Empowering Health Care Organizations to Collect and Submit Digital Quality Measures via Health Data Utility: A Case Study in Maryland
In June of 2022, the Chesapeake Regional Information System for our Patients (CRISP), Maryland’s state-designated health data utility (HDU), partnered with the State of Maryland’s Health Services Cost Review Commission (HSCRC) and Medisolv, a leader in quality management software, to become the first state in the country to successfully receive Electronic Clinical Quality Measure (eCQM) data from Maryland hospitals under a new quality reporting mandate.
The partnership developed because of a shared desire to innovate on digital quality measure strategy. Since the decision to partner, HSCRC, CRISP and Medisolv have worked collaboratively to collect hospital eCQMs, broadening reporting requirements as the initiative progresses each year. While the program and partnership has faced challenges, it has also led to increased public health data reporting and transparency to deliver more equitable and efficient care.
Importance of eCQMs
Electronic clinical quality measures (eCQMs) are standardized performance measures that use data electronically extracted from electronic health records (EHR) and/or health information technology (IT) systems to measure the quality of health care provided.[1] Data collection of quality measures such as eCQMs can serve as a marker of quality for hospitals, health systems, and providers to better manage patient care and identify effective care and treatment interventions.
The Centers for Medicare and Medicaid Services (CMS) uses eCQMs in a variety of quality reporting and value-based purchasing programs. In 2016, it became mandatory for eligible hospitals to report data via eCQMs for the Hospital Inpatient Quality Reporting Program[2] and the Medicare Promoting Interoperability Program[3]. In addition, most hospitals are required to submit eCQMs to The Joint Commission as part of its hospital accreditation.
This data transparency helps payers and regulators identify areas to focus limited dollars available for quality improvement, encourages hospitals and clinicians to improve care, and helps consumers make more informed decisions about health care options.
Background on CRISP, Medisolv, and HSCRC Partnership
CRISP is both the state-designated Health Information Exchange (HIE) and a Health Data Utility (HDU). As the state HIE, CRISP organizes and governs organizational and technical processes for the maintenance transmittal, access or disclosure of electronic health care information between or among health care providers or entities through an interoperable system. Building and expanding on these critical HIE capabilities and infrastructure, as an HDU, CRISP collects, aggregates, and analyzes clinical information, public health data, claims data, health administrative and operations data to assist the state in the evaluation of public health interventions and health equity. Additionally, as a key characteristic of HDUs, CRISP maintains and benefits from a diverse and robust governance structure, including multiple committees with a broad array of engaged stakeholders.
CRISP has worked collaboratively with Maryland’s HSCRC for many years to support HSCRC’s various quality programs and payment initiatives. As an independent regulatory agency under Maryland’s Total Cost of Care Model, HSCRC has the authority to hold a portion of hospital revenue at-risk based on specified performance benchmarks.
In 2021, HSCRC approached CRISP with the request to partner in the collection of eCQMs in order to expand its reporting and transparency to the public. The idea behind the initiative was to enable the state to evaluate hospital performance, identify statewide areas for improvement, and incorporate benchmarks into policy development in a timely and consistent manner. Since providers were already accustomed to logging into CRISP to access clinical data, the decision was made to partner with CRISP on data collection to make the process as seamless as possible for hospitals.
As an HDU, CRISP maintains advanced technical infrastructure and services that are designed to serve a wide range of stakeholder needs. It was recognized at the outset that this project required additional technical services that CRISP did not have internally. To better understand the capabilities of potential vendors and in recognizing the importance of identifying leaders in quality reporting and data collection, CRISP, in collaboration with HSCRC, surveyed existing vendors in this space through a Request for Information (RFI). The RFI allowed CRISP to understand existing eCQM vendor capabilities related to several factors, including the below use cases.
- Ability to both collect and transmit eCQMs from hospitals, to the HSCRC on a quarterly basis.
- Knowledge of data collection for Hybrid Hospital-Wide Readmission measures. Vendors were asked to explain their understanding of hybrid measures, their experience in collecting then, and their approach to combining data from multiple data input streams.
- Knowledge of physician-focused eCQMs for a potential project with another state agency at a later date.
Medisolv was selected as a partner given the company’s leadership in quality management software and its location in Maryland, providing the company with a deep understanding of the Maryland model and its structure.
Early in the project, the Maryland Health Care Commission (MHCC) became actively engaged as a fourth member of this partnership. MHCC is the state regulator that designates CRISP as the state HIE and HDU. MHCC uses the year-end data collected and publishes components of it on their consumer-facing website. This data informs consumers on critical aspects of patient care and population health including patient engagement, safety, prescribed medications, and treatment outcomes.
Reporting Requirements
Since June 2022, HSCRC, MHCC, CRISP and Medisolv have worked collaboratively to collect hospital eCQMs, making Maryland the first state in the country to successfully receive eCQM data from hospitals under a new quality reporting mandate. As of 2022, and under the State of Maryland initiative, hospitals are required to submit quality performance data, independent of CMS reporting requirements, on a quarterly basis via the Medisolv Submission Portal integrated with CRISP’s HIE portal.
At the onset of the initiative, hospitals were required to submit four measures quarterly, with the first submission window opening in July 2022. Data is reported/submitted via the QRDA I that is uploaded to Medisolv via the CRISP HIE portal.
For the 2023 data collection efforts, HSCRC required submission of the Core Clinical Data Elements (CCDE) for hybrid measure. The two hybrid measures that were required include:
- Hybrid HWR: Hospital-Wide 30-day Readmission
- Hybrid HWR: Hospital-Wide 30-day All-Cause Risk Standardized Mortality Measure
Regarding the eCQM measure submission requirements for CY 2024, HSCRC requires submission of QRDA I files for the eCQM’s listed below.
- eOPI-1: Safe Use of Opioids-Concurrent prescribing
- PC-02: Cesarean Birth
- PC-07: Severe Obstetric Complications (risk-adjusted)
- HH-01: Hospital Harm- Severe Hypoglycemia
- HH-02: Hospital Harm- Severe Hyperglycemia
- Two additional eCQM measures of the hospital’s choosing
Measures for 2025 will remain unchanged from 2024, but HSCRC is offering additional flexibility with reporting timelines. Hospitals that do report all the data requested by the deadline will be eligible for a $150,000 bonus per hospital.
Challenges
Until recently, emergency department (ED) utilization was an eCQM (ED-2 measure) that was tracked and required for reporting by CMS. Given that the measure is no longer required by CMS, vendors decided to stop reporting this measure and additionally, stopped supporting the specifications related to ED wait times. As a result, HSCRC removed reporting requirements for ED utilization and instead set up a separate workgroup, the ED Wait Time Reduction Commission, that focuses on high throughput times in Maryland hospitals, where the backlogs are, and how wait times can be improved.
Additionally, throughout the program, hospitals have occasionally needed to file extension requests for submitting eCQMs to HSCRC. These extension requests, known as Extraordinary Circumstance Exceptions (ECEs) can be filed with the HSCRC for various reasons, including cyber-attacks and delays in EHR upgrades.
Having the right partnership in place to address these challenges has proved to be of invaluable significance. As an HDU, CRISP has been able to support this program in a neutral and flexible way to ensure goals are met by regularly and frequently communicating with HSCRC, MHCC, and Medisolv to determine how to best support hospitals that have not submitted data and troubleshoot any issues hospitals are reporting.
Significance of Partnership and Benefit to Public Health
In July 2024, MHCC reported the opioid measure for 2023 on their public-facing website and are currently exploring the feasibility of reporting maternal morbidity measures that would be part of a birthing score card for hospitals in Maryland. In 2025, MHCC has decided to publish hyper- and hypo-glycemia measures that were reported for 2024 to provide transparency on treatment outcomes for individuals with diabetes and other related conditions. The partnership between CRISP, HSCRC, MHCC and Medisolv demonstrates state government ability to collect eCQM data to evaluate and advance care quality. Through this work, CRISP, has been able to demonstrate an emerging HDU capability in collecting and submitting quality metrics.
[1] “Electronic Clinical Quality Measures Basics”. Centers for Medicare & Medicaid Services. September 2024. Available: https://www.cms.gov/medicare/regulations-guidance/promoting-interoperability-programs/electronic-clinical-quality-measures-basics#:~:text=Health%20care%20providers%20are%20required,to%20measure%20health%20care%20quality.
[2] “Hospital Inpatient Quality Reporting Program”. Centers for Medicare & Medicaid Services. September 10, 2024. Available: https://www.cms.gov/medicare/quality/initiatives/hospital-quality-initiative/inpatient-reporting-program
[3] “2022 Medicare Promoting Interoperability Program Requirements”. Centers for Medicare & Medicaid Services. September 24, 2024. Available: https://www.cms.gov/2022-medicare-promoting-interoperability-program-requirements