How can EHRs submit data to QPP for Program Year 1 (2017)?

[Developer Group for QPP APIs]

EHRs will be able to submit data to QPP for Program Year 1 (2017) through file upload. CMS will not have a version of the Submissions API suitable for use by EHRs ready in time for Year 1 reporting. Read on for details.

EHR Submission Modalities for QPP Program Year 1 (2017)

EHR Vendors – File Upload Only

Clinician or clinician's staff exports a QPP or QRDA III data file from an ONC certified EHR (CEHRT), then logs in to QPP website with EIDM credentials and uploads the file

EHR Data Submission Vendors (DSV) – File Upload Only

Clinician or clinician's staff selects performance data using CEHRT, then asks DSV to submit the data to CMS on their behalf, exports

DSV staff member exports QPP or QRDA III data file, then logs in to QPP website with their EIDM credentials and uploads the file

Why is API limited to Qualified Registries and QCDRs in Year 1?

With finite time and resources for our API effort, we prioritized the most common submission use case first—Registry and QCDR submissions.

Qualified Registries and QCDRs are different from EHRs and Submission vendors

Why can't EHRs use the API in the same way as Qualified Registries or QCDRs?

EHRs are different from Qualified Registries and QCDRs. The latter can authenticate on behalf of all the entities they represent, but an EHR as a product can only authenticate on behalf of the person using it. Also, clinicians enter into contracts with them to submit data to CMS under a controlled set of circumstances.

How will EHRs submit data to QPP in future program years?

CMS will continue to offer the file upload functionality for submission of data to QPP in Program Year 2 (2018). Our vision for the QPP APIs is to lower the burden for eligible clinicians and groups by enabling them to use their ONC certified EHR to both report data to and get feedback from CMS without leaving the EHR. We will be working together with our EHR vendor partners to build the right tools to accomplish this vision for the API in QPP Program Year 2 (2018) and beyond.

[Grant Wideman]

I am sorry to say but this is a very disturbing. We have been consulting with multiple EMRs for the last 8 months to get them ready for this API. It was very clearly announced back in January that the "PRODUCTION" API will be available in July. There has been delays after delays and now we are hearing that it will not be available to EHRs at all. We have spent a lot of resources and commitment to clients including cancelling contracts with registries. We didn't do that based on some hearsay but based on documentation made available by CMS. The website at https://qpp.cms.gov/developers/submission-methods very clearly outlined that API will be the "preferred method" for EHRs and it will be available in 2017. I am hoping we are not the only one affected by this announcement this late in the year. We are planning to report and ask for explanation of  this lack of accountability and would request our EHR to join us.  

[Michael Murdock]

Grant, I totally agree with you, lack of accountability on CMS is a theme that continues to plague them. I also have worked many hours preparing for the API that was promised. One of CMS biggest hurtles is they always contract this out to many other consulting companies that are not held accountable and those companies don't communicate well with each other, thus the product is delays. But I hate to say this but that's our government at work.

Michael    

[Michael Murdock]

Grant, I totally agree with you, lack of accountability on CMS is a theme that continues to plague them. I also have worked many hours preparing for the API that was promised. One of CMS biggest hurtles is they always contract this out to many other consulting companies that are not held accountable and those companies don't communicate well with each other, thus the product is delays. But I hate to say this but that's our government at work.

Michael    

On Thursday, September 14, 2017 at 3:03:37 PM UTC-4, Developer Group for QPP APIs wrote:

[Grant Wideman]

 This has exposed us to a lot of risk with our clients. We are consulting our attorney to discuss our options. The contractors are being paid with our Tax Payers dollars and we have the right to question and claim damages. Please contact me at widema...@gmail.com if you would like to join us

[Pawan Jindal]

Could you clarify which version of QRDA III would be accepted by QPP website. Would it be based on the IG available at https://www.cms.gov/Regulations-and-Guidance/Legislation/EHRIncentivePrograms/Downloads/eCQM_QRDA_EC.pdf  or the one that is tested during the ONC certification? The guide at the link above is different from the one that the CEHRT are certified for? 

Also, this QRDA III format includes the improvement activities and the ACI components. Can providers use this QRDA III format to submit all the categories data for MIPS?

[Jonathan Sullivan]

Yes, the version of QRDA III accepted by the QPP website is the 2017 Implementation Guide that you linked below. And yes, providers can use this QRDA III format to submit all the categories of data for MIPS.

[ONCOCHART Software]

Besides here in this group, where else is it officially published that clinicians will not be able to submit data from EHRs directly to CMS using the API? We've done a lot of work to get our EHR ready for submission using the API. I found this link, but it isn't the same as what is above. https://qpp.cms.gov/developers/submission-methods

[Shane Jarrell]

Bump!

[Jonathan Sullivan]

It is not officially published elsewhere. You are correct that the information on the link you shared is inconsistent. The information at that link was published earlier in the year and is now out of date. We will put in a ticket to bring that information into alignment with the above.

We understand and appreciate the frustration on the part of EHR developers and their customers that we will not be able to provide EHR submission via the API for QPP Program Year 1 (2017). As stated above, we will be working together with our EHR vendor partners to build the right tools to accomplish this vision for the API in QPP Program Year 2 (2018) and beyond.

On Tuesday, October 3, 2017 at 12:28:58 PM UTC-4, ONCOCHART Software wrote:

[ONCOCHART Software]

For what it is worth, I emailed the QPP helpdesk with two questions.

Questions

Will clinicians be able to submit Quality and ACI category data directly from their chosen EHR if that EHR has implemented the QPP API? I've read in the Developer group for API (https://groups.google.com/forum/#!topic/qpp-apis/6Ac3AyW36nU) that this will not be possible for year one, but I'd prefer a more official answer.

Regardless of the answer above, if the manual file upload option is chosen by the clinician, does the EHR have to produce one QPP formatted file that contains both the Quality and ACI data, or should the EHR generate one QPP formatted file for Quality and another QPP formatted file for ACI?

Answers provided by the QPP helpdesk

A: The answer on the Google Group is the official answer. CMS will not have a version of the Submissions API suitable for use by EHRs ready in time for Year 1 reporting. If the manual file upload option is chosen by the clinician, the EHR does not have to produce one QPP formatted file that contains both the Quality and ACI data. The Quality and ACI data can be combined in one uploaded file, or can be uploaded in separate files. Both options are valid and will be treated equally.

On Tuesday, October 3, 2017 at 1:07:28 PM UTC-5, Shane Jarrell wrote:

Bump!

[Pawan Jindal]

Just to clarify - the "QPP Formatted File" mentioned below is the QRDA III file that supports all categories, correct? If yes, it could also include the Improvement Activities data. In summary, the EHRs can create a single file for export for submission of all categories of MIPS.

Jonathan, could you please confirm that?

[Jonathan Sullivan]

Yes, EHRs can create a single file for export for submission of all categories of MIPS.

[Michael Murdock]

Can we use the older QRDA III xml i.e. cypress format? or do we have to used the conversion utility to convert it to the QRDA III qpp format?

[Ivana Ng]

Hi Michael - 

If you upload the QRDA III XML file via qpp.cms.gov, you do not have to convert it to the QPP format (the UI will do that work for you!). If you are integrating directly with the API though, you'll have to use the /converter endpoint to convert the QRDA III XML file to QPP JSON format before parsing and posting to the /measurement-sets endpoint.

-Ivana

Ivana Ng

Product Manager

Nava

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[Pawan Jindal(MyMipsScore.com)]

Hi Ivana, 

I know this has been asked multiple times on this forum now but there is still a lot of confusion around the functionality that will be available through the UI submission. After reviewing all the forum topics and talking to QPP support, we are assuming the following. I will really appreciate if you could confirm our understanding:

• Providers will be able to manually submit their QPP data for all categories using their EDIM account.
• Providers will have the option to upload a QRDA III file. Will there be an option to upload a JSON file too (in QPP format) too?
• The QRDA III file could include data for all 3 categories as a single file based on the 2017 specs. Does it have to include all the 3 categories or can it be for one or two categories too? 
• The QRDA III file could include data for a single provider or for the group.
• The QRDA III file can only contain data for the eCQMs. The eCQMs version ids have to match the ones in measures.json file. 
• For obvious reason, the QRDA III can not be used to submit registry measures. Providers will need to use a registry to submit any registry measures. Can providers use registry to submit the quality data and manually upload ACI and IA data?
• Our understanding from discussion with QPP support is that there is no separate " EHR certification" to create these new QRDA III files for all categories. By submitting the data, the providers are attesting to the 2 facts below:
• The Quality data came from an EHR that was certified for the eCQMs that are included in the submission file
• The ACI data came from a certified EHR meaningful use dashboard. 

Thanks,

Pawan

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[Jonathan Sullivan]

Hi Pawan,

Here are the answers to your questions.

Q1: Will providers be able to manually submit their QPP data for all categories using their EDIM account?

A1: Yes

Q2: Will providers have the option to upload a QRDA III file?

A2: Yes

Q3: Will there be an option to upload a JSON file (in QPP format) too?

A3: Yes

Q4: The QRDA III file could include data for all 3 categories as a single file based on the 2017 specs?

A4: Yes

Q5: Does it have to include all the 3 categories or can it be for one or two categories too?

A5: It can be one or more categories.

Q6: The QRDA III file could include data for a single provider or for the group?

A6: Yes

Q7: The QRDA III file can only contain data for the eCQMs. The eCQMs version ids have to match the ones in measures.json file.

A7: Yes

Q8: For obvious reason, the QRDA III can not be used to submit registry measures. Providers will need to use a registry to submit any registry measures.

A8: Yes

Q9: Can providers use registry to submit the quality data and manually upload ACI and IA data?

A9: Yes

Q10: Our understanding from discussion with QPP support is that there is no separate " EHR certification" to create these new QRDA III files for all categories. By submitting the data, the providers are attesting to the 2 facts below:

The Quality data came from an EHR that was certified for the eCQMs that are included in the submission file

The ACI data came from a certified EHR meaningful use dashboard.

A10: Yes

[Pawan Jindal(MyMipsScore.com)]

Thank you Jonathan. 

[Pooja kini]

 Hi All,

 When the submission window opens on Jan2 in QPP, if EHR vendors can use direct API for data submission or should we go through the QRDA III file conversion only and then submit to API. Please need an official confirmation as this is important for us.

Is Year 1 API Submissions limited only to Qualified Registries /QCDRs. Please confirm

Please confirm.

Thanks & Regards

Dr. Pooja

[Ivana Ng]

For Year 1, EHR vendors must use the QPP website to submit data for MIPS. 

Ivana Ng

Product Manager

Nava

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[Jay Fisher]

When using the file upload method, how will our providers be able to analyze their submission confirmations / shortfalls?  Is there a response file we can download and process?  Can we get the specifications for that response so we can load it into our own systems?  

[sup...@popmso.com]

Hi Ivana,

Could provide more detailed information how to submit ACI & IA measure data using the QPP website?

Does this means that the submitter needs to login as a provider and submit ACI & IA measure data individually?

Is there a way to submit all providers using our EHR system as a group?

Thanks in advance.

// Seung Hyun

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[Sarah White]

Hi Seung Hyun,

Can you post this as a new thread and clarify how you're submitting information to QPP? I'm closing this thread.

Thanks,

Sarah