In Clinical Psychiatry News yesterday, I wrote a column entitled, "Effect on Psychiatry of Stage 2 Meaningful Use," where I focused primarily on the proposal that all "meaningful EHR users" must collect and report 12 clinical quality measures or CQMs. This is not to be confused with the objectives that must also be achieved. Both the objectives and the measures have core items and menu items. The core ones are mandatory (unless one meets exclusion criteria) and the menu ones are selectives (eg, one must be chosen from a list of options).
In the column, I listed the proposed core CQMs (as listed in Table 6 of the Notice of Proposed Rule Making or NPRM) and focused particularly on one of the proposed CQMs, depression screening. Here is the proposed list for Stage 2:
- receiving consultant reports
- functional status assessments for patients with complex chronic conditions
- controlled hypertension
- medication reconciliation
- use of high risk meds in the elderly
- therapeutic drug monitoring
- antithrombotic use in ischemic vascular disease
- obesity screening and counseling in kids
- tobacco use screening in adults
- cholesterol screening in adults
- depression screening for ages 12 and up
[For a refresher on Stage 1, this article should be helpful.]
CMS actually proposed two possible schemes for reporting these measures. One scheme -- called 1a -- is to select 12 measures from a larger list of 125 options in Table 8 of the NPRM, with at least one from each of 6 domains. The other -- called 1b -- is to report on all 11 of the Table 6 measures (listed above) and 1 from Table 8. The former scheme makes more sense for most specialists, especially psychiatrists, because it maintains flexibility and does not force us to report on things like cholesterol screening and antithrombotic use, both of which are most likely being addressed by a patient's PCP (primary care physician). If one instead reports CQMs via the Medicare Physician Quality Reporting System's EHR Reporting Option, then one can skip the above two schemes (at least, that's how I read it).
This Table 8 list of 125 clinical quality measures is the proposed list, not the final list that will likely be a subset of these based on public comments. Out of this long list, I list below those CQMs that seem to be most relevant to Psychiatry, while being sure to include at least one measure from each domain.
|CLINICAL QUALITY MEASURE RELATED TO PSYCHIATRY||DOMAIN|
|Initiation & Engagement of Alcohol & Drug Treatment||Clinical Process/ Effectiveness|
|Medication Reconciliation||Patient Safety|
|Major Depression: Diagnostic Evaluation||Clinical Process/ Effectiveness|
|Major Depression: Suicide Risk Assessment||Clinical Process/ Effectiveness|
|Anti-depressant Medication Management||Clinical Process/ Effectiveness|
|ADHD: Follow-Up Care for Children Prescribed ADHD Medication||Clinical Process/ Effectiveness|
|Mood disorders: Appraisal drug & alcohol use||Clinical Process/ Effectiveness|
|Bipolar Disorder: Monitoring change in level-of-functioning||Clinical Process/ Effectiveness|
|Screening for Clinical Depression||Population/ Public Health|
|Documentation of Current Medications in the Medical Record||Patient Safety|
|Depression Remission at Six Months||Clinical Process/ Effectiveness|
|Depression Remission at Twelve Months||Clinical Process/ Effectiveness|
|Depression Utilization of the PHQ-9 Tool||Clinical Process/ Effectiveness|
|Child & Adolescent Major Depression: Suicide Risk Assessment||Patient Safety|
|Dementia: Staging of Dementia||Clinical Process/ Effectiveness|
|Dementia: Cognitive Assessment||Clinical Process/ Effectiveness|
|Dementia: Functional Status Assessment||Patient and Family Engagement|
|Dementia: Counseling Regarding Safety Concerns||Patient and Family Engagement|
|Dementia: Caregiver Education and Support||Patient and Family Engagement|
|Dementia: Counseling Regarding Risks of Driving||Patient Safety|
|Closing the referral loop: receipt of specialist report||Care Coordination|
|Adverse Drug Event Prevention: Therapeutic drug monitoring||Patient Safety|
So, if the 1b proposal is chosen by CMS, psychiatrists will have to report on cholesterol and anticoagulants, however this will also result in near-universal depression screening. This would likely result in a lot more referrals to mental health specialists when patients are found to score positively on the screening tool (note that any standardized screening tool is acceptable, such as the BDI, GDS, PHQ-9, and M3), resulting in improvements in morbidity and reductions in costs associated with undiagnosed and untreated depression.
I must say that I am torn between the two options, as I would like to have my cake and eat it, too.
Please comment on your thoughts about this. Also, let CMS know your thoughts by providing public comment prior to May 7 at this regulations.gov page.