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AAMC Submits Comments on Quality Metrics for Health Exchanges

December 28, 2012—The AAMC submitted comments Dec. 27 to the Centers for Medicare and Medicaid Services’ (CMS) request for information (RFI) on quality metrics for federally facilitated health insurance exchanges (Exchanges). CMS sought feedback from stakeholders on 15 broad questions relating to quality improvement strategies, successful quality measures and measure sets, evaluating performance and public reporting, among others.

The AAMC emphasized the following key points in its comments:

  • CMS should avoid building new and potentially redundant infrastructure for data collection and public reporting of quality data for the Exchanges;
  • All quality measures should be evidence-based, reliable, valid, and fully tested before implementation. Quality measures must be both NQF-endorsed and approved by the Measure Applications Partnership (MAP);
  • All quality measures should utilize a robust risk-adjustment methodology to account for differences in severity and risk across patient populations, particularly for socioeconomic factors;
  • CMS should select quality measures for all patient populations, not just those that are Medicare-specific;
  • The quality rating system for Exchanges should align with existing provider and health plan initiatives and include a transparent reporting methodology. Stakeholders should be given adequate time to review the performance data, and have the opportunity to respond to any inaccuracies; and
  • CMS should consider assessing institutions and plans on the availability, publicity, and usage of services targeted to disabled and English second language (ESL) patients.

CMS is still in the early stages of developing quality metrics for Exchanges, and does not expect new quality reporting standards to take effect until 2016.


Jennifer Faerberg, MHSA
Director, Clinical Transformation Unit
Telephone: 202-862-6221

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


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Washington Highlights, a weekly electronic newsletter, features brief updates on the latest legislative and regulatory activities affecting medical schools and teaching hospitals.

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Jason Kleinman
Sr. Legislative Analyst, Govt. Relations
Telephone: 202-903-0806