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AAMC Submits Comments on the MAP Pre-Rulemaking Draft Report

January 27, 2012The AAMC sent a Jan 20 comment letter  on the Measures Application Partnerships’ (MAP) draft Pre-Rulemaking Report, released Jan 11. 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 AAMC comments focus specifically on the clinician and hospital sections of the draft report.

Regarding the MAP clinician recommendations, the AAMC comment letter reiterates that the measures for the physician value modifier should be publicly reported for a minimum of one year before being used in a payment-based performance program. The AAMC letter also expresses its concerns with implementation of the Clinician/Group-Consumer Assessment of Health Providers (CG-CAHPS) measures for payment purposes, without proper testing.

Regarding the hospital sections, the AAMC letter highlights its concerns with the inclusion of readmission composites, which are not actionable by providers and duplicate readmission measures already being publicly reported by hospitals.

The draft report provided input on 368 quality measures, under 18 separate federal programs, that were reviewed by the workgroups. Approximately 40 percent of the measures were supported by the workgroups and the coordinating committee. The workgroups additionally prioritized measures that cut across multiple settings and programs, specifically addressing measures of care coordination.

MAP consists of five workgroups (clinician, hospital, ad hoc safety, dual-eligible beneficiaries, and post-acute/long term care) that provide input to a coordinating committee that makes the final recommendations. The AAMC is a voting member of the clinician workgroup.

A final report is due Feb. 1, 2012.


Scott Wetzel, M.P.P.
Lead, Quality Reporting
Telephone: 202-828-0495


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