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AAMC Submits Comments on NQF Measure Application Partnership Draft Report

January 10, 2020

AAMC Submits Comments on NQF Measure Application Partnership Draft Report

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CONTACTS
Phoebe Ramsey, Sr. Regulatory Analyst, Quality & Payment Policy

The AAMC Jan. 8 submitted comments to the National Quality Forum (NQF) regarding the Measure Application Partnership’s (MAP) 2020 Considerations for Implementing Measures in Federal Programs draft report to the Centers for Medicare and Medicaid Services (CMS), based upon CMS’ 2019 Measures under Consideration (MUC) List.

The MAP’s draft report is the last step for public input before the MAP provides program-specific recommendations to CMS as part of the pre-rulemaking process for the selection of quality and efficiency measures for use in the Medicare program as required by Section 3014 of the Affordable Care Act (ACA, P.L. 111-148 and P.L. 111-152).

In its comments, the AAMC highlighted its commitment to working with the MAP and other stakeholders to evaluate CMS’ proposed measures and expressed its appreciation of the MAP Workgroups’ thoughtful discussion of the MUC List and holistic review of Medicare quality programs. The AAMC shared its concerns with some of the proposed measures, as summarized below.

For the hospital measures, the AAMC continues to strongly believe that certain accountability measures must be adjusted for sociodemographic status (SDS) before being included in the Medicare quality reporting programs and be NQF-endorsed prior to MAP review. Additionally, the AAMC recommends that the report appropriately distinguish the Medicare and Medicaid Promoting Interoperability Program for Eligible Hospitals and Critical Access Hospitals (Promoting Interoperability Program) as separate from the Hospital Inpatient Quality Reporting Program (IQR). While electronic clinical quality measures are shared between the two programs, the programs have unique histories and distinct penalties on hospitals for failure to meet a given program’s reporting requirements and the report should appropriately reflect that.

Regarding the clinician measures under consideration, the AAMC strongly believes that providers should not be held accountable for activities outside their control. Measures must be valid and reliable at the clinician or practice group level, including appropriate attribution of outcomes to a single clinician or practice. Similar to hospital measures, the AAMC believes that certain quality measures (particularly outcome and cost measures) must be adjusted for SDS prior to inclusion in the programs.

The AAMC also provided comment on individual measures for consideration for the IQR and the Merit Incentive Payment System and Medicare Shared Savings Program.

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