eCQM Reporting for ACOs: FHIR or QRDA?

George asks: “We are an ACO working toward submitting eCQMs to meet Medicare’s Quality Standard so we can collect all of our shared savings. I’m confused about the data we need to supply for that. Is it FHIR (Fast Healthcare Interoperability Resources) or QRDA (Quality Reporting Data Architecture) that we need?”

Great question, George.

You don’t have to have either in order to report eCQMs.

It’s surprising to me how many of our clients using certified EHR technology, (CEHRT), cannot generate usable FHIR, QRDA, or any HL7 CDA (Clinical Data Architecture) messages.

In order to be certified, your EHR vendor had to show that they were able to create HL7 messages from a sample set of data in a controlled environment.

The real-time clinical environment is not the same as the testing environment.

• For one thing, data that is textual rather than structured in nature can effectively communicate pertinent medical history without having the structured data architecture needed for simplified electronic quality reporting functions.
• There are also coding and configuration issues at play in real-time EHR use that are not as controllable as in the testing environment.
• Finally, small variations in documentation workflows can prevent the inclusion of important data from the messages.

The good news is, neither FHIR, QRDA, or any clinical data architecture-compliant messages are essential for eCQM reporting.

If you have functional or even partially functional HL7 data that you can get to us, we can read it and we can use it to build your quality analysis and submissions for whatever reporting you are doing. It’s good data for:

• The APP Plus for ACOs,
• And MIPS quality reporting,
• And it doesn’t just work for eCQMs but it also serves as a good solid foundation for MIPS CQMs and Medicare CQMs.

We have a preference, though, for flat files. Here’s why:

• The electronic process and format of flat files maintains the electronic foundation to qualify as eCQM reporting.
• More healthcare organizations can produce and transmit flat files from a query tool like SQL than can produce useful HL7 messages.
• HL7 CDA data is patient-specific which creates some inefficiency in the interchange. For a large organization, the data that needs to be exchanged can be massive, leading to significant delays and handling complications.
• I have a particular dislike for QRDA files. If your data makes it into them effectively, they are a great source of data for all Medicare-related quality reporting needs. The problem I see with QRDA is that they are only useful for established, formalized, quality measures. I want the system we build with you to be scalable into any analytics that you can find useful.