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AAMC Comments on the MAP Pre-Rulemaking Draft Report

January 16, 2015— The AAMC Jan. 13 submitted a comment letter  on the Measure Applications Partnership’s (MAP) Pre-Rulemaking Report released in December 2014. The 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 list of measures reviewed by the MAP can be found here. The AAMC commented specifically on the hospital and clinician sections of the draft report.

The letter notes AAMC strongly supports appropriate sociodemographic adjustment for readmissions and other accountability measures and supports the MAP recommendations to have several measures included in the National Quality Forum (NQF)’s sociodemographic status (SDS) trial period. The trial period is expected to start in January 2015 and will be used to determine whether there is a conceptual and empirical relationship between measures’ outcomes and SDS factors. The AAMC also urges the MAP to ensure that new and revised measures under consideration are publicly reported before being reviewed for performance programs, are high value, useful for consumers, and are not unduly burdensome for providers to implement.

In response to the clinician section of the report, the AAMC asks that the MAP update the draft report to provide greater context around the complexity of the physician quality reporting process. Unlike for hospitals, clinicians in physician group practices are limited by the number of available measures to report and the methods for submitting such data, be it through Physician Quality Reporting System (PQRS) or Electronic Health Record (EHR) incentive program.

Last, the AAMC urges CMS to take additional steps to align the PQRS, EHR incentive, and value modifier (VM) programs in order to reduce unnecessary burden and complexity for clinicians.

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

The final report is expected to be released in early February 2015.


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


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