The AAMC Feb. 28 submitted comments to the Centers for Medicare and Medicaid Services (CMS) on its project to develop four hospital-level electronic clinical quality measures (eCQMs). CMS is providing stakeholders the opportunity to comment on measures early in the measure development stage. These measures are not currently under consideration by CMS for use in the Medicare program, but could be considered in the future.
The AAMC is committed to working with CMS to ensure the development of new eCQMS will improve the quality of care while ensuring new measures do not add burdens to hospitals. The AAMC's concerns with some of the measures under development are summarized below:
- Generally, the AAMC continues to have concerns that hospitals and vendors may not be sufficiently prepared to fully report eCQMs and urges CMS to focus on sufficiently addressing current concerns with eCQM reporting and focus on the inclusion of a small number of eCQMs that are meaningful and not overly burdensome for hospitals.
- CMS should complete testing of these eCQMs under development such that the measures demonstrate reliability and validity in the acute care setting and should submit the measures to the National Quality Forum (NQF) for review and endorsement.
- Measures should be developed carefully such that they accurately measure preventable patient harm, are meaningful for patients, and are impactful for quality improvement.
- Measures should be adjusted for clinical risk factors and risk adjustment for socio-demographic risk factors as appropriate to ensure that providers are not held accountable for factors outside of their control.