient population and is less subjected to the nuances of performance negatively impacted by inaccurate or missing documentation.