The AAMC Jan. 10 submitted comments to the National Quality Forum (NQF) regarding the Measure Application Partnership’s (MAP) draft reports to the Centers for Medicare and Medicaid Services (CMS) on 2019 Considerations for Implementing Measures based upon CMS’s 2018 Measures under Consideration List for 2019 pre-rulemaking.
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, P.L. 111-148).
The AAMC is committed to working with the MAP and other stakeholders to evaluate CMS’ proposed measures and appreciates the MAP Workgroups’ thoughtful review and discussion of the 2018 MUC list for 2019 pre-rulemaking. In the comments, the AAMC shared concerns with some of the proposed measures, as summarized below:
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Clinician Measures: Providers should not be held accountable for activities outside their control. Cost measures must be appropriately risk adjusted, including for social risk factors, and the attribution methodology for episodes should clearly and accurately determine the relationship between patient and clinician before the 11 episode-level cost measures under consideration are incorporated into the Quality Payment Program. The two re-evaluated total cost measures, Medicare Spending per Beneficiary and Total Per Capita Cost, must similarly be appropriately adjusted for both clinical and social risk factors before they are proposed for the Quality Payment Program.
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Hospital Measures: The AAMC continues to strongly believe that certain accountability measures must be adjusted for sociodemographic status before being included in the Medicare quality reporting programs and should be NQF-endorsed prior to MAP review.