February 19, 2013
Gerald M. Shea
Treasurer and Interim Chief Executive Office
National Quality Forum
1030 15th Street NW Suite 800
Washington DC 20005
Dear Mr. Shea:
The American Urological Association (AUA), representing over 90 percent of the practicing urologists in the United States, welcomes the opportunity to submit comments on the National Quality Forum’s (NQF) eMeasure Feasibility Assessment. The long-standing mission of the AUA is to promote the highest standards of clinical urological care through education, research, and formulation of health care policy. We appreciate your attention to the concerns of America’s urologists.
First, one item of concern to the AUA is provider input. The majority of urologists practice in small or solo practices. We note that while your environmental scan did include providers, the participants were from an ambulatory physician practice and two health systems. Thus, the unique perspective of a small practice was not included, and therefore, your results are somewhat skewed. While we appreciate that eMeasures are the way of the future, utilizing them is a step that is currently unattainable for many providers, a large number of whom are in small or solo practices. Many neither have electronic health records (EHRs) nor do they report on quality measures. Their input in this assessment would be just as valuable as those of large health systems and would likely help you to develop a strategy to bridge the gap to those not currently participating. Additionally, focusing substantial resources solely on the development of eMeasures may not increase participation and may only further isolate these providers. We would urge a greater emphasis on measure development and outreach that would facilitate non-participants’ desire and ability to begin to participate rather than ostracize them further. Just because eMeasures exist does not mean they will be used, just as many providers do not practice quality measurement now even though many measures currently exist. A well-organized campaign must accompany the development process.
Additionally, we have concerns about two of the recommendations presented in the feasibility assessment:
Recommendation 2, 2.1 Data element feasibility assessment: Data in a structured format deserves further consideration. The current availability of structured data is largely dependent on the quality and prevalence of vendor-developed templates. Providers may find a suitable template that can capture information in structured fields with one EHR product, but may have to input this data by free-text in another due to the lack of available structured fields. Furthermore, existing templates that facilitate structured data capture may have poor usability; so, providers may elect in certain circumstances to enter relevant data more quickly in narrative form. Therefore, feasibility assessment of data elements should not solely evaluate an eMeasure based on the presence of existing structured data fields, but rather on the type of data needed and suitability for capture in structured form.
Recommendation 7, Greater Collaborative Efforts Needed: Additional stakeholders should include medical specialty organizations and other bodies that participate in the development of clinical guidelines and other evidence-based documents. Since quality measures may be derived from guideline documents, owing to their potential for methodological rigor and synthesis of data, efforts to create "actionable" statements and to assess data that can be represented in structured format will allow for consistency in terms along the knowledge portfolio spectrum. Provider acceptance of eMeasures will be enhanced if the content is closely derived from clinical guidelines, similar to the way in which well-constructed review courses properly prepare candidates for board exams. Ideally, electronic forms of these guidelines (eGuidelines) would maximize usability, underscoring the need for vendor collaboration at all stages of EHR knowledge integration.
Thank you for your attention to our concerns. Please contact Jennifer Bertsch, Manager, Quality (410.689.4043, jbertsch@AUAnet.org) if you have questions or wish to discuss our comments in greater detail.
Christopher Tessier, MD
Vice Chair, Quality Improvement and Patient Safety Committee