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AAMC Submits Comments on NQF MAP Draft Recommendations to CMS

January 14, 2022

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CONTACTS
Phoebe Ramsey, Manager of Regulatory Payment Policy & Quality

The AAMC submitted comments on Jan. 13 to the National Quality Forum (NQF) regarding the Measure Application Partnership’s (MAP’s) draft recommendations to the Centers for Medicare & Medicaid Services (CMS) on its 2021 Measures Under Consideration (MUC) List. The MAP is a public-private, multistakeholder partnership established under the Affordable Care Act (ACA, P.L. 111-148 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.

In its comments, the AAMC stated its commitment to working with the MAP and other stakeholders to evaluate the CMS’ proposed measures and noted its appreciation of the MAP workgroups’ thoughtful discussion of the MUC List and holistic review of Medicare quality programs. The letter added that the association continues to strongly believe that measures should be NQF-endorsed as valid and reliable prior to MAP review and that measures should be evaluated in a broader context — not just a given quality program’s measure set but also wider priority areas such as health care equity.

Regarding measures intended to address health care equity, the AAMC commented that measurement at this early stage should balance existing evidence and clinical guidelines to support measuring a given process or structure, the competing need to build an evidence base to inform future interventions, and the context of how the measure might be used within a quality program to avoid potential unintended consequences. Balancing these three considerations can lead to the development of appropriate outcome measures for future consideration, the letter stated.

The AAMC’s comments also noted support for the MAP workgroups’ recommendations to conditionally support the Screening for Social Drivers of Health measure for both hospitals and clinicians, pending NQF endorsement, including efforts to screen patients for their health-related social needs, and agreed that measurement could help improve and standardize screening. The comments affirmed that the NQF endorsement process is vital to ensuring the measure is appropriate for use in the Hospital Inpatient Quality Reporting (IQR) Program and the Merit-based Incentive Payment System (MIPS). In its comments, the AAMC urged the MAP to revise its recommendations to “do not support for rulemaking” for the related Screen Positive Rate for Social Drivers of Health measure due to the lack of clarity on how the measure score should be interpreted and the lack of actionable information to drive quality improvement.

Finally, regarding the Hospital Commitment to Health Equity measure, the association recommended that the MAP consider a “conditional support for rulemaking” recommendation, pending NQF endorsement. The letter stated that the measurement of structures within a hospital’s control and tied to the early evidence base of best practices, such as screening for health-related social needs and performing community needs assessments with community-based partners, can lead to developing valid equity metrics for the future.

The AAMC also provided comment on additional measures for consideration for the IQR and Medicare Promoting Interoperability Programs for hospitals and the MIPS as part of the Quality Payment Program for clinicians and group practices.

The MAP’s final recommendations are expected to be released in February 2022.

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