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click” data entry of patient information.
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http://www.nuance.com/healthcare/products/dragon_medical.asp
Microsoft rolls out encrypted e-mail features in its
HealthVault personal health platform in collaboration with the federal
Direct Project health record exchange initiative.
Microsoft
Teams with U.S. Direct Project on HealthVault Expansion - Health Care IT
- News & Reviews - eWeek.com
Source: eweek.com
Agency for Healthcare Quality – Medicare Shared Savings
Program: Accountable Care Organizations Proposed Rules-Comments
File code CMS–1345–P
Before offering my
comments on the measurement of quality in the transition from
transaction-based medicine to accountable care I first must note that
the concepts presented in these proposed statutory requirements are in
the whole necessary, achievable and well designed to achieve
accountability in our healthcare system. While we expect there will be
promotional activities forthcoming from CMS that will emphasize the role
of the patient and their responsibilities for achieving optimized and
affordable healthcare we will not address this issue in our comments
below.
In order to
facilitate the context of the comments we will first reference the
proposed verbiage which will be in bold and refer to external sources as
and where possible.
With the exception of exchanging information electronically through the
use of an electronic health record the emphasis on measurement of
clinical processes, the caregiver experience and outcomes seem to be
focused on surveys for measurement and additional reports that the ACO
must generate and forward to the government. While measuring quality of
care is a complex and difficult task, it appears that the government,
through these proposed regulations, has decided it is too difficult to
measure quality beginning with the first patient – PHP encounter and has
chosen to begin the measurement of quality after the visit has been
coded for payment. If the initial diagnosis of the patient's disease
or/problem is incorrect, but all the coding is correct, then the patient
will proceed down a path of sub optimized care which may go undetected
until or unless a specialist is called in to review said diagnosis or,
the patient experiences repeated and significant problems requiring a
return to their PHP. After recognizing the patient's reaction to their
first treatment plan including medications prescribed, the provider has
another opportunity to readdress their diagnosis and subsequent
treatment plan. While one might argue that patient safety was not risked
from our point of view, it might be argued, even when this incident
remains undocumented by the various surveys required for ACOs, there
could still be a problem. Physicians that have excellent communication
skills are not likely to be scored poorly by the patient who has
experienced such a situation.
Rather than increasing the reporting burden for PHPs and patients, we
suggest leveraging data already gathered by the PHP and residents in
their EHR system. ACOs, which transmit in batch mode the patient's
medical history, the symptoms they presented, diagnosis and treatment
plan, should be very careful when analyzing this unstructured data. This
unstructured data (text) could be analyzed more completely using
sensitive qualitative measurement. Converting the unstructured (text),
part of the medical record into structured information, which is not
granular enough to access the quality of the diagnosis and treatment,
leads to measurement of events such as did the provider exchange
information with a specialist or did the provider use e-prescribe, etc.
These events by themselves do not improve the patient’s care, yet
translating this information into codes or reports for discrete
numerical information, places considerable burden on providers.
While not commonly known or used in the medical field unstructured
(text) content analysis has been used for many years in the intelligence
gathering market and in most recently the road legal market. Application
of this technology has reduced costs of large litigation most
significantly and reduced the time required for discovery by orders of
magnitude. This same sort of tool is directly applicable to measuring
quality within the healthcare process.
Page
19569, Section II E. Quality and Other Reporting
Requirements,
2. Proposed Measures To Assess the
Quality of Care Furnished by an ACO,
b. Considerations in Selecting
Measures, 1. Use of Measures,
third bullet in second column states,
· “The
collection of information
should minimize the burden on
providers to the extent possible. As part of that effort, we have
begun and will continuously seek to
align Shared Savings Program
measures with the methods and measures included in the
Medicare and Medicaid EHR Incentive
Programs to enable the
collection and reporting of
performance information to be a
seamless part of care delivery and
the meaningful use of certified EHR
technology.”
Again as mentioned earlier in the comments above the burden on providers
of generating reports, filling out surveys is quickly diminishing the
productivity gains they realized through installing electronic health
records. We suggest that the agency for healthcare quality examine the
use of an application for unstructured content analysis. We are not
talking about technology from Google which counts the number of links,
nor are we talking about full-text Boolean searches, we are talking
about content analysis based upon 300+ mathematical algorithms. This
measuring tool is most accurate with large volumes of information;
terabytes and above.
Page 19570 Section II E. c. Proposed Quality Measures for Use in
Establishing Quality Performance
Standards That ACOs Must Meet
for Shared Savings states,
“Based upon the principles described,
we are proposing 65 measures (see
Table 1 pages 19571-19591) for use in the calculation of the
ACO Quality Performance Standard. We
propose that ACOs will submit data on
these measures using the process
described later in this proposed rule and
meet defined quality performance thresholds.”
While measuring quality outcomes in healthcare is much like measuring
beauty, in both cases a definition can be developed and then some
quantitative measures established that will assist in a numerical
comparison between multiple judges. Inherent in this complexity is the
fact that measuring quality in a healthcare setting is a qualitative
rather than a quantitative process. The American Society of quality
control can provide numerous tests for quality inspection and reporting
based on defects per unit or level I level II or level III type defects.
Unfortunately these techniques cannot be translated to measuring
healthcare quality which has been extraordinarily large possibilities of
good and bad quality. The research performed by Stanford University and
the Center for primary care and outcomes research reported the risks
associated with implementing the patient quality index. While their
research highlighted challenges regarding selecting the indicators, the
numerator or the denominator of the statistic used for a quality
measure, they also highlighted policy implications that should be
considered. Their research poses the question, will the measurements
which are presented in table 1, insure true quality improvement or will
it simply improve coding and shift the burden of the case management to
the PHP from specialists and other healthcare providers? They also pose
the question, does this focus on avoidance of hospitalization really
reflect quality or, is it simply an attempt to reduce costs at the
expense of the patient's healthcare? One of the recommendations made by
this research group was that the government should identify
interventions and link usefulness of indicators with true quality
improvement.
The measurement of true quality, infers a relevancy and risk assessment
not answered through statistical analysis. Statistical significance,
without practical significance, appears to be where these measurements
are headed. While qualitative research often involves validated surveys,
this method is not preferred to direct sampling of the research
populations’ experiences. Unfortunately few researchers have access
to/or knowledge of the latest content analysis tools that would
significantly increase the quality of their conclusions based upon an
ability to quickly and reliably analyze thousands of published research
articles which may have been impractical to analyze given their research
budgets.
Page 19570 Section II E. 3.
Requirements for Quality Measures
Data Submission by ACOs, b. GPRO Tool,
first paragraph, states
“We propose that the
existing GPRO tool be built out, refined,
and upgraded to support clinical data
collection and measurement reporting
and feedback to ACOs under the Shared
Savings Program.”
Page 19592 Section II E. 3.
Requirements for Quality Measures
Data Submission by ACOs, b. GPRO Tool, first column, fourth paragraph,
states
Quality Performance Standards, “In the GPRO audit process, we plan to
abstract a random sample of 30
beneficiaries previously abstracted for
each of the quality measure domains/ measure sets. The audit process
would
include up to three phases, depending
on the results of the first two phases.
Although each sample would include 30
beneficiaries per domain, only the first
eight beneficiaries’ medical records
would be audited for mismatches during
the first phase of the audit…”
We suggest that, before the government build out the GPRO tool, a pilot
project containing the 50 or more collections of medical records of
5,000 beneficiaries for one of the quality domains/measure sets be
analyzed using a content analysis tool. This tool should be able to
search and retrieve information based upon concepts and ideas they
contain and should be able to link relationships between patient
history, symptoms, diagnosis and outcomes. Using thousands of published
research articles and best practice documentation a library of several
gigabytes of information up to a terabyte of information should be used
to judge the efficacy of this measurement process.
These comments have taken considerable thought and time on our part.
However, we hope that this effort will be well received and will enjoy
consideration on the part of the agency for healthcare quality. The
comments in this document are from Glass Eye Consulting of Denver,
Colorado. We have no vested interest in any product or service which we
have commented on in this document. Our comments are designed to improve
the quality measurements of healthcare without consuming providers time
dedicated to reporting mechanisms which by themselves will reduce the
attention given to patients and thereby lower healthcare outcomes.
Questions regarding our comments can be forwarded to mpglass@q.com
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