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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.

CHA submitted the attached comment letter to the Centers for Medicare & Medicaid Services (CMS) today in response to CMS’ request for information on core access to care measures and metrics that could be used to assess access in the Medicaid program. CHA encourages CMS to take a thoughtful approach and develop an action plan that would ensure successful implementation of CMS' goals for the program. More specifically, CHA recommends that CMS develop and implement a National Access Strategy, similar to its approach when developing the National Quality Strategy, and allow multi-stakeholder and multi-agency participation in the process. CHA also urges CMS to look beyond traditional metrics to identify new evidence-based areas for measure development and to identify measurement gaps. CHA recommends that CMS consider environmental factors such as poverty, access to transportation and affordable housing when evaluating a beneficiary’s access to care. These factors can have significant impacts on patient health and health care delivery and should receive consideration. While CHA appreciates CMS’ efforts to create an equitable health care system, CHA requests that CMS recognize the costs of providing health care when it determines whether rates are adequate to ensure access. CMS must ensure that payment rates remain adequate for hospitals that are asked to do more with less.