CHA has submitted the attached response to the Centers for Medicare & Medicaid Services (CMS) request for information on the certification of health information technology (HIT). In conjunction with the Office of the National Coordinator, CMS sought input on electronic health records products used for reporting electronic clinical quality measures (eCQMs), specifically requesting feedback on how often to require recertification of HIT modules, the number of eCQMs a certified HIT module should be required to certify to, and ways to improve module testing.
In comments, CHA urged CMS to complete a full and transparent evaluation of the current state of eCQM development in order to inform future rulemaking, and to develop a strategic, long-term, detailed measurement strategy with clear goals for identifying appropriate eCQMs. In response to CMS’ specific questions, CHA urged CMS to require recertification of HIT modules each time a new eCQM is added to a program. CHA also believes that CMS should require certification of all eCQMs used in all CMS programs, and that certification should occur in advance of the measures’ adoption into the program. Finally, CHA stressed the need for a robust testing process for each eCQM.