The AAMC Jan. 12 submitted comments in response to the 2016 Measure Applications Partnership’s (MAP) Pre-Rulemaking Report released in December 2015. The MAP is a public-private, multi-stakeholder partnership established under the Affordable Care Act (ACA, P.L. 111-48 and P.L. 111-152) to provide guidance to the Department of Health and Human Services (HHS) on the selection of quality measures for federal payment and reporting programs. The MAP released preliminary recommendations on the reviewed measures.
The AAMC focused its comments on the clinician and hospital sections of the draft report. For the clinician section, the AAMC asks that the MAP emphasize measures that are truly meaningful to clinicians, address gap areas, and reduce administrative burden. The association also asks the MAP to acknowledge and address concerns that clinicians are being held accountable for care that is outside of their direct control and to allow time for specialties to develop appropriate use and overuse measures that are based on solid evidence.
Additionally, the AAMC cites concerns with a number of measures reviewed by the MAP, including the prevention quality acute composite and prevention quality chronic composite, which have been discussed for use in the Merit-Based Incentive Payment System (MIPS) and Medicare Shared Saving Program (MSSP). The association cites concerns that the measures are not adjusted for sociodemographic status (SDS) factors and are not designed for use at the clinician level.
In response to the hospital section of the report, the AAMC comments that accountability measures must undergo review in the National Quality Forum (NQF)’s SDS trial period prior to inclusion in Medicare’s pay-for-reporting and pay-for-performance quality programs. The NQF is currently holding this trial period to determine whether there is a conceptual and empirical relationship between outcomes and SDS factors for a subset of measures.
The association strongly recommends that all hospital measures be endorsed by the NQF at the time of MAP consideration so that members have a baseline understanding that the measure has been tested, is reliable, and can be used in a specific setting. The AAMC also notes its support for removal of the Patient Safety and Adverse Events Composite measure (PSI-90) from Medicare’s performance programs, due to concerns that the measure is susceptible to surveillance bias, may not be preventable through evidence-based practices, and is unable to capture the full scope of patient risk factors.
The final report is expected to be released in February 2016.