NQF
Version Number: 3.6
Meeting
Date: January 26-27, 2016
Measure Applications Partnership
Coordinating Committee Discussion
Guide
Key Tips
- Use the back and forward buttons on your browser to navigate
(such as returning to your place after you've clicked a link).
- Please don't print. The paper version will be very long and
difficult to navigate.
- The discussion guide will be updated as we get more information,
such as public comments.
- Further
instructions and help
- Joining
remotely?
|
Agenda
Agenda Synopsis
Full Agenda
Day 1: January 26,
2016 |
|
|
|
9:30 AM |
Breakfast |
|
|
10:00 AM |
Welcome and Review of Meeting Objectives
|
|
Beth McGlynn, MAP Coordinating Committee Co-Chair Harold Pincus,
MAP Coordinating Committee Co-Chair
|
10:30 AM |
MAP Pre-Rulemaking Approach Updates |
|
Erin O’Rourke, Senior Director, NQF Beth McGlynn
- Review the 2015-2016 MAP Pre-Rulemaking Approach
- Discuss the implementation of measures under development
pathway
- Discuss the process to consider of gap filling
measures
|
11:30 AM |
MAP Pre-Rulemaking Strategic Issues |
|
Taroon Amin, NQF Consultant Harold Pincus
- Review the Risk-adjustment of Measures for Socioeconomic Status
(SES) Trial Period
- Discuss attribution and shared accountability
- Discuss the importance of feedback loops
|
12:30 PM |
Opportunity for Public Comment |
|
|
12:45 PM |
Lunch
|
|
|
1:15 PM |
Pre-Rulemaking Recommendations for PAC/LTC
Programs |
|
Carol Raphael, Workgroup Co-Chair Sarah Sampsel, Senior Director,
NQF Erin O’Rourke Beth McGlynn
- Discuss key themes from the PAC/LTC Workgroup meeting
- Review and finalize broader guidance about programmatic issues
- Review and discuss input from the MAP Dual Eligible Beneficiaries
Workgroup
- Review and finalize workgroup measure
recommendations
|
|
Measures Requiring a Vote on
MAP's Preliminary Recommendation |
|
This section of the meeting includes debate and voting on measures
pulled by MAP Coordinating Committee members. |
|
- Skilled Nursing Facility 30-Day Potentially Preventable
Readmission Measure (SNFPPR) (required by PAMA) (MUC ID:
MUC15-1048)
- Description: All-condition risk-adjusted potentially
preventable hospital readmission rates (required under PAMA) (Measure
Specifications)
- Programs under consideration: Skilled
Nursing Facility Value-Based Purchasing Program
- Public comments received: 11
- Workgroup Rationale: MAP members raised concerns about
potential negative unintended consequences if SNFs are hesitant to
transfer patients to the hospital to avoid penalties. Some MAP members
noted the limited actionability of this measure and that increased
granularity could provide information to improve care. However, other
members stated that providers should implement their own systems for
tracking and identifying these issues for quality improvement.CMS
indicated that this measure would replace the current all-cause
readmission as soon as practical.
- Workgroup Recommendation: Encourage continued
development
- Falls risk composite process measure (MUC ID: MUC15-207)
- Description: Percentage of patients who were assessed for
falls risk and whose care plan reflects the assessment and was
implemented as appropriate. (Measure
Specifications)
- Programs under consideration: Home
Health Quality Reporting Program
- Public comments received: 12
- Workgroup Rationale: MAP noted that this composite measure
addresses falls risk and related clinical intervention assessments,
which are considered safety measures and meet the goals of the Home
Health QRP.
- Workgroup Recommendation: Encourage continued
development
- Hospice and Palliative Care Composite Process Measure (MUC
ID: MUC15-231)
- Description: This measure will assess percentage of hospice
patients who received care processes consistent with guidelines at
admission. This is a composite measure based on select measures from 7
NQF-endorsed measures: NQF #1641, NQF #1647, NQF #1634, NQF #1637, NQF
#1639, NQF #1638, NQF #1617. (Measure
Specifications)
- Programs under consideration: Hospice
Quality Reporting Program
- Public comments received: 19
- Workgroup Rationale: Although MAP encouraged continued
development, members noted the need to balance this measure with what
is relevant to the patient, and not limit to only check box quality
measures.
- Workgroup Recommendation: Encourage continued
development
- Application of IRF Functional Outcome Measure: Change in
Self-Care Score for Medical Rehabilitation Patients (NQF #2633)
(MUC ID: MUC15-236)
- Description: This quality measure estimates the
risk-adjusted mean change in self-care score between admission and
discharge among SNF residents. (The endorsed specifications of the
measure are: This measure estimates the risk-adjusted mean change in
self-care score between admission and discharge for Inpatient
Rehabilitation Facility (IRF) Medicare patients.) (Measure
Specifications; Summary
of NQF Endorsement Review)
- Programs under consideration: Skilled
Nursing Facility Quality Reporting System
- Public comments received: 17
- Workgroup Rationale: The functional status measures are
adaptations of currently endorsed measures for the IRF population.
MAP encouraged continued development to ensure alignment across PAC
settings, but also noted there should be some caution in
interpretation of measure results due to patient differentiation
between facilities.MAP also stressed the importance of considering
burden on providers when measures are considered for
implementation.
- Workgroup Recommendation: Encourage continued
development
- Drug Regimen Review Conducted with Follow-Up for Identified
Issues-Post Acute Care (PAC) Home Health Quality Reporting Program
(Required under the IMPACT Act) (MUC ID: MUC15-1127)
- Description: Percentage of stays Inpatient Rehabilitation
Facility (IRF), Long Term Care Facility (LTCH), and Skilled Nursing
Facility (SNF) or care episodes Home Health (HH) in which a drug
regimen review was conducted at the Admission (IRF, LTCH or SNF)/
Start of Care (SOC)/ Resumption of Care (ROC) (HH) and timely
follow-up with a physician occurred each time potential clinically
significant medication issues were identified throughout the stay
(IRF, LTCH, or SNF) or care episode (HH). (Measure
Specifications)
- Programs under consideration: Home
Health Quality Reporting Program
- Public comments received: 11
- Workgroup Rationale: MAP noted the importance of medication
reconciliation but raised concerns and asked for greater clarity about
the definition of reconciliation versus drug regimen review. Members
also noted the challenge of defining some of the measure components,
specifically “a clinically significant issue” given the large number
of medications a patient may be taking. MAP stressed that medication
reconciliation is a step in a drug regimen review and asked for
greater clarity on defining the drug regimen review process. MAP
stressed the importance of conducting a complete medication review
from all sites of care, including the home. MAP members noted the
value of the role of family caregivers in providing this information
and the hope that technology can help to minimize the burden of
getting this information. MAP members asked for greater emphasis of
the inclusion of non-prescription medication (including supplements),
noting that this is a particular concern in the PAC/LTC population.MAP
members raised some concerns about the feasibility of this measure and
noted the need to clarify the roles of the interdisciplinary team. MAP
noted the importance of attribution issues for this measure.
Additionally, Workgroup members raised concerns about the challenges
of competing guidelines and need for greater clarity about when a
medication can be withdrawn. MAP stressed that medication
reconciliation needs to be an on-going process. MAP also noted that
this is a particular concern for dual-eligible beneficiaries.
- Workgroup Recommendation: Encourage continued
development
- Drug Regimen Review Conducted with Follow-Up for Identified
Issues-Post Acute Care (PAC) Inpatient Rehabilitation Facility Quality
Reporting Program (Required under the IMPACT Act) (MUC ID:
MUC15-1128)
- Description: Percentage of stays Inpatient Rehabilitation
Facility (IRF), Long Term Care Facility (LTCH), and Skilled Nursing
Facility (SNF) or care episodes Home Health (HH) in which a drug
regimen review was conducted at the Admission (IRF, LTCH or SNF)/
Start of Care (SOC)/ Resumption of Care (ROC) (HH) and timely
follow-up with a physician occurred each time potential clinically
significant medication issues were identified throughout the stay
(IRF, LTCH, or SNF) or care episode (HH). (Measure
Specifications)
- Programs under consideration: Inpatient
Rehabilitation Facility Quality Reporting Program
- Public comments received: 8
- Workgroup Rationale: MAP noted the importance of medication
reconciliation but raised concerns and asked for greater clarity about
the definition of reconciliation versus drug regimen review. Members
also noted the challenge of defining some of the measure components,
specifically “a clinically significant issue” given the large number
of medications a patient may be taking. MAP stressed that medication
reconciliation is a step in a drug regimen review and asked for
greater clarity on defining the drug regimen review process. MAP
stressed the importance of conducting a complete medication review
from all sites of care, including the home. MAP members noted the
value of the role of family caregivers in providing this information
and the hope that technology can help to minimize the burden of
getting this information. MAP members asked for greater emphasis of
the inclusion of non-prescription medication (including supplements),
noting that this is a particular concern in the PAC/LTC population.MAP
members raised some concerns about the feasibility of this measure and
noted the need to clarify the roles of the interdisciplinary team. MAP
noted the importance of attribution issues for this measure.
Additionally, Workgroup members raised concerns about the challenges
of competing guidelines and need for greater clarity about when a
medication can be withdrawn. MAP stressed that medication
reconciliation needs to be an on-going process. MAP also noted that
this is a particular concern for dual-eligible beneficiaries.
- Workgroup Recommendation: Encourage continued
development
- Drug Regimen Review Conducted with Follow-Up for Identified
Issues-Post Acute Care (PAC) Long-Term Care Hospital Quality Reporting
Program (Required under the IMPACT Act) (MUC ID: MUC15-1129)
- Description: Percentage of stays Inpatient Rehabilitation
Facility (IRF), Long Term Care Facility (LTCH), and Skilled Nursing
Facility (SNF) or care episodes Home Health (HH) in which a drug
regimen review was conducted at the Admission (IRF, LTCH or SNF)/
Start of Care (SOC)/ Resumption of Care (ROC) (HH) and timely
follow-up with a physician occurred each time potential clinically
significant medication issues were identified throughout the stay
(IRF, LTCH, or SNF) or care episode (HH). (Measure
Specifications)
- Programs under consideration: Long-Term
Care Hospital Quality Reporting Program
- Public comments received: 4
- Workgroup Rationale: MAP noted the importance of medication
reconciliation but raised concerns and asked for greater clarity about
the definition of reconciliation versus drug regimen review. Members
also noted the challenge of defining some of the measure components,
specifically “a clinically significant issue” given the large number
of medications a patient may be taking. MAP stressed that medication
reconciliation is a step in a drug regimen review and asked for
greater clarity on defining the drug regimen review process. MAP
stressed the importance of conducting a complete medication review
from all sites of care, including the home. MAP members noted the
value of the role of family caregivers in providing this information
and the hope that technology can help to minimize the burden of
getting this information. MAP members asked for greater emphasis of
the inclusion of non-prescription medication (including supplements),
noting that this is a particular concern in the PAC/LTC population.MAP
members raised some concerns about the feasibility of this measure and
noted the need to clarify the roles of the interdisciplinary team. MAP
noted the importance of attribution issues for this measure.
Additionally, Workgroup members raised concerns about the challenges
of competing guidelines and need for greater clarity about when a
medication can be withdrawn. MAP stressed that medication
reconciliation needs to be an on-going process. MAP also noted that
this is a particular concern for dual-eligible beneficiaries.
- Workgroup Recommendation: Encourage continued
development
- Drug Regimen Review Conducted with Follow-Up for Identified
Issues-Post Acute Care (PAC) Skilled Nursing Facility Quality Reporting
Program (Required under the IMPACT Act) (MUC ID: MUC15-1130)
- Description: Percentage of stays Inpatient Rehabilitation
Facility (IRF), Long Term Care Facility (LTCH), and Skilled Nursing
Facility (SNF) or care episodes Home Health (HH) in which a drug
regimen review was conducted at the Admission (IRF, LTCH or SNF)/
Start of Care (SOC)/ Resumption of Care (ROC) (HH) and timely
follow-up with a physician occurred each time potential clinically
significant medication issues were identified throughout the stay
(IRF, LTCH, or SNF) or care episode (HH). (Measure
Specifications)
- Programs under consideration: Skilled
Nursing Facility Quality Reporting System
- Public comments received: 11
- Workgroup Rationale: MAP noted the importance of medication
reconciliation but raised concerns and asked for greater clarity about
the definition of reconciliation versus drug regimen review. Members
also noted the challenge of defining some of the measure components,
specifically “a clinically significant issue” given the large number
of medications a patient may be taking. MAP stressed that medication
reconciliation is a step in a drug regimen review and asked for
greater clarity on defining the drug regimen review process. MAP
stressed the importance of conducting a complete medication review
from all sites of care, including the home. MAP members noted the
value of the role of family caregivers in providing this information
and the hope that technology can help to minimize the burden of
getting this information. MAP members asked for greater emphasis of
the inclusion of non-prescription medication (including supplements),
noting that this is a particular concern in the PAC/LTC population.MAP
members raised some concerns about the feasibility of this measure and
noted the need to clarify the roles of the interdisciplinary team. MAP
noted the importance of attribution issues for this measure.
Additionally, Workgroup members raised concerns about the challenges
of competing guidelines and need for greater clarity about when a
medication can be withdrawn. MAP stressed that medication
reconciliation needs to be an on-going process. MAP also noted that
this is a particular concern for dual-eligible beneficiaries.
- Workgroup Recommendation: Encourage continued
development
- Medicare Spending Per Beneficiary-Post Acute Care (PAC) Home
Health Quality Reporting Program (Required under the IMPACT Act)
(MUC ID: MUC15-1134)
- Description: The MSPB-PAC Measure for HHAs evaluates
providers’ efficiency relative to the efficiency of the national
median HHA provider. Specifically, the MSPB-PAC Measure assesses the
cost to Medicare for services during an episode of care, which
consists of a treatment period and an associated services period. The
episode is triggered by the initiation of a 60 day HHA service period.
The treatment period begins at the trigger and ends on the last day of
the service period. The associated services period begins at the
trigger and ends 30 days after the end of the treatment period. These
periods constitute the episode window during which beneficiaries’
Medicare services are counted toward the episode. The MSPB-PAC episode
includes all services during the episode window that are attributable
to the HHA provider and those rendered by other providers, except
those services during the associated services period that are
clinically unrelated to HHA responsibilities (e.g., planned care and
routine screening). (Measure
Specifications)
- Programs under consideration: Home
Health Quality Reporting Program
- Public comments received: 10
- Workgroup Rationale: Members noted the importance of
balancing cost measures with quality and access. Although the MAP
encouraged continued development, they did note concerns about the
potential for unintended consequences. In particular, the group raised
concerns about issues of premature discharges. The group noted this
could put a tremendous burden on family caregivers who may have to
care for a patient they are not fully able to support. Members also
noted the need to consider risk adjustment for severity and
socioeconomic status.
- Workgroup Recommendation: Encourage continued
development
- Medicare Spending per Beneficiary-Post Acute Care (PAC) Inpatient
Rehabilitation Facility Quality Reporting Program (Required under the
IMPACT Act) (MUC ID: MUC15-287)
- Description: The MSPB-PAC Measure for IRFs evaluates
providers’ efficiency relative to the efficiency of the national
median IRF provider. Specifically, the MSPB-PAC Measure assesses the
cost to Medicare for services during an episode of care, which
consists of a treatment period and an associated services period. The
episode is triggered by an admission to an IRF stay. The treatment
period begins at the trigger and ends at discharge. The associated
services period begins at the trigger and ends 30 days after the end
of the treatment period (i.e., discharge). These periods constitute
the episode window during which beneficiaries’ Medicare services are
counted toward the episode. The MSPB-PAC episode includes all services
during the episode window that are attributable to the IRF provider
and those rendered by other providers, except those services during
the associated services period that are clinically unrelated to IRF
responsibilities (e.g., planned care and routine screening). (Measure
Specifications)
- Programs under consideration: Inpatient
Rehabilitation Facility Quality Reporting Program
- Public comments received: 12
- Workgroup Rationale: MAP noted that socioeconomic status is
a particular concern for IRFs. Patients need social supports to be
able to return to the community with a disability. Additionally, it
was suggested that providers who are teaching facilities and serve low
income patients may have higher costs than others.
- Workgroup Recommendation: Encourage continued
development
- Medicare Spending per Beneficiary-Post Acute Care (PAC) Long-Term
Care Hospital Quality Reporting Program (Required under the IMPACT Act)
(MUC ID: MUC15-289)
- Description: The MSPB-PAC Measure for LTCHs evaluates
providers’ efficiency relative to the efficiency of the national
median LTCH provider. Specifically, the MSPB-PAC Measure assesses the
cost to Medicare for services during an episode of care, which
consists of a treatment period and an associated services period. The
episode is triggered by an admission to an LTCH stay. The treatment
period begins at the trigger and ends at discharge. The Measure is
constructed differently for cases in which the LTCH stay is paid
according to the standard MS-LTC-DRG versus cases in which the LTCH
stay is paid a site neutral rate comparable to the IPPS payment rates.
The associated services period for standard payment rate cases begins
at the trigger and ends 30 days after the end of the treatment period
(i.e., discharge). The associated services period for site neutral
payment rate cases begins at the close of the treatment period and
ends 30 days after, to parallel the MSPB-Hospital measure. For the
standard and site neutral cases, these periods constitute the episode
window during which beneficiaries’ Medicare services are counted
toward the episode. For the standard cases, the MSPB-PAC episode
includes all services during the episode window that are attributable
to the LTCH provider and those rendered by other providers, except
those services during the associated services period that are
clinically unrelated to LTCH responsibilities (e.g., planned care and
routine screening). For the site neutral cases, the MSPB-PAC episode
includes all services during the episode window that are attributable
to the LTCH provider and those rendered by other providers, except
those services during the associated services period that are
clinically unrelated to LTCH responsibilities (e.g., planned care and
routine screening). As discussed above, there is a difference in the
construction of the associated services period for these cases, in
that it only begins at discharge and ends 30 days after. (Measure
Specifications)
- Programs under consideration: Long-Term
Care Hospital Quality Reporting Program
- Public comments received: 8
- Workgroup Rationale: Members noted the importance of
balancing cost measures with quality and access. Although the MAP
encouraged continued development, they did note concerns about the
potential for unintended consequences.
- Workgroup Recommendation: Encourage continued
development
- Medicare Spending per Beneficiary-Post Acute Care (PAC) Skilled
Nursing Facility Quality Reporting Program (Required under the IMPACT
Act) (MUC ID: MUC15-291)
- Description: The MSPB-PAC Measure for SNFs evaluates
providers’ efficiency relative to the efficiency of the national
median SNF provider. Specifically, the MSPB-PAC Measure assesses the
cost to Medicare for services during an episode of care, which
consists of a treatment period and an associated services period. The
episode is triggered by an admission to a SNF stay. The treatment
period begins at the trigger and ends at discharge. The associated
services period begins at the trigger and ends 30 days after the end
of the treatment period (i.e., discharge). These periods constitute
the episode window during which beneficiaries’ Medicare services are
counted toward the episode. The MSPB-PAC episode includes all services
during the episode window that are attributable to the SNF provider
and those rendered by other providers, except those services during
the associated services period that are clinically unrelated to SNF
responsibilities (e.g., planned care and routine screening). (Measure
Specifications)
- Programs under consideration: Skilled
Nursing Facility Quality Reporting System
- Public comments received: 10
- Workgroup Rationale: Members noted the importance of
balancing cost measures with quality and access. Although the MAP
encouraged continued development, they did note concerns about the
potential for unintended consequences. The group also raised concerns
about the impact on rural providers. Additionally, MAP raised concerns
that measuring acute and post-acute care separately could discourage
innovative partnerships between hospitals and PAC/LTC providers.
- Workgroup Recommendation: Encourage continued
development
|
|
Measures Identified for
Discussion (No Vote Required) |
|
This section of the meeting includes discussion on specific measures
(no vote required) where MAP Coordinating Committee members would like to
add themes to the recommendation rationale or better understand the
workgroup deliberations. |
|
- Discharge to Community-Post Acute Care (PAC) Inpatient
Rehabilitation Facility Quality Reporting Program (Required under the
IMPACT Act) (MUC ID: MUC15-408)
- Description: This measure describes the risk-standardized
rate of Medicare fee-for-service (FFS) patients/residents/persons who
are discharged to the community following a post-acute stay/episode,
and do not have an unplanned (re)admission to an acute care hospital
or LTCH in the 31 days following discharge to community, and remain
alive during the 31 days following discharge to community. (Measure
Specifications)
- Programs under consideration: Inpatient
Rehabilitation Facility Quality Reporting Program
- Public comments received: 14
- Workgroup Rationale: MAP noted that available discharge
codes and coding practices could cause confusion about the results of
this measure and could also introduce validity concerns. MAP asked for
greater clarity about the intent of these measures, especially how
they may impact patients and consumers. MAP members raised concerns
about the multiple ways that readmissions are being measured and noted
that a provider could potentially be penalized multiple times for the
same occurrence. MAP noted the need for excluding patients who are
admitted to hospice to prevent discouraging discharges to hospice. MAP
also noted that discharge to community can reflect access to social
support and the measure may need to reflect this. MAP indicated the
need for these measures to be submitted for NQF review and endorsement
to address psychometric concerns about the measures.MAP members noted
concerns about the risk adjustment of these measures, particularly for
the home health setting. MAP specifically noted the need to
appropriately risk adjust the measures to avoid unintended
consequences.
- Workgroup Recommendation: Encourage continued
development
- Discharge to Community-Post Acute Care (PAC) Long-Term Care
Hospital Quality Reporting Program (Required under the IMPACT Act)
(MUC ID: MUC15-414)
- Description: This measure describes the risk-standardized
rate of Medicare fee-for-service (FFS) patients/residents/persons who
are discharged to the community following a post-acute stay/episode,
and do not have an unplanned (re)admission to an acute care hospital
or LTCH in the 31 days following discharge to community, and remain
alive during the 31 days following discharge to community. (Measure
Specifications)
- Programs under consideration: Long-Term
Care Hospital Quality Reporting Program
- Public comments received: 12
- Workgroup Rationale: MAP noted that available discharge
codes and MAP noted that available discharge codes and coding
practices could cause confusion about the results of this measure and
could also introduce validity concerns. MAP asked for greater clarity
about the intent of these measures, especially how they may impact
patients and consumers. MAP members raised concerns about the multiple
ways that readmissions are being measured and noted that a provider
could potentially be penalized multiple times for the same occurrence.
MAP noted the need for excluding patients who are admitted to hospice
to prevent discouraging discharges to hospice. MAP also noted that
discharge to community can reflect access to social support and the
measure may need to reflect this. MAP indicated the need for these
measures to be submitted for NQF review and endorsement to address
psychometric concerns about the measures.MAP members noted concerns
about the risk adjustment of these measures, particularly for the home
health setting. MAP specifically noted the need to appropriately risk
adjust the measures to avoid unintended consequences.
- Workgroup Recommendation: Encourage continued
development
- Discharge to Community-Post Acute Care (PAC) Skilled Nursing
Facility Quality Reporting Program (Required under the IMPACT Act)
(MUC ID: MUC15-462)
- Description: This measure describes the risk-standardized
rate of Medicare fee-for-service (FFS) patients/residents/persons who
are discharged to the community following a post-acute stay/episode,
and do not have an unplanned (re)admission to an acute care hospital
or LTCH in the 31 days following discharge to community, and remain
alive during the 31 days following discharge to community. (Measure
Specifications)
- Programs under consideration: Skilled
Nursing Facility Quality Reporting System
- Public comments received: 14
- Workgroup Rationale: MAP noted that available discharge
codes and coding practices could cause confusion about the results of
this measure and could also introduce validity concerns. MAP asked for
greater clarity about the intent of these measures, especially how
they may impact patients and consumers. MAP members raised concerns
about the multiple ways that readmissions are being measured and noted
that a provider could potentially be penalized multiple times for the
same occurrence. MAP noted the need for excluding patients who are
admitted to hospice to prevent discouraging discharges to hospice. MAP
also noted that discharge to community can reflect access to social
support and the measure may need to reflect this. MAP indicated the
need for these measures to be submitted for NQF review and endorsement
to address psychometric concerns about the measures.MAP members noted
concerns about the risk adjustment of these measures, particularly for
the home health setting. MAP specifically noted the need to
appropriately risk adjust the measures to avoid unintended
consequences.
- Workgroup Recommendation: Encourage continued
development
|
|
Finalizing Workgroup Recommendations for All
PAC/LTC Programs |
|
This section of the meeting finalizes the remaining workgroup
recommendations for:
|
2:15 PM |
Opportunity for Public
Comment
|
|
|
2:30 PM |
Pre-Rulemaking Recommendations for Clinician
Programs |
|
Bruce Bagley, Workgroup Chair Eric Whitacre, Workgroup Chair
Reva Winkler, Senior Director, NQF Andrew Lyzenga, Senior Director,
NQF Harold Pincus
- Discuss key themes from the Clinician Workgroup meeting
- Review and finalize broader guidance about programmatic issues
- Review and discuss input from the MAP Dual Eligible Beneficiaries
Workgroup
- Review and finalize workgroup measure
recommendations
|
|
Measures Requiring a Vote on
MAP's Preliminary Recommendation |
|
This section of the meeting includes debate and voting on measures
pulled by MAP Coordinating Committee members. |
|
- Surveillance colonoscopy for dysplasia in colonic Crohns Disease
(MUC ID: MUC15-212)
- Description: Percentage of patients with diagnosis of
colonic Crohn’s Disease for 10 years or more that have documented
colonoscopy in the measurement period or 1 year prior to measurement
period. (Measure
Specifications)
- Programs under consideration: Merit-Based
Incentive Payment System (MIPS)
- Public comments received: 8
- Workgroup Rationale: Crohn's disease is a chronic
inflammatory disease of the digestive tract. Symptoms include
abdominal pain and diarrhea, sometimes bloody, and weight loss.
Crohn’s patients are at higher risk for colon cancer. American Society
for Gastrointestinal Endoscopy (ASGE) guidelines recommend that
patients with Crohn’s Disease for more than 10 years should have a
surveillance colonoscopy every 1-2 years. Although there are no
measures that focus on Crohn’s Disease in the current measures set and
this measure would complement other colonoscopy measures MAP is
concerned that the measure could be better specified to discourage
overuse as well as encourage appropriate use of endoscopy. Comments
from the American Gastroenterological Association do not support this
measure and American Society for Gastrointestinal Endoscopy commented
"While ASGE finds the inclusion of surveillance measures in public
reporting programs worthy of exploration, this measure, as specified,
would not deter overutilization of colonoscopy. The recommendations
for surveillance colonoscopy in Crohn’s disease are based on how long
the patient has had the disease."
- Workgroup Recommendation: Do not encourage further
consideration
- NMSC: Biopsy Reporting Time - Pathologist (MUC ID:
MUC15-216)
- Description: Length of time taken from when the pathologist
completes the final biopsy report to when s/he sends the final report
to the biopsying physician. This measure evaluates the reporting time
between pathologist and biopsying clinician. (Measure
Specifications)
- Programs under consideration: Merit-Based
Incentive Payment System (MIPS)
- Public comments received: 7
- Workgroup Rationale: MAP does not encourage further
consideration of this measure for accountability programs. This
"behind the scenes" measure is appropriate for quality improvement and
systems improvement.
- Workgroup Recommendation: Do not encourage further
consideration
- Hepatitis C Virus (HCV)- Sustained Virological Response (SVR)
(MUC ID: MUC15-229)
- Description: Percentage of Patients aged 18 years and older
with a diagnosis of hepatitis C who have completed a full course of
antiviral treatment with undetectable hepatitis C virus (HCV)
ribonucleic acid (RNA) 11 weeks after cessation of treatment. (Measure
Specifications)
- Programs under consideration: Merit-Based
Incentive Payment System (MIPS)
- Public comments received: 8
- Workgroup Rationale: This is an intermediate outcome that
reflects the treatment for Hepatitis C. Recent studies report that
combining several oral antivirals—drugs taken in pill form, not as
injections—clear the virus from the liver in more than 95% of people
in just 12 weeks. The new medications are very expensive though
cost-effectiveness studies conclude that treatment is cost-effective
in most patients. This measure only captures patients that begin
treatment – patient that cannot afford the medications are not
included. This is an intermediate outcome measure related to process
measure PQRS#087/NQF #0398 Hepatitis C: Hepatitis C Virus (HCV)
Ribonucleic Acid (RNA) Testing Between 4-12 Weeks After Initiation of
Treatment. MAP encourages continued development but noted that data on
current performance would provide a better understanding of gap in
care. Public comments on this measure were mixed with some strongly
supporting and other not.
- Workgroup Recommendation: Encourage continued
development
- Screening endoscopy for varices in patients with cirrhosis
(MUC ID: MUC15-251)
- Description: Percentage of patients with diagnosis of
cirrhosis that have documented endoscopy (Measure
Specifications)
- Programs under consideration: Merit-Based
Incentive Payment System (MIPS)
- Public comments received: 6
- Workgroup Rationale: Esophageal varices (dilated veins) are
a serious complications of cirrhosis of the liver. Screening for
varices allows treatment to prevent variceal hemorrhage. Endoscopy is
the standard for diagnosing varices. AASLD guidelines recommend
endoscopy at the time of diagnosis when the prevalence of medium/large
varices is 15-25% (Class IIa, Level C evidence.) Follow up screening
every 1-2 years is recommended depending on the initial findings. If
patients have small varices, follow up endoscopy is not necessary.
All recommendations are Level C evidence so there is little empirical
evidence that screening endoscopy will impact patient outcomes.
Endoscopy carries significant costs, so evidence-based indications are
needed. MAP does not encourage continued development because while
this measure would address a new topic area in the set, the screening
recommendation is not based on solid empirical evidence. The submitter
did not provide any information on opportunity for improvement.
Comments from the American Gastroenterological Association do not
support this measure and American Society for Gastrointestinal
Endoscopy commented "ASGE does not support advancement of this measure
as specified. This measure would not deter overutilization of
colonoscopy. Most guidelines suggest screening every 3 years in
cirrhotic and within a year if they are decompensated."
- Workgroup Recommendation: Do not encourage further
consideration
- Ischemic Vascular Disease All or None Outcome Measure (Optimal
Control) (MUC ID: MUC15-275)
- Description: The IVD All-or-None Measure is one outcome
measure (optimal control). The measure contains four goals. All four
goals within a measure must be reached in order to meet that measure.
The numerator for the all-or-none measure should be collected from the
organization's total IVD denominator. All-or-None Outcome Measure
(Optimal Control) - Using the IVD denominator optimal results include:
Most recent blood pressure measurement is less than 140/90 mm Hg --
And Most recent tobacco status is Tobacco Free -- And Daily Aspirin or
Other Antiplatelet Unless Contraindicated -- And Statin Use (Measure
Specifications)
- Programs under consideration: Merit-Based
Incentive Payment System (MIPS)
- Public comments received: 5
- Workgroup Rationale: Composite measures of evidence-based
processes and intermediate clinical outcomes combine multiple factors
important to care and address whether a patients is receiving all the
evidence-based care they receive. Most of the atherosclerotic disease
measures enjoy high performance individually, but the composite
reveals that the results are not uniformly high for individual
patients. Opportunity for improvement exists which can further reduce
the risks of poor outcomes for patients and represents a measure that
promotes high performance. CMS recently removed PQRS #349 (NQF#0076)
Optimal Vascular Care - an all-or-none-composite measure - because it
is duplicative of the Millions Hearts measures. MAP supports use of
both a composite measure as well as the individual measures for the
Millions Hearts campaign. This measure, MUC15-275 is a competing
measure with PQRS #349 (NQF#0076) – both are all-or-none composite
measures for ischemic vascular disease. NQF will be evaluating both
measures side-by-side in the upcoming Cardiovascular - Phase 4
project. CONDITION: MAP conditionally supports this measure pending
the outcome of the NQF evaluation of both composite measures. MAP
supports inclusion of the composite measure that is considered
best-in-class by the NQF review.
- Workgroup Recommendation: Conditional
support
- Prevention Quality Indicators 92 Prevention Quality Chronic
Composite (MUC ID: MUC15-576)
- Description: PQI composite of chronic conditions per
100,000 population, ages 18 years and older. Includes admissions for
one of the following conditions: diabetes with short-term
complications, diabetes with long-term complications, uncontrolled
diabetes without complications, diabetes with lower-extremity
amputation, chronic obstructive pulmonary disease, asthma,
hypertension, heart failure, or angina without a cardiac procedure.
(Includes PQIs 1, 3, 5, 7, 8, 13, 14, 15, and 16) (Measure
Specifications)
- Programs under consideration: Merit-Based
Incentive Payment System (MIPS)
- Public comments received: 8
- Workgroup Rationale: This composite measure combines AHRQ's
PQI individual measures for admissions for several chronic conditions.
This composite measure for population health encourages care
coordination and efficient use of healthcare services and is sensitive
to dual eligible patients. MAP encourages continued development and
testing of this measure with attention to applicability at the
clinician level of analysis and the risk-adjustment model under
development. MAP suggests considering sociaodemographic factors also.
CMS advised MAP that this composite is already used in the Physician
Value Modifier Program.
- Workgroup Recommendation: Encourage continued
development
- Prevention Quality Indicators 92 Prevention Quality Chronic
Composite (MUC ID: MUC15-576)
- Description: PQI composite of chronic conditions per
100,000 population, ages 18 years and older. Includes admissions for
one of the following conditions: diabetes with short-term
complications, diabetes with long-term complications, uncontrolled
diabetes without complications, diabetes with lower-extremity
amputation, chronic obstructive pulmonary disease, asthma,
hypertension, heart failure, or angina without a cardiac procedure.
(Includes PQIs 1, 3, 5, 7, 8, 13, 14, 15, and 16) (Measure
Specifications)
- Programs under consideration: Medicare
Shared Savings Program
- Public comments received: 9
- Workgroup Rationale: This composite measure combines AHRQ's
PQI individual measures for admissions for several chronic conditions.
This composite measure for population health encourages care
coordination and efficient use of healthcare services and is sensitive
to dual eligible patients. MAP encourages continued development and
testing of this measure with attention to applicability at the ACO
level of analysis and the risk-adjustment model under development.
MAP suggests considering sociodemographic factors also. CMS advised
MAP that this composite is already used in the Physician Value
Modifier Program.
- Workgroup Recommendation: Encourage continued
development
- PQI 91 Prevention Quality Acute Composite (MUC ID:
MUC15-577)
- Description: PQI composite of acute conditions per 100,000
population, ages 18 years and older. Includes admissions with a
principal diagnosis of one of the following conditions: dehydration,
bacterial pneumonia, or urinary tract infection. (Includes PQIs 10,
11, and 12) (Measure
Specifications)
- Programs under consideration: Merit-Based
Incentive Payment System (MIPS)
- Public comments received: 8
- Workgroup Rationale: This composite measure combines AHRQ's
PQIs individual measures for three acute conditions. MAP encourages
continued development of this composite with testing at the clinician
level with the new risk-adjustment model that includes co-morbidities.
This composite measure for population health encourages care
coordination and efficient use of healthcare services and is sensitive
to dual eligible patients. This measure encourages appropriate care of
acute conditions in the ambulatory setting to avoid hospitalization
which is highly desirable for patients and families. However, MAP
raised concerns about the potential for promoting antibiotic overuse
such as overtreatment for aspiration pneumonia particularly in
patients residing in nursing homes and unnecessary treatment for
asymptomatic bactiuria. MAP questioned whether there could be
interaction of this measure with the hospital acquired
condition(HACs)measures - the developer responded that the present on
admission codes used for these measures are excluded for the HACs. CMS
advised MAP that this composite is already used in the Physician Value
Modifier Program. CMS advised that they are considering attribution
and geographical comparisons.
- Workgroup Recommendation: Encourage continued
development
- PQI 91 Prevention Quality Acute Composite (MUC ID:
MUC15-577)
- Description: PQI composite of acute conditions per 100,000
population, ages 18 years and older. Includes admissions with a
principal diagnosis of one of the following conditions: dehydration,
bacterial pneumonia, or urinary tract infection. (Includes PQIs 10,
11, and 12) (Measure
Specifications)
- Programs under consideration: Medicare
Shared Savings Program
- Public comments received: 7
- Workgroup Rationale: This composite measure combines AHRQ's
PQIs individual measures for three acute conditions. MAP encourages
continued development of this composite with testing at the ACO level
with the new risk-adjustment model that includes co-morbidities. This
composite measure for population health encourages care coordination
and efficient use of healthcare services and is sensitive to dual
eligible patients. This measure encourages appropriate care of acute
conditions in the ambulatory setting to avoid hospitalization which is
highly desirable for patients and families. However, MAP raised
concerns about the potential for promoting antibiotic overuse such as
overtreatment for aspiration pneumonia particularly in patients
residing in nursing homes and unnecessary treatment for asymptomatic
bactiuria. MAP questioned whether there could be interaction of this
measure with the hospital acquired condition(HACs)measures - the
developer responded that the present on admission codes used for these
measures are excluded for the HACs. CMS advised MAP that this
composite is already used in the Physician Value Modifier Program.
- Workgroup Recommendation: Encourage continued
development
- Falls: Screening, Risk-Assessment, and Plan of Care to Prevent
Future Falls (MUC ID: MUC15-579)
- Description: This is a clinical process measure that
assesses falls prevention in older adults. The measure has three
rates: A) Screening for Future Fall Risk: Percentage of patients aged
65 years of age and older who were screened for future fall risk at
least once within 12 months; B) Falls: Risk Assessment: Percentage of
patients aged 65 years of age and older with a history of falls who
had a risk assessment for falls completed within 12 months; C) Plan of
Care for Falls: Percentage of patients aged 65 years of age and older
with a history of falls who had a plan of care for falls documented
within 12 months. (Measure
Specifications; Summary
of NQF Endorsement Review)
- Programs under consideration: Medicare
Shared Savings Program
- Public comments received: 7
- Workgroup Rationale: Prevention of falls is a
cross-cutting, patient safety measure applicable to all Medicare
patients. This NQF-endorsed measure is aligned with PQRS.
- Workgroup Recommendation: Support
- Paired Measure: Depression Utilization of the PHQ-9 Tool;
Depression Remission at Six Months; Depression Remission at Twelve
Months (MUC ID: MUC15-928)
- Description: This three-component paired measure assesses
whether the PHQ-9 screening tool was used among patients with a
diagnosis of major depression or dysthymia, and using patient reports,
whether patients with an initial PHQ score >9 demonstrate remission
(i.e., PHQ score >5) at six or 12 months. (Measure
Specifications)
- Programs under consideration: Merit-Based
Incentive Payment System (MIPS)
- Public comments received: 8
- Workgroup Rationale: In 2006 and 2008, an estimated 9.1% of
U.S. adults reported symptoms for current depression.1 Persons with a
current diagnosis of depression and a lifetime diagnosis of depression
or anxiety were significantly more likely than persons without these
conditions to have cardiovascular disease, diabetes, asthma and
obesity and to be a current smoker, to be physically inactive and to
drink heavily. There is an opportunity for improvement for the
population captured by this paired measure, which includes two PROs.
MAP noted that the clinician set contains measure NQF#710/PQRS#370
Depression Remission at Twelve months and NQF#712 and
PQRS#371Depressison Utilization of the PHQ-9. CMS advised that the
public-private collaboration ongoing to development core sets of
measures to foster better alignment will include measures
NQF#710/PQRS#370 and NQF#1895 Assessment of mental status for
community-acquired bacterial pneumonia. This NQF-endorsed measure is a
patient-reported outcome. This updated three-part measure consolidates
two current measures in the PQRS and Meaningful Use programs. MAP was
advised that the data collected for the current measures can be used
for this measures without additional burden. MAP also notes that this
new measure is more aggressive that the current measures and supports
this measure with the following CONDITIONS: look at the response
rates; consider risk-stratification to minimize adverse selection;
consider target rates for different types of providers and consider
alignment with the core measures.
- Workgroup Recommendation: Conditional
Support
- Screening for Hepatoma in patients with Chronic Hepatitis B
(MUC ID: MUC15-217)
- Description: Percentage of patients with a diagnosis of
Chronic Hepatitis B that have had a documented abdominal US, CT Scan,
or MRI in the measurement period (Measure
Specifications)
- Programs under consideration: Merit-Based
Incentive Payment System (MIPS)
- Public comments received: 8
- Workgroup Rationale: This measure addresses a new topic
area of Hepatitis B and is related to PQRS# 401 Screening for
Hepatocellular Carcinoma (HCC) in patients with Hepatitis C Cirrhosis.
A systematic review of Screening for Hepatocellular Carcinoma in
Chronic Liver Disease concluded that “There is very-low-strength
evidence about the effects of HCC screening on mortality in patients
with chronic liver disease. Screening tests can identify early-stage
HCC, but whether systematic screening leads to a survival advantage
over clinical diagnosis is uncertain.” The frequency of imaging is not
specified. MAP does not encourage further consideration because the
current evidence indicates that the benefit to patients is uncertain.
The costs of screening without evidence of a benefit are not
justified. Comments from the American Gastroenterological Association
do not support this measure and American Society for Gastrointestinal
Endoscopy commented "ASGE does not support advancement of this measure
at this time as the measure concept lacks sufficient evidence to show
importance to measure and variation in performance."
- Workgroup Recommendation: Do not encourage further
consideration
|
|
Measures Identified for
Discussion (No Vote Required) |
|
This section of the meeting includes discussion on specific measures
(no vote required) where MAP Coordinating Committee members would like to
add themes to the recommendation rationale or better understand the
workgroup deliberations. |
|
- Hepatitis A vaccination for patients with cirrhosis (MUC ID:
MUC15-210)
- Description: Percentage of patients with diagnosis of
cirrhosis that have documented hepatitis A vaccination (Measure
Specifications)
- Programs under consideration: Merit-Based
Incentive Payment System (MIPS)
- Public comments received: 9
- Workgroup Rationale: The ACIP recommends Hepatitis A
vaccination: "Although not at increased risk for Hep A infection,
persons with chronic liver disease are at increased risk for fulminant
hepatitis A. Death certificate data indicate a higher prevalence of
chronic liver disease among persons who died of fulminant hepatitis A
compared with persons who died of other causes. Vaccination against
viral hepatitis for patients with cirrhosis can improve long term
clinical outcomes. (ACIP 2014)MAP encouraged continued development of
this measure but strongly recommends this measure be fully harmonized
with PQRS#183/NQF#0399 Hepatitis C: Hepatitis vaccination or better
yet, consolidate both into a single vaccination measure for patients
with chronic liver disease as recommended by ACIP. The measure is
duals sensitive. The registry is not specified. Data on current
performance would provide a better understanding of the gap in care.
Public comments on this measure were mixed with some strongly
supporting and other not.
- Workgroup Recommendation: Encourage continued
development
- Hepatitis B vaccination for patients with chronic Hepatitis C
(MUC ID: MUC15-220)
- Description: Percentage of patients with diagnosis of
chronic Hepatitis C that have documented hepatitis B vaccination (Measure
Specifications)
- Programs under consideration: Merit-Based
Incentive Payment System (MIPS)
- Public comments received: 7
- Workgroup Rationale: CDC recommends that all patients with
chronic liver disease are vaccinated for hepatitis B. MAP encourages
continued development with strong consideration to consolidating this
measure as Hepatitis B vaccination for all patients with chronic liver
disease, including hepatitis C as recommended by CDC, i.e., combine
this measure with the MUC for Hepatitis B vaccination for patients
with cirrhosis. Importantly, the specifications should specify that
all doses of the vaccine should be given to get credit for this
measure. This measure is duals sensitive. Data on current performance
would provide better understanding of the gap in care. The registry
is not specified. Public comments on this measure were mixed with some
strongly supporting and other not.
- Workgroup Recommendation: Encourage continued
development
- Hepatitis B vaccination for patients with cirrhosis (MUC ID:
MUC15-211)
- Description: Percentage of patients with diagnosis of
cirrhosis that have documented hepatitis B vaccination (Measure
Specifications)
- Programs under consideration: Merit-Based
Incentive Payment System (MIPS)
- Public comments received: 8
- Workgroup Rationale: The CDC recommendation for Hepatitis B
vaccination includes persons with chronic liver disease as a
preventive health measure. MAP encourages continued development of
this measures with strong consideration to focusing this measure on
patients with chronic liver disease, including Hepatitis C, rather
than multiple measures. The measure is duals sensitive. The registry
is not specified. Data on current performance would provide a better
understanding of the gap in care. Public comments on this measure were
mixed with some strongly supporting and other not.
- Workgroup Recommendation: Encourage continued
development
- Over-utilization of mesh in the posterior compartment (MUC
ID: MUC15-436)
- Description: Percentage of patients undergoing vaginal
surgery for pelvic organ prolapse involving the posterior compartment
where a synthetic mesh augment is utilized. (Measure
Specifications)
- Programs under consideration: Merit-Based
Incentive Payment System (MIPS)
- Public comments received: 6
- Workgroup Rationale: Posterior repair with and without mesh
have been compared with similar outcomes. Mesh has been shown to have
significant complications including expulsion of the mesh in 17%. MAP
encourages continued development of this measure that will promote
reduced use of mesh and the associated costs (mesh and complications)
without affecting patient outcomes. The measure adds an appropriate
use measure to the group of measures for pelvic prolapse – a common
condition in older women.
- Workgroup Recommendation: Encourage continued
development
|
|
Finalizing Workgroup Recommendations for All
Clinician Programs |
|
This section of the meeting finalizes the remaining workgroup
recommendations for:
|
3:30 PM |
Break
|
|
|
3:45 PM |
Opportunity for Public Comment |
|
|
4:45 PM |
Opportunity for Public Comment |
|
|
5:00 PM |
Adjourn for the Day |
|
|
Day 2: January 27,
2016 |
|
|
|
9:00 AM |
Breakfast |
|
|
9:15 AM |
Day 1 Recap |
|
Beth McGlynn Harold Pincus
|
9:30 AM |
Pre-Rulemaking Recommendations for Hospital
Programs |
|
Cristie Upshaw Travis, MAP Hospital Workgroup Co-Chair Ronald
Walters, MAP Hospital Workgroup Co-Chair Melissa Mariñelarena, Senior
Director, NQF Erin O’Rourke Beth McGlynn
- Discuss key themes from the Hospital Workgroup meeting
- Review and finalize broader guidance about programmatic issues
- Review and discuss input from the MAP Dual Eligible Beneficiaries
Workgroup
- Review and finalize workgroup measure
recommendations
|
|
Measures Requiring a Vote on
MAP's Preliminary Recommendation |
|
This section of the meeting includes debate and voting on measures
pulled by MAP Coordinating Committee members. |
|
- Measurement of Phosphorus Concentration (MUC ID: MUC15-1136)
- Description: Percentage of all peritoneal dialysis and
hemodialysis patient months with serum or plasma phosphorus measured
at least once within the month. (Measure
Specifications; Summary
of NQF Endorsement Review)
- Programs under consideration: End-Stage
Renal Disease Quality Incentive Program
- Public comments received: 6
- Workgroup Rationale: MAP supported this measure, NQF #0255,
because it tracks performance of a precursor process that is
consistent with clinical guidelines to mitigate patient morbidity and
mortality. The measure has been found to be reliable, valid, and not
burdensome to calculate. This updated measure has been broadened to
include pediatric patients and permit an alternative measurement
mechanism, plasma phosphorous.
- Workgroup Recommendation: Support
- ESRD Vaccination: Full-Season Influenza Vaccination (MUC ID:
MUC15-761)
- Description: Percentage of ESRD patients = 6 months of age
on October 1 and on chronic dialysis = 30 days in a facility at any
point between October 1 and March 31 who either received an influenza
vaccination, were offered and declined the vaccination, or were
determined to have a medical contraindication. (Measure
Specifications)
- Programs under consideration: End-Stage
Renal Disease Quality Incentive Program
- Public comments received: 9
- Workgroup Rationale: MAP did not support this measure
because there is no discussion of exclusions, and it does not address
the inactivated vaccine. Additionally, there is a burden for staff to
enter data into the database. MAP encouraged CMS to consider NQF
#0226, which is NQF-endorsed, fully aligned, and fully tested.
- Workgroup Recommendation: Do not
support
- National Healthcare Safety Network (NHSN) Antimicrobial Use
Measure (MUC ID: MUC15-531)
- Description: Assesses antimicrobial use (AU) in hospitals
based on medication administration data hospitals collect
electronically at the point of care and report via electronic file
submissions to NHSN. AU data included in the measure are antibacterial
agents administered to adult and pediatric patients in a specified set
of hospital ward and intensive care unit locations. (Measure
Specifications)
- Programs under consideration: Hospital
Inpatient Quality Reporting and EHR Incentive Program
- Public comments received: 10
- Workgroup Rationale: MAP conditionally supported this
measure since the measure developer stated that the measure is
intended for use in the National Healthcare Safety Network (NHSN) and
wishes to gain greater experience and gather more information before
using it for reporting or payment. MAP recognized the high importance
of antimicrobial stewardship and conditionally support the inclusion
of this measure in the IQR program to allow for the opportunity for
additional testing to address feasibility issues. However, MAP noted
these issues should be addressed before the measure is reported on
Hospital Compare.
- Workgroup Recommendation: Conditional support, pending the
Centers for Disease Control recommendation that the measure is ready
for use in public reporting, and pending resubmission to MAP for
review of implementation data
- Excess Days in Acute Care after Hospitalization for Pneumonia
(MUC ID: MUC15-391)
- Description: This measure assesses the difference
(“excess”) between the average number of risk-adjusted days a
hospital’s patients spend in an ED, observation, or readmission in the
30 days following a hospitalization for pneumonia (“predicted”) and
the number of days in acute care that they would have been expected to
spend if discharged from an average hospital. (Measure
Specifications)
- Programs under consideration: Hospital
Inpatient Quality Reporting and EHR Incentive Program
- Public comments received: 8
- Workgroup Rationale: MAP conditionally supported this
measure pending NQF review and endorsement. MAP also stated that the
Standing Committee reviewing this measure should consider SDS factors
that examine the true hospital vs. community role in readmissions and
consider parsimony with regard to multiple pneumonia readmission
measures.
- Workgroup Recommendation: Conditional support, pending NQF
review and endorsement and examination of SDS
factors
- IQI-22: Vaginal Birth After Cesarean (VBAC) Delivery Rate,
Uncomplicated (MUC ID: MUC15-1083)
- Description: Vaginal births per 1,000 deliveries by
patients with previous Cesarean deliveries. Excludes deliveries with
complications (abnormal presentation, preterm delivery, fetal death,
multiple gestation diagnoses, or breech procedure). (Measure
Specifications)
- Programs under consideration: Hospital
Inpatient Quality Reporting and EHR Incentive Program
- Public comments received: 8
- Workgroup Rationale: MAP did not support this measure
because it adds little value to this measure set since VBAC rates
would be calculated using only CMS claims data.
- Workgroup Recommendation: Do not
support
- INR Monitoring for Individuals on Warfarin after Hospital
Discharge (MUC ID: MUC15-1015)
- Description: Percentage of adult inpatient hospital
discharges to home for which the individual was on warfarin and
discharged with a non-therapeutic International Normalized Ratio (INR)
who had an INR test within 14 days of hospital discharge (Measure
Specifications; Summary
of NQF Endorsement Review)
- Programs under consideration: Hospital
Inpatient Quality Reporting and EHR Incentive Program
- Public comments received: 9
- Workgroup Rationale: MAP conditionally supported this
measure an optional eCQM pathway and asked that its performance be
monitored. MAP recognized that this is an important patient safety
issue, but stated that it should be optional for hospitals because not
all vendors may be able to support the implementation of this measure.
- Workgroup Recommendation: Conditional support, pending
optional eCQM pathway
- Adult Local Current Smoking Prevalence (MUC ID: MUC15-1013)
- Description: Percentage of adult (age 18 and older) U.S.
population that currently smoke, defined as adults who reported having
smoked at least 100 cigarettes in their lifetime and currently smoke.
(The endorsed specifications of the measure are: Percentage of
adult (age 18 and older) U.S. population that currently smoke.)
(Measure
Specifications; Summary
of NQF Endorsement Review)
- Programs under consideration: Hospital
Inpatient Quality Reporting and EHR Incentive Program
- Public comments received: 11
- Workgroup Rationale: MAP encouraged further development of
this measure at the city and/or county level because the group
recognized the importance of a community-based approach to decrease
smoking. This type of county-based measure indicates the need for
hospital collaboration with the surrounding community to work together
to provide tobacco cessation.
- Workgroup Recommendation: Encourage continued
development
- Spinal Fusion Clinical Episode-Based Payment Measure (MUC
ID: MUC15-837)
- Description: The measure constructs a clinically coherent
group of services to inform providers about resource use and
effectiveness. It sums Parts A and B payments related to a Spinal
Fusion IP stay and attributes them to the hospital where the index IP
stay occurred. (Measure
Specifications)
- Programs under consideration: Hospital
Inpatient Quality Reporting and EHR Incentive Program
- Public comments received: 9
- Workgroup Rationale: MAP did not support this measure
because although cost is important to measure, data supporting
variation in costs for this procedure was not provided. The group also
noted that measuring resource use (cost) is different from
appropriateness of care; the cost of a service is not indicative of
quality care.
- Workgroup Recommendation: Do not
support
- Aortic Aneurysm Procedure Clinical Episode-Based Payment Measure
(MUC ID: MUC15-835)
- Description: The measure constructs a clinically coherent
group of services to inform providers about resource use and
effectiveness. It sums Parts A and B payments related to an aortic
aneurysm procedure inpatient (IP) stay and attributes them to the
hospital where the index IP stay occurred. It includes abdominal
aortic aneurysm and thoracic aortic aneurysm subtypes. (Measure
Specifications)
- Programs under consideration: Hospital
Inpatient Quality Reporting and EHR Incentive Program
- Public comments received: 8
- Workgroup Rationale: MAP did not support this measure
because although cost is important to measure, data supporting
variation in costs for this procedure was not provided. The group also
noted that measuring resource use (cost) is different from
appropriateness of care; the cost of a service is not indicative of
quality care.
- Workgroup Recommendation: Do not
support
- Cholecystectomy and Common Duct Exploration Clinical
Episode-Based Payment Measure (MUC ID: MUC15-836)
- Description: The measure constructs a clinically coherent
group of services to inform providers about resource use and
effectiveness. It sums Parts A and B payments related to a
Cholecystectomy and Common Duct Exploration IP stay and attributes
them to the hospital where the index IP stay occurred. (Measure
Specifications)
- Programs under consideration: Hospital
Inpatient Quality Reporting and EHR Incentive Program
- Public comments received: 7
- Workgroup Rationale: MAP did not support this measure
because although cost is important to measure, data supporting
variation in costs for this procedure was not provided. The group also
noted that measuring resource use (cost) is different from
appropriateness of care; the cost of a service is not indicative of
quality care.
- Workgroup Recommendation: Do not
support
- Transurethral Resection of the Prostate (TURP) for Benign
Prostatic Hyperplasia Clinical Episode-Based Payment Measure (MUC
ID: MUC15-838)
- Description: The measure constructs a clinically coherent
group of services to inform providers about resource use and
effectiveness. It sums Parts A and B payments related to a TURP IP
stay and attributes them to the hospital where the index IP stay
occurred. (Measure
Specifications)
- Programs under consideration: Hospital
Inpatient Quality Reporting and EHR Incentive Program
- Public comments received: 5
- Workgroup Rationale: MAP did not support this measure
because although cost is important to measure, data supporting
variation in costs for this procedure was not provided. The group also
noted that measuring resource use (cost) is different from
appropriateness of care; the cost of a service is not indicative of
quality care.
- Workgroup Recommendation: Do not
support
- Thirty-day all-cause unplanned readmission following psychiatric
hospitalization in an Inpatient Psychiatric Facility (IPF) (MUC ID:
MUC15-1082)
- Description: The measure estimates a facility-level
risk-standardized readmission rate for unplanned, all-cause
readmission within 30 days of discharge from an Inpatient Psychiatric
Facility of adult Medicare fee-for-service (FFS) patients with a
principal diagnosis of a psychiatric disorder. The performance period
for the measure is 24 months. (Measure
Specifications)
- Programs under consideration: Inpatient
Psychiatric Facility Quality Reporting Program
- Public comments received: 8
- Workgroup Rationale: MAP noted the importance of reducing
readmissions for mental health conditions but recommended this measure
be submitted for NQF review and endorsement. MAP recommended the
Admissions and Readmissions Standing Committee pay particular
attention to the influence of sociodemographic factors when reviewing
this measure as access to community resources and supports can
influence a patient's ability to manage mental and behavioral health
issues on an outpatient basis.
- Workgroup Recommendation: Conditional support, pending NQF
review and endorsement and examination of SDS
factors.
- Substance Use Core Measure Set (SUB)-3 Alcohol & Other Drug
Use Disorder Treatment Provided or Offered at Discharge and SUB-3a
Alcohol & Other Drug Use Disorder Treatment at Discharge (MUC
ID: MUC15-1065)
- Description: Overall rate which includes all hospitalized
patients 18 years of age and older to whom alcohol or drug use
disorder treatment was provided, or offered and refused, at the time
of hospital discharge, and a second rate, a subset of the first, which
includes only those patients who received alcohol or drug use disorder
treatment at discharge. (The endorsed specifications of the measure
are: The measure is reported as an overall rate which includes all
hospitalized patients 18 years of age and older to whom alcohol or
drug use disorder treatment was provided, or offered and refused, at
the time of hospital discharge, and a second rate, a subset of the
first, which includes only those patients who received alcohol or drug
use disorder treatment at discharge. The Provided or Offered rate
(SUB-3) describes patients who are identified with alcohol or drug use
disorder who receive or refuse at discharge a prescription for
FDA-approved medications for alcohol or drug use disorder, OR who
receive or refuse a referral for addictions treatment. The Alcohol and
Other Drug Disorder Treatment at Discharge (SUB-3a) rate describes
only those who receive a prescription for FDA-approved medications for
alcohol or drug use disorder OR a referral for addictions treatment.
Those who refused are not included.These measures are intended to be
used as part of a set of 4 linked measures addressing Substance Use
(SUB-1 Alcohol Use Screening ; SUB-2 Alcohol Use Brief Intervention
Provided or Offered; SUB-3 Alcohol and Other Drug Use Disorder
Treatment Provided or Offered at Discharge; SUB-4 Alcohol and Drug
Use: Assessing Status after Discharge).) (Measure
Specifications; Summary
of NQF Endorsement Review)
- Programs under consideration: Inpatient
Psychiatric Facility Quality Reporting Program
- Public comments received: 8
- Workgroup Rationale: MAP recognized the importance of
addressing this critical quality and public health concern. MAP noted
that this process measure is a start to addressing the issue but
recommended that outcome measures be quickly developed and
implemented. MAP recommended that the developer consider expanding
this measure to the under 18 population and that this measure be
considered for implementation in the IQR program.
- Workgroup Recommendation:
Support
|
|
Finalizing Workgroup Recommendations for All
Hospital Programs |
|
This section of the meeting finalizes the remaining workgroup
recommendations for:
|
10:30 AM |
Break |
|
|
10:45 AM |
MAP at 5 Years: Vision for the
Future |
|
Wunmi Isijola, Administrative Director, NQF Harold Pincus Taroon
Amin Erin O’Rourke
- Discuss improved CDP/MAP alignment and how MAP can ensure scientific
integrity of the measures it recommends
- Discuss the impact of the NQF Intended Use project on the
pre-rulemaking process
|
11:45 AM |
Discussion of MAP Core Concepts – Breakout
Sessions |
|
|
12:00 PM |
Lunch |
|
|
12:30 PM |
Finalization of MAP Core Concepts |
|
|
1:30 PM |
Round-Robin Discussion: Improving MAP’s
Processes |
|
Amber Sterling, Project Manager, NQF
|
2:00 PM |
Opportunity for Public Comment |
|
|
2:15 PM |
Closing Remarks |
|
Beth McGlynn Harold Pincus
|
2:30 PM |
Adjourn |
|
|
Appendix A: Measure Information
Measure Index
Ambulatory Surgical Center Quality Reporting Program
End-Stage Renal Disease Quality Incentive Program
Hospital Acquired Condition Reduction Program
Home Health Quality Reporting Program
Hospital Inpatient Quality Reporting and EHR Incentive Program
- Adult
Local Current Smoking Prevalence (Workgroup Recommendation: Encourage
continued development; Public comments received:11;
MUC ID: MUC15-1013)
- American
College of Surgeons-Centers for Disease Control and Prevention (ACS-CDC)
Harmonized Procedure Specific Surgical Site Infection (SSI) Outcome
Measure (Workgroup Recommendation: Conditional support, pending NQF review
and endorsement of measure updates; Public comments received:4;
MUC ID: MUC15-534)
- Aortic
Aneurysm Procedure Clinical Episode-Based Payment Measure (Workgroup
Recommendation: Do not support; Public comments received:8;
MUC ID: MUC15-835)
- Cholecystectomy
and Common Duct Exploration Clinical Episode-Based Payment Measure
(Workgroup Recommendation: Do not support; Public comments received:7;
MUC ID: MUC15-836)
- Excess
Days in Acute Care after Hospitalization for Pneumonia (Workgroup
Recommendation: Conditional support, pending NQF review and endorsement and
examination of SDS factors; Public comments received:8;
MUC ID: MUC15-391)
- Hospital
30-Day Mortality Following Acute Ischemic Stroke Hospitalization Measure
(Workgroup Recommendation: Conditional support, pending NQF review and
endorsement; Public comments received:14;
MUC ID: MUC15-294)
- Hospital-level,
risk-standardized 30-day episode-of-care payment measure for pneumonia
(Workgroup Recommendation: Conditional support, pending NQF review and
endorsement of measure updates and examination of SDS factors; Public comments
received:8;
MUC ID: MUC15-378)
- Hybrid
30-Day Risk-Standardized Acute Ischemic Stroke Mortality Measure with Claims
and Clinical Electronic Health Record (EHR) Risk Adjustment Variables
(Workgroup Recommendation: Conditional support, pending NQF review and
endorsement; Public comments received:12;
MUC ID: MUC15-1135)
- Hybrid
30-Day Risk-Standardized Acute Ischemic Stroke Mortality Measure with
Electronic Health Record (EHR)-Extracted Risk Adjustment Variables
(Workgroup Recommendation: Do not support; Public comments received:12;
MUC ID: MUC15-1033)
- INR
Monitoring for Individuals on Warfarin after Hospital Discharge (Workgroup
Recommendation: Conditional support, pending optional eCQM pathway; Public
comments received:9;
MUC ID: MUC15-1015)
- IQI-22:
Vaginal Birth After Cesarean (VBAC) Delivery Rate, Uncomplicated
(Workgroup Recommendation: Do not support; Public comments received:8;
MUC ID: MUC15-1083)
- National
Healthcare Safety Network (NHSN) Antimicrobial Use Measure (Workgroup
Recommendation: Conditional support, pending the Centers for Disease Control
recommendation that the measure is ready for use in public reporting, and
pending resubmission to MAP for review of implementation data ; Public
comments received:10;
MUC ID: MUC15-531)
- Patient
Safety and Adverse Events Composite (Workgroup Recommendation: Support;
Public comments received:10;
MUC ID: MUC15-604)
- Spinal
Fusion Clinical Episode-Based Payment Measure (Workgroup Recommendation:
Do not support; Public comments received:9;
MUC ID: MUC15-837)
- Transurethral
Resection of the Prostate (TURP) for Benign Prostatic Hyperplasia Clinical
Episode-Based Payment Measure (Workgroup Recommendation: Do not support;
Public comments received:5;
MUC ID: MUC15-838)
Hospital Outpatient Quality Reporting Program
Hospice Quality Reporting Program
Hospital Value-Based Purchasing Program
Inpatient Psychiatric Facility Quality Reporting Program
Inpatient Rehabilitation Facility Quality Reporting Program
Long-Term Care Hospital Quality Reporting Program
Merit-Based Incentive Payment System (MIPS)
Medicare Shared Savings Program
Prospective Payment System-Exempt Cancer Hospital Quality Reporting
Program
Skilled Nursing Facility Quality Reporting System
Skilled Nursing Facility Value-Based Purchasing Program
Full Measure Information
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF review
and endorsement
- Workgroup Rationale: MAP conditionally supported the measure,
noting the high value and urgency of this measure, given many new entrants to
the ambulatory surgical center space, as well as the clustering outbreaks of
Toxic Anterior Segment Syndrome. MAP cautioned that the measure should be
reviewed and endorsed by NQF before adoption into ASCQR, so that a specialized
standing committee can evaluate the measure for scientific
acceptability.
- Public comments received: 7
Rationale for measure provided by HHS
Toxic anterior segment
syndrome (TASS), an acute, noninfectious inflammation of the anterior segment of
the eye, is a complication of anterior segment eye surgery that typically
develops within 24 hours after surgery. Various contaminants, including those
from surgical equipment or supplies, have been implicated as causes of TASS.
Although most cases of TASS can be treated, the inflammatory response associated
with TASS can cause serious damage to intraocular tissues, resulting in vision
loss. Prevention requires careful attention to solutions, medications, and
ophthalmic devices and to cleaning and sterilization of surgical equipment
because of the numerous potential etiologies. Despite a recent focus on
prevention, cases of TASS continue to occur, sometimes in clusters. The
incidence of TASS is unknown, but frequencies of 1454 cases in approximately
69,000 surgeries (Bodnar et al, J Cataract Refract Surg. 2012
Nov;38(11):1902-10.) and 909 cases in 50,114 surgeries (Cutler et al, J Cataract
Refract Surg. 2010 Jul;36(7):1073-80.) have been reported in cross-sectional
studies in the literature. With millions of anterior segment surgeries being
performed in the United States each year, measurement and public reporting have
the potential to serve as an additional tool to drive further preventive
efforts.
Measure Specifications
- NQF Number (if applicable):
- Description: This measure is used to assess the number of
ophthalmic anterior segment surgery patients diagnosed with TASS within 2 days
of surgery.
- Numerator: All anterior segment surgery patients diagnosed with
TASS within 2 days of surgery
- Denominator: All anterior segment surgery patients
- Exclusions: None
- HHS NQS Priority: Making Care Safer
- HHS Data Source: Administrative clinical data, Paper medical
record, Other (physician diagnosis and report for numerator)
- Measure Type: Outcome
- Steward: Ambulatory Surgical Center (ASC) Quality
Collaboration
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Support
- Workgroup Rationale: MAP supported this measure because it fills a
priority gap in the ESRD-QI program, measuring an intermediate outcome closely
associated in the literature with severe adverse events, including elevated
mortality. The measure is not expected to be burdensome to implement, as the
necessary data elements exist already as part of the CROWNWeb
repository.
- Public comments received: 7
Rationale for measure provided by HHS
The measure focus is
evidence-based, demonstrated as follows: • Health outcome: a rationale supports
the relationship of the health outcome to processes or structures of care.
Applies to patient-reported outcomes (PRO), including health-related quality of
life/functional status, symptom/symptom burden, experience with care,
health-related behavior. • Intermediate clinical outcome: a systematic
assessment and grading of the quantity, quality, and consistency of the body of
evidence that the measured intermediate clinical outcome leads to a desired
health outcome. • Process: a systematic assessment and grading of the quantity,
quality, and consistency of the body of evidence 4 that the measured process
leads to a desired health outcome. • Structure: a systematic assessment and
grading of the quantity, quality, and consistency of the body of evidence that
the measured structure leads to a desired health outcome. • Efficiency:
evidence not required for the resource use component.
Measure Specifications
- NQF Number (if applicable): 2701
- Description: Percentage of adult in-center hemodialysis patients in
the facility whose average ultrafiltration rate (UFR) is = 13
ml/kg/hour.
- Numerator: Number of patients* from the denominator whose average
UFR >13 ml/kg/hour who receive an average of <240 minutes per treatment
during the calculation period.** *To address the fact that patients may
contribute varying amounts of time to the annual denominator population,
results will be reported using a “patient-month” construction. ** The
calculation period is defined as the same week that the monthly Kt/V is
drawn.
- Denominator: Number of adult in-center hemodialysis patients in an
outpatient dialysis facility undergoing chronic maintenance hemodialysis
during the calculation period.
- Exclusions: 1. Patients <18 years of age (implicit in
denominator definition). 2. Home dialysis patients (implicit in denominator
definition). 3. Patients in a facility <30 days. 4. Patients with >4
hemodialysis treatments during the calculation period. 5. Patients with <7
hemodialysis treatments in the facility during the reporting month. 6.
Patients without a completed CMS Medical Evidence Form (Form CMS-2728) in the
reporting month. 7. Kidney transplant recipients with a functioning
graft.(The endorsed specifications of the measure are: The following
patients are excluded from the denominator population:1. Patients <18 years
of age (implicit in denominator definition). 2. Home dialysis patients
(implicit in denominator definition).3. Patients in a facility <30 days.4.
Patients with >4 hemodialysis treatments during the calculation period.5.
Patients with <7 hemodialysis treatments in the facility during the
reporting month.6. Patients without a completed CMS Medical Evidence Form
(Form CMS-2728) in the reporting month.7. Kidney transplant recipients with a
functioning graft.8. Facilities treating <=25 adult in-center hemodialysis
patients during the reporting month)
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: CROWNWeb
- Measure Type: Intermediate Outcome
- Steward: KCQA- Kidney Care Quality Alliance
- Endorsement Status: Endorsed October 2, 2015
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because there
is no discussion of exclusions, and it does not address the inactivated
vaccine. Additionally, there is a burden for staff to enter data into the
database. MAP encouraged CMS to consider NQF #0226, which is NQF-endorsed,
fully aligned, and fully tested.
- Public comments received: 9
Rationale for measure provided by HHS
Influenza vaccination is
universally recommended for all people aged 6 months and older. According to the
CDC, seasonal influenza, which occurs between October and March/April of the
following year, is associated with approximately 36,000 deaths and 226,000
hospitalizations annually. While overall rates of influenza infection are
highest among children, rates of serious illness and mortality are highest among
adults aged 65 years or older and children aged two years or younger as well as
among immunocompromised patients, which include ESRD patients. The proposed
influenza vaccination measure is a facility-level measure that applies to all
dialysis patients. At the end of 2012 there were 413,725 patients being
dialyzed, of whom 114,083 were new (incident) to dialysis.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of ESRD patients = 6 months of age on
October 1 and on chronic dialysis = 30 days in a facility at any point between
October 1 and March 31 who either received an influenza vaccination, were
offered and declined the vaccination, or were determined to have a medical
contraindication.
- Numerator: Number of patients from the denominator who during the
time from August 1 through March 31 (to be calculated and reported
separately): 1) Received an influenza vaccination (documented by the dialysis
provider, documented off-site vaccination, or patient self-report) 2) Were
offered an influenza vaccination and declined 3) Were determined to have a
medical contraindication
- Denominator: All patients alive and aged >/= 6 months on October
1 and on chronic dialysis >/= 30 days in a facility at any point between
October 1 and March 31 (in-center or home dialysis)
- Exclusions: Patients younger than 6 months old Patients on chronic
dialysis (as defined by a completed 2728 form or a REMIS/CROWNWeb record) for
less than 30 days
- HHS NQS Priority: Best Practice of Healthy Living
- HHS Data Source: CROWNWeb
- Measure Type: Process
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Support
- Workgroup Rationale: MAP supported this measure, NQF #0255, because
it tracks performance of a precursor process that is consistent with clinical
guidelines to mitigate patient morbidity and mortality. The measure has been
found to be reliable, valid, and not burdensome to calculate. This updated
measure has been broadened to include pediatric patients and permit an
alternative measurement mechanism, plasma phosphorous.
- Public comments received: 6
Rationale for measure provided by HHS
Consistent monitoring of
phosphorus levels helps ensure regulation of patient morbidity and mortality,
including stabilization of bone density, decreased bone pain, fracture
prevention and decreased rates of arteriosclerosis and related conditions (e.g.,
stroke, heart attack). Routine blood tests will also aid in detection of and
monitoring for abnormal states phosphorus balance in this especially vulnerable
population. Among the 6,073 facilities that have at least one eligible patient,
we generated the following statistics of their performance scores (based on the
patient month) using the January – December 2013 CROWNWeb clinical data: mean
(SD)=87% (18%); min=0%; max=100%; 25th percentile=86%; 50th percentile=92%; 75th
percentile=96%. A description of the data is included in questions 1.1-1.7 under
“Scientific Acceptability”. Disparity analyses were performed among the entire
eligible adult population (n=518,127) to examine the difference in performance
scores by sex, race, ethnicity, and age. In particular, for each facility, the
percent of patient-months by demographic group (sex, race, ethnicity, age) was
calculated. Then, the facilities were divided into quintiles (Q1-Q5) based on
the percentage of patient-months in the particular demographic category (i.e., a
facility with percentage of females similar to the national median will be
included in quintile 3). The top 20% of facilities in terms of rank, based on
the percentages of females, were classified as Q5, while the bottom 20% of
facilities were classified as Q1. Average (mean) performance for the measure was
calculated for each quintile, and the means were examined for trend across
quintiles (Q1-Q5). The Cochran-Armitage test for trend was performed to assess
disparities in performance scores. All the results for each group across
quintiles were statistically significant (p<0.0001), which imply that there
are statistically significant changes in performance scores depending on sex,
race, ethnicity, and age. While these differences are statistically significant,
we did not determine them to be clinically meaningful differences. The mean
performance scores for percent of patient-months with a phosphorus measurement
in each quintile, by demographic group, are presented below. Facility Level
Quintiles by Population Group (Quintile 1-5): Female(Q1=85.6%; Q2=88.0%;
Q3=87.6%; Q4=88.3%; Q5=84.5%; P<0.0001) White (Q1=86.4%; Q2=85.5%; Q3=87.2%;
Q4=87.3%; Q5=87.6%; P<0.0001) Black (Q1=86.9%; Q2=87.4%; Q3=87.1%; Q4=86.0%;
Q5=86.7%; P<0.0001) Hispanic (Q1=85.2%; Q2=89.1%; Q3=87.6%; Q4=86.1%;
Q5=86.8%; P<0.0001) Age>=65 (Q1=83.2%; Q2=88.0%; Q3=87.6%; Q4=87.4%;
Q5=87.9%; P<0.0001) (note: age <18 was too small to calculate quintiles).
In healthy individuals, the kidney occupies an integral, multi-faceted role in
the maintenance of calcium-phosphorus homeostasis. It follows that abnormalities
of calcium-phosphorus regulation are exceedingly common in patients with
advanced chronic kidney disease, which, indeed, most data indicate that only
25-35% of dialysis patients are able to maintain calcium in the suggested target
range of 8.4-9.5 mg/dL (KDOQI 2003). Numerous studies have demonstrated the
impact of prolonged calcium-phosphorus dysregulation on patient morbidity and
mortality (KDOQI 2003), which can lead to progressive bone weakness, bone pain
and increased susceptibility to fractures, and severe arteriosclerosis that can
precipitate strokes, heart attacks, and other adverse cardiac events.
Unfortunately, overt symptoms can often remain unmanifested in many but the most
extreme disordered states of calcium-phosphorus dysregulation, which is why
routine blood tests are necessary to detect and monitor abnormal states of
calcium and phosphorus balance in this especially vulnerable population.
National Kidney Foundation. 2003. "K/DOQI Clinical Practice Guidelines for Bone
Metabolism and Disease in Chronic Kidney Disease," American Journal of Kidney
Disease, 42 (Suppl 3): S17. Found at:
http://www.kidney.org/professionals/kdoqi/guidelines_bone/index.htm
Measure Specifications
- NQF Number (if applicable): 255
- Description: Percentage of all peritoneal dialysis and hemodialysis
patient months with serum or plasma phosphorus measured at least once within
the month.
- Numerator: Number of dialysis patient months in the denominator
with serum or plasma phosphorus measured at least once within the reporting
month.
- Denominator: Number of patient-months among in-center hemodialysis,
home hemodialysis, or peritoneal dialysis patients under the care of the
dialysis facility for the entire reporting month
- Exclusions: Exclusions that are implicit in the denominator
definition include all patients who have not been in the facility the entire
reporting month. There are no additional exclusions for this
measure.
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: CROWNWeb
- Measure Type: Process
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Endorsed on October 2, 2015.
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has not been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Renal (Aug 18 draft
report available as of 9/17/15)
- Review for Importance: The measure meets the Importance
criteria(1a. Evidence, 1b. Performance Gap)1a. Evidence: 6-H; 15-M; 0-L; 0-I;
1b. Performance Gap: 0-H; 6-M; 16-L; 1-IRationale:• The developer presents the
measure focus as the facility´s process of measuring serum or plasma
phosphorus each month for End Stage Renal Disease (ESRD) dialysis patients.
They provided the following path as the process leads to the improvement of
mortality: Measure serum or plasma phosphorus--> Assess value-->Identify
problem-->Identify treatment options-->Administer the appropriate
treatment-->Patient experiences improvement in mortality.• Developers also
reference The Kidney Disease: Improving Global Outcomes (KDIGO) clinical
practice guidelines, and cites additional sources of evidence. Three separate
Technical Expert Panels (TEPs) were involved in the development and
maintenance of the measure. The TEPs found no randomized control trials
providing strong evidence to inform healthcare providers as to the efficacy of
phosphorus lowering strategies on improvement in clinical outcomes.• The
Committee discussed the measure evidence and found that the KDIGO guidelines
provided did not match the measure specifications. KDIGO guidelines state for
chronic kidney disease (CKD), phosphorous levels should be measured every one
to three months and the measure requires a monthly phosphorous. The evidential
data provided is largely focused around phosphate levels and not the act of
measuring phosphate levels. Despite the discrepancy in the actual process of
measuring phosphorous levels, the Committee rated this measure as moderately
satisfying the evidence criteria.• Performance gap data provided by the
developer noted that consistently monitoring phosphorous levels helps to
ensure the regulation of patient morbidity and mortality. Additionally,
routine blood tests will assist in the detection and monitoring for abnormal
phosphorous balance.• Developers provided information on the performance
scores of the more than 6,000 facilities that housed at least a single
eligible patient. Using the 2013 CROWNWeb data, the median data were
calculated at 92%.• Committee members noted the high percentage of performance
at the 50th percentile stating there was not much room for improvement.
Questioning whether or not there were factors to be improved upon, members
agreed that there was only slight opportunity for improvement and voted to
consider the measure for endorsement with reserve status.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria(2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity)2a. Reliability: 4-H;
18-M; 0-L; 0-I; 2b. Validity: 3-H; 19-M; 1-L; 0-IRationale:• Some members
asked for clarification of whether or not the denominator truly excluded
patients who had not been in the facility for the entire month. Developers
clarified that a patient must be out of the facility for an entire 30 calendar
days during the reporting month to be included in the denominator exclusion.•
The assessment of reliability was based on facility-level Pearson correlation
coefficients between the current performance month and the previous month for
2013 reporting months (January – December 2013). Pearson correlation
coefficients of each pair of the current and preceding months ranted from 0.72
– 0.90 and were statistically significant (p<0.0001). Monthly IURs ranged
from 0.95 – 0.97.• There was confusion among committee members regarding the
specifications related to transplant patients with functioning allografts.
Additionally, inclusion of pediatric patients was a point of confusion since
the evidence provided was only from adult patients.• Once the developer
clarified that pediatric and adult patients were included in the denominator
and in the testing, committee members concluded the measure was reliable and
valid.
- Review for Feasibility: 18-H; 5-M; 0-L; 0-I(3a. Clinical data
generated during care delivery; 3b. Electronic sources; 3c.Susceptibility to
inaccuracies/ unintended consequences identified 3d. Data collection strategy
can be implemented)Rationale:• The data source for this measure is CROWNWeb.
If patient data is missing in CROWNWeb, Medicare claims are used. Data is
collected or generated and used by healthcare personnel during provision of
care. The Committee had no major concerns with feasibility.
- Review for Usability: 17-H; 6-M; 0-L; 0-I(Meaningful,
understandable, and useful to the intended audiences for 4a. Public
Reporting/Accountability and 4b. Quality Improvement, 4c. Susceptibility to
inaccuracies/unintended consequences identified)Rationale:• The measure is
currently in use in the End Stage Renal Disease Quality Improvement Program
(ESRD QIP). The current use for quality improvement is internal and specific
to the organization via the Renal Physicians Association (RPA) Quality
Improvement Registry.• The measure was first publicly reported in the final
QIP PY 2014 scores released in December 2013, so performance data over time
cannot be assessed at this time. The Committee did not have any major concerns
with the use and usability of this measure.
- Review for Related and Competing Measures: No related or competing
measures noted.
- Endorsement Public Comments: Three commenters were generally in
support of this measure for reserve status.
- Endorsement Committee Recommendation: The measure was originally
endorsed in 2007, re-endorsed in 2012 and is specified for use at the facility
level. The Committee noted that while this is a process measure focused on
monthly assessment of patient serum or plasma phosphorus, the evidence
provided was not in direct alignment. Specifically, the KDIGO guidelines state
for CKD, phosphorous levels should be measured every one to three months and
the measure states a monthly phosphorous. The Committee rated this measure as
moderately satisfying the evidence criteria. The Committee found the testing
data supplied by the developer demonstrated adequate reliability, validity and
feasibility of the measure. Committee members agreed that there was only
slight opportunity for improvement and voted to recommend the measure for
endorsement with reserve status. Standing Committee Recommendation for
Endorsement with Potential for Reserve Status: 22-Y;
0-N
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because it
was recently reviewed by NQF and was recommended for reserve status because
the measure has “topped out”. MAP also determined that measuring
hypercalcemia in this population was not clinically important because almost
all dialysis patients have calcium levels below the target level.
- Public comments received: 5
Rationale for measure provided by HHS
In 2011, total Medicare
costs for the ESRD program were $34.3 billion, a 5.4% increase from 2010 [14].
Abnormalities in serum levels of calcium and phosphorus, which are markers of
mineral and bone disorder, are common among ESRD patients. Numerous studies have
demonstrated the association of prolonged calcium and phosphorus dysregulation
on patient morbidity and mortality [2,1]. In March 2010, the C- TEP recommended
that a quality measure (CPM) for the upper limit of total serum calcium be
calculated as the proportion of patients (calculated as patient months) with
3-month rolling average of total serum calcium greater than 10.2 mg/dL. This
recommendation is consistent with the value indicated by a TEP held in 2006 and
with the 2003 KDOQI guidelines [1]. The TEP in 2013 also reviewed the measures
and recommended no changes to the current threshold. Since 10.2 mg/dl is the
considered the upper limit of the normal range in the majority of clinical
laboratories, this measure is also consistent with the published KDIGO
guidelines [2]. Review of the currently available literature and evidence
indicates that observational cohort studies show a consistent adverse
association of hypercalcemia with cardiovascular events and all-cause mortality
[3-7]. Clinical data demonstrate the association of increased serum calcium with
vascular [8,9] and valvular calcifications [10]. The basic science also supports
a pathological role of high calcium in promoting soft tissue and vascular
calcification [11-13]. Although there are no interventional studies
demonstrating the benefit of correcting hypercalcemia, there was unanimous
agreement among the 2010 C-TEP members that calcium concentrations >10.2
mg/dL place the patient at increased risk of poor outcomes. Current guidelines
indicate that clinical decision should be based on trends rather than single
laboratory values [2]. Therefore, it was unanimously agreed to use a three-month
rolling average for the reporting period. 1c.4. Citations for data demonstrating
high priority provided in 1a.3 1) National Kidney Foundation: K/DOQI Clinical
Practice Guidelines for Bone Metabolism and Disease in Chronic Kidney Disease.
American Journal of Kidney Disease 2003 42:S1-S202 (suppl 3). 2) Kidney Disease:
Improving Global Outcomes (KDIGO) CKD-MBD Work Group: KDIGO Clinical Practice
Guideline for the Diagnosis, Evaluation, Prevention, and Treatment of Chronic
Kidney Disease-Mineral and Bone Disorder (CKD-MBD). Kidney International 2009 76
(Suppl 113): S1-S130. 3) Block GA, Klassen PS, Lazarus JM, et al. Mineral
metabolism, mortality, and morbidity in maintenance hemodialysis. Journal of the
American Society of Nephrology : JASN 2004 15:2208-18. 4) Young EW, Albert JM,
Satayathum S, et al. Predictors and consequences of altered mineral metabolism:
the Dialysis Outcomes and Practice Patterns Study. Kidney international 2005
67:1179-87. 5) Kalantar-Zadeh K, Kuwae N, Regidor DL, et al. Survival
predictability of time-varying indicators of bone disease in maintenance
hemodialysis patients. Kidney international 2006 70:771-80. 6) Kimata N, Albert
JM, Akiba T, et al. Association of mineral metabolism factors with all-cause and
cardiovascular mortality in hemodialysis patients: the Japan dialysis outcomes
and practice patterns study. Hemodialysis international. International Symposium
on Home Hemodialysis 2007 11:340-8. 7) Tentori F, Blayney MJ, Albert JM, et al.
Mortality risk for dialysis patients with different levels of serum calcium,
phosphorus, and PTH: the Dialysis Outcomes and Practice Patterns Study (DOPPS).
American journal of kidney diseases : the official journal of the National
Kidney Foundation 2008 52:519-30. 8) Chertow G.M., Raggi P., Chasan-Taber S.,
Bommer J., Holzer H., Burke S.K. Determinants of progressive vascular
calcification in haemodialysis patients. Nephrology Dialysis Transplantation
2004 19 (6), pp. 1489-1496. 9) Dhingra R, Sullivan LM, Fox CS, Wang TJ,
D´Agostino RB Sr, Gaziano JM, Vasan RS: Relations of serum phosphorus and
calcium levels to the incidence of cardiovascular disease in the community. Arch
Intern Med 2007 167: 879–885. 10) Wang AY, Lam CW, Wang M, Chan IH, Lui SF,
Sanderson JE. Is valvular calcification a part of the missing link between
residual kidney function and cardiac hypertrophy in peritoneal dialysis
patients? Clinical journal of the American Society of Nephrology 2009 4:1629-36.
11) Ketteler M, Schlieper G, Floege J. Calcification and cardiovascular health:
new insights into an old phenomenon. Hypertension 2006 47:1027–1034. 12)
Giachelli CM. Vascular calcification mechanisms. Journal of the American Society
of Nephrology : JASN 2004 15:2959–2964. 13) Yang H, Curinga G, Giachelli CM.
Elevated extracellular calcium levels induce smooth muscle cell matrix
mineralization in vitro. Kidney Int. 2004;66(6):2293–2299. 14) U S Renal Data
System, USRDS 2013 Annual Data Report: Atlas of Chronic Kidney Disease and
End-Stage Renal Disease in the United States, National Institutes of Health,
National Institute of Diabetes and Digestive and Kidney Diseases, Bethesda, MD,
2013.
Measure Specifications
- NQF Number (if applicable): 1454
- Description: Percentage of adult dialysis patients with a 3-month
rolling average of total uncorrected calcium (serum or plasma) greater than
10.2 mg/dL (hypercalcemia)
- Numerator: Number of patient-months in the denominator with 3-month
rolling average of total uncorrected serum (or plasma) calcium greater than
10.2 mg/dL
- Denominator: Number of patient-months among adult (greater than or
equal to 18 years old) in-center hemodialysis, home hemodialysis, or
peritoneal dialysis patients under the care of the dialysis facility for the
entire reporting month who have had ESRD for greater than 90
days.
- Exclusions: Exclusions that are implicit in the denominator
definition include all patients who have not been in the facility the entire
reporting month (transient patients), and patients who have had ESRD for
<91 days. There are no additional exclusions for this measure.
- HHS NQS Priority: Making Care Safer
- HHS Data Source: Data Source/Registry: CROWNWeb data from January
2013-December 2013.
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Endorsed on October 2, 2015.
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has not been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Renal (Aug 18 draft
report available as of 9/17/15)
- Review for Importance: The measure does not meet the Importance
criteria(1a. Evidence, 1b. Performance Gap)1a. Evidence: 0-H; 1-M; 22-L; 0-I;
Insufficient Evidence with Exception: 19-Y; 4-N; 1b. Performance Gap: 0-H;
0-M; 21-L; 2-I Reconsideration Performance Gap: 0-H; 7-M; 6-L; 5-IRationale:•
For this intermediate outcome measure, evidence provided by the developer
included two clinical guidelines and an April 2013 Technical Expert Panel
(TEP) review. The Kidney Disease: Improving Global Outcomes (KDIGO) graded the
evidence 2D, very low evidence, and the Kidney Disease Outcomes Quality
Initiative (KDOQI) was expert opinion only. The TEP did not recommend any
revisions to the measure.• While the Committee acknowledged that this measure
was an important safety measure that filled a gap area in bone and mineral
disease, members agreed that evidence demonstrating that calcium
concentrations less than 10.2 mg/dL place the patient at increased risk of
cardiovascular events and all-cause mortality was largely associative. The
Committee allowed the measure to move forward on an evidence exception.• The
developer provided January – December 2013 CROWNWeb clinical data on
performance scores generated among 5,973 facilities that had at least one
eligible patient that indicate the mean gap of performance is two point one
percent.• Disparities data were also provided that imply that there are
statistically significant changes in performance scores depending on sex,
race, ethnicity, and age; however, the Committee found it was not a clinically
meaningful difference.• The Committee concluded there was very little room for
improvement and the current gap did not warrant a national performance
measure.• The Committee considered the measure for endorsement with reserve
status due to the fact that there were no other bone and mineral measures;
however, determined that losing endorsement would not affect current
performance of the measure.• Some committee members suggested lowering the
measure threshold to allow for a greater gap in care, however, the developer
stated there was no evidence for a lower threshold and two previous TEPs had
supported the current threshold of less than 10.2 mg/dL.• The Committee
encouraged the developer to consider alternative bone and mineral measures.
The developer reassured the Committee that they have convened multiple TEPs in
order to develop additional measures in this area but have not been successful
thus far to create another strong, evidence supported measure in this area.•
At the post-comment call, the Committee decided to reconsider this measure
based on the information provided by the developer. While the measure did not
pass the gap criterion, the Committee decided they would like to consider this
measure for reserve status.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria(2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity)2a. Reliability: 0-H;
15-M; 2-L; 0-I; 2b. Validity: 0-H; 17-M; 0-L; 0-IRationale:• The developer
used CROWNWeb and Medicare claims data from January 2013 – December 2013 to
calculate the inter-unit reliability (IUR) for the 12 month period to assess
the reliability of this measure. The IUR is 0.86 with the confidence interval
being 0.78 - 0.84. This suggests that 86% of variation in the measure is
attributed to between facility variance. The Committee agreed that the testing
results suggest this measure is reliable• The developer assessed validity
using Poisson regression analysis to identify the predictive strength of
facility level performance scores for hypercalcemia on mortality, using the
2013 standardized mortality ratio. The results of the Poisson regression
suggest that facilities with a higher percentage of patient-months with
hypercalcemia experience a higher standardized mortality rate relative to
facilities with a lower percentage of patients with hypercalcemia. The
Committee agreed that the testing results suggest the measure is
valid.
- Review for Feasibility: 12-H; 5-M; 0-L; 0-I(3a. Clinical data
generated during care delivery; 3b. Electronic sources; 3c.Susceptibility to
inaccuracies/ unintended consequences identified 3d. Data collection strategy
can be implemented)Rationale:• The data elements required are routinely
measured as part of patient care and can be derived from CROWNWeb and
electronic health records. The Committee agreed that collection of this data
is feasible.
- Review for Usability: 6-H; 12-M; 0-L; 0-I(Meaningful,
understandable, and useful to the intended audiences for 4a. Public
Reporting/Accountability and 4b. Quality Improvement, 4c. Susceptibility to
inaccuracies/unintended consequences identified)Rationale:The measure is
currently in use in the Dialysis Facility Compare program. The Committee did
not have any major concerns with the use and usability of this
measure.
- Review for Related and Competing Measures: No related or competing
measures noted.
- Endorsement Public Comments: Two commenters agreed with the
Committee’s initial recommendation to not endorse this measure citing a poor
measure would be more harmful than no measure.
Developer Response: During the recent DFC performance period, 1538
facilities had 0% of patients with hypercalcemia, 1494 facilities had 1% of
patients with hypercalcemia, 889 facilities had 2%, 594 had 3%, and 1360
facilities had 4% or more of their patients with hypercalcemia. The
distribution demonstrates the success of many facilities in their ability to
achieve extremely low rates of hypercalcemia, as over 3000 facilities have 1%
or less patients with hypercalcemia. However, when one looks at the average
national performance of 2%, they may interpret that statistic as demonstrating
the absence of a performance gap for this safety measure. That interpretation
ignores the highly skewed distribution of facility performance for this safety
measure as shown in the figure. For this safety measure, the performance gap
is clearly demonstrated by comparing the 1360 US dialysis facilities (23% of
the total reported facilities) with 4% or greater patients with hypercalcemia
to the majority of dialysis facilities that achieve extremely low
hypercalcemia rates. We maintain that the measure is important for safety
monitoring, as nearly one-fourth of US dialysis facilities are relatively poor
at preventing hypercalcemia, an intermediate outcome consistently associated
with poorer patient survival and clearly influenced by providers’ bone and
mineral disease management practices.
- Endorsement Committee Recommendation: This measure was originally
endorsed in 2011 and is specified at the facility level. The measure is
currently used in the CMS Dialysis Facility Compare public reporting program.
While the Committee agreed that evidence was largely associative, they allowed
the measure to move forward on an evidence exception due to it being
considered an important safety measure that fills a gap area in bone and
mineral disease. The Committee initially concluded there was very little
opportunity for improvement and the 2.1% gap identified by the developer did
not warrant a national performance measure. However, based on new data
provided by the developer during the post comment call, the Committee agreed
to consider the measure for endorsement with reserve status, noting there were
no other bone and mineral measures available in the field. After review of the
reliability, validity, feasibility, and usability of the measure, the
Committee agreed that the measure should be recommended for endorsement with
reserve status.
Standing Committee Recommendation for Endorsement with Potential for
Reserve Status: 19-Y; 0-N
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF review
and endorsement of measure updates and examination of SDS
factors.
- Workgroup Rationale: MAP conditionally supported this measure,
pending NQF review and endorsement of measure updates and examination of SDS
factors. MAP agreed that this MUC measures a critical outcome in a
high-priority domain for the ESRD QIP program. ESRD patients average nearly
two hospitalizations per year that burden patients and health systems alike.
MUC-693 is aligned with MUC-1167, a measure of readmissions.
- Public comments received: 8
Rationale for measure provided by HHS
1b.1. Rationale
Hospitalization rates are an important indicator of patient morbidity and
quality of life. On average, dialysis patients are admitted to the hospital
twice a year and spend an average of 11 days in the hospital per year (USRDS,
2014). Hospitalizations account for approximately 37 percent of total Medicare
expenditures for ESRD patients. Measures of the frequency of hospitalization
have the potential to help efforts to control escalating medical costs, and to
play an important role in identifying potential problems and helping facilities
provide cost-effective health care. 1c.4. Citations 1) U S Renal Data System,
USRDS 2014 Annual Data Report: Atlas of Chronic Kidney Disease and End-Stage
Renal Disease in the United States, National Institutes of Health, National
Institute of Diabetes and Digestive and Kidney Diseases, Bethesda, MD, 2014. 2)
Wheeler J, Hirth R, Meyer K, Messana JM. Exploring preventable hospitalizations
of dialysis patients. J Am Soc Nephrol 22, 2011. [3] Erickson KF, Winkelmayer
WC, Chertow GM, Bhattacharya J. Physician visits and 30-day hospital
readmissions in patients receiving hemodialysis. J Am Soc Nephrol 25, 2014
(published online before print). [4] Arora P, Kausz AT, Obrador GT, Ruthazer R,
Khan S, Jenuleson CS, Meyer KB, Pereira BJ. Hospital utilization among chronic
dialysis patients. J Am Soc Nephrol 11: 740 –746, 2000. [5] Piraino B.
Staphylococcus aureus infections in dialysis patients: focus on prevention.
ASAIO J 46(6): S13-S17, 2000. [6] Dalrymple LS, Johansen KL, Romano PS, Chertow
GM, Mu Y, Ishida JH, Grimes B, Kaysen GA, Nguyen DV. Comparison of
hospitalization rates among for-profit and nonprofit dialysis facilities. Clin J
Am Soc Nephrol 9, 2014 (published online before print).
Measure Specifications
- NQF Number (if applicable):
- Description: Standardized hospitalization ratio for admissions
among ESRD dialysis patients.
- Numerator: Number of inpatient hospital admissions among eligible
patients at the facility during the reporting period.
- Denominator: Number of hospital admissions that would be expected
among eligible patients at the facility during the reporting period, given the
patient mix at the facility.
- Exclusions: UM-KECC’s treatment history file provides a complete
history of the status, location, and dialysis treatment modality of an ESRD
patient from the date of the first ESRD service until the patient dies or the
data collection cutoff date is reached. For each patient, a new record is
created each time he/she changes facility or treatment modality. Each record
represents a time period associated with a specific modality and dialysis
facility. SIMS/CROWNWeb is the primary basis for placing patients at dialysis
facilities and dialysis claims are used as an additional source. Information
regarding first ESRD service date, death and transplant is obtained from
additional sources including the CMS Medical Evidence Form (Form CMS-2728),
transplant data from the Organ Procurement and Transplant Network (OPTN), the
Death Notification Form (Form CMS-2746) and the Social Security Death Master
File. As patients can receive dialysis treatment at more than one facility in
a given year, we assign each patient day to a facility (or no facility, in
some cases) based on a set of conventions below, which largely align with
those for the Standardized Mortality Ratio (SMR). We detail patient inclusion
criteria, facility assignment and how to count days at risk, all of which are
required for the risk adjustment model. General Inclusion Criteria for
Dialysis Patients Though a patient’s follow-up in the database can be
incomplete during the first 90 days of ESRD therapy, we only include a
patient’s follow-up into the tabulations after that patient has received
chronic renal replacement therapy for at least 90 days. Thus,
hospitalizations, mortality and survival during the first 90 days of ESRD do
not enter into the calculations. This minimum 90-day period also assures that
most patients are eligible for Medicare, either as their primary or secondary
insurer. It also excludes from analysis patients who die or recover during the
first 90 days of ESRD. In order to exclude patients who only received
temporary dialysis therapy, we assigned patients to a facility only after they
had been on dialysis there for the past 60 days. This 60 day period is used
both for patients who started ESRD for the first time and for those who
returned to dialysis after a transplant. That is, hospitalizations during the
first 60 days of dialysis at a facility do not affect the SHR of that
facility. Identifying Facility Treatment Histories for Each Patient For each
patient, we identify the dialysis provider at each point in time. Starting
with day 91 after onset of ESRD, we attribute patients to facilities according
to the following rules. A patient is attributed to a facility once the patient
has been treated there for the past 60 days. When a patient transfers from one
facility to another, the patient continues to be attributed to the original
facility for 60 days and then is attributed to the destination facility. In
particular, a patient is attributed to their current facility on day 91 of
ESRD if that facility had treated him or her for the past 60 days. If on day
91, the facility had not treated a patient for the past 60 days, we wait until
the patient reaches day 60 of continuous treatment at that facility before
attributing the patient to that facility. When a patient is not treated in a
single facility for a span of 60 days (for instance, if there were two
switches within 60 days of each other), we do not attribute that patient to
any facility. Patients are removed from facilities three days prior to
transplant in order to exclude the transplant hospitalization. Patients who
withdrew from dialysis or recovered renal function remain assigned to their
treatment facility for 60 days after withdrawal or recovery. If a period of
one year passes with neither paid dialysis claims nor SIMS information to
indicate that a patient was receiving dialysis treatment, we consider the
patient lost to follow-up and do not include that patient in the analysis. If
dialysis claims or other evidence of dialysis reappears, the patient is
entered into analysis after 60 days of continuous therapy at a single
facility. Days at Risk for Medicare Dialysis Patients After patient
treatment histories are defined as described above, periods of follow-up in
time since ESRD onset are created for each patient. In order to adjust for
duration of ESRD appropriately, we define 6 time intervals with cut points at
6 months, 1 year, 2 years, 3 years and 5 years. A new time period begins each
time the patient is determined to be at a different facility, or at the start
of each calendar year or when crossing any of the above cut points. Since
hospitalization data tend not to be as complete as mortality data, we include
only patients whose Medicare billing records should include all
hospitalizations. To achieve this goal, we require that patients reach a
certain level of Medicare-paid dialysis bills to be included in the
hospitalization statistics, or that patients have Medicare-paid inpatient
claims during the period. Specifically, months within a given dialysis
patient-period are used for SHR calculation when they meet the criterion of
being within two months after a month with either: (a) $900+ of Medicare-paid
dialysis claims OR (b) at least one Medicare-paid inpatient claim. The
intention of this criterion is to assure completeness of information on
hospitalizations for all patients included in the analysis. The number of
days at risk in each of these patient-ESRD-facility-year time periods is used
to calculate the expected number of hospital admissions for the patient during
that period. The SHR for a facility is the ratio of the total number of
observed hospitalizations to the total number of expected hospitalizations
during all time periods at the facility. Based on a risk adjustment model for
the overall national hospitalization rates, we compute the expected number of
hospitalizations that would occur for each month that each patient is
attributed to a given facility. The sum of all such expectations over patients
and months yields the overall number of hospital admissions that would be
expected given the specific patient mix and this forms the denominator of the
measure. The denominator of the SHR stems from a proportional rates model
(Lawless and Nadeau, 1995; Lin et al., 2000; Kalbfleisch and Prentice, 2002).
This is the recurrent event analog of the well-known proportional hazards or
Cox model (Cox, 1972; Kalbfleisch and Prentice, 2002). To accommodate
large-scale data, we adopt a model with piecewise constant baseline rates
(e.g. Cook and Lawless, 2007) and the computational methodology developed in
Liu, Schaubel and Kalbfleisch (2012).
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Administrative claims
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: This measure is an update to NQF #1463, and has
been submitted to NQF for endorsement maintenance with a decision pending in
2016. The update modifies the risk adjustment model.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because
mortality rates would be more meaningful to consumers and actionable for
facilities. MAP also discussed the need to include hospice after the start
of dialysis as an exclusion because patients sometimes undergo a trial period
of three to four months of dialysis before determining to stop
treatment.
- Public comments received: 8
Rationale for measure provided by HHS
There is evidence indicating
that mortality among black ESRD patients is lower than mortality for white ESRD
patients, mortality for Hispanic ESRD patients is lower than mortality for
non-Hispanic ESRD patients, and mortality for female ESRD patients is lower than
mortality for male ESRD patients (see references below). Without a race
adjustment, identical SMRs for one facility with predominantly white patients
and one facility with predominantly black patients, for example, would give the
false impression that quality of care at the two facilities was equivalent, when
in fact adjusted mortality at the facility with more black patients would be
lower if performance was identical. The SMR is adjusted for all three of these
patient characteristics to avoid masking disparities in care across groups. To
examine sociodemographic disparities we included quintiles of socioeconomic
status (defined for each patient as the median zipcode code household income).
This had little effect on the resulting expected deaths counts from the model.
See the section on risk adjustment for further details. References: J
Kalbfleisch, R Wolfe, S Bell, R Sun, J Messana, T Shearon, V Ashby, R Padilla, M
Zhang, M Turenne, J Pearson, C Dahlerus, Y Li, 2015, “Risk Adjustment and the
Assessment of Disparities in Dialysis Mortality Outcomes” accepted for
publication by JASN; Powe, NR. Reverse race and ethnic disparities in survival
increase with severity of chronic kidney disease: What does this mean? Clin J Am
Soc Nephrol 1: 905–906, 2006; Cowie CC, Port FK, Rust KF, Harris MI: Differences
in survival between black and white patients with diabetic end-stage renal
disease. Diabetes Care 17: 681–687, 1994).
Measure Specifications
- NQF Number (if applicable):
- Description: Standardized ratio for death among ESRD dialysis
patients. (The endorsed specifications of the measure are: Risk-adjusted
standardized hospitalization ratio for admissions for dialysis facility
patients.)
- Numerator: Number of deaths among eligible patients at the facility
during the time period.
- Denominator: Number of deaths that would be expected among eligible
dialysis patients at the facility during the time period, given the mortality
rate is at the national average and the patient mix at the
facility.
- Exclusions: UM-KECC’s treatment history file provides a complete
history of the status, location, and dialysis treatment modality of an ESRD
patient from the date of the first ESRD service until the patient dies or the
data collection cutoff date is reached. For each patient, a new record is
created each time he/she changes facility or treatment modality. Each record
represents a time period associated with a specific modality and dialysis
facility. SIMS/CROWNWeb is the primary basis for placing patients at dialysis
facilities and dialysis claims are used as an additional source. Information
regarding first ESRD service date, death and transplant is obtained from
additional sources including the CMS Medical Evidence Form (Form CMS-2728),
transplant data from the Organ Procurement and Transplant Network (OPTN), the
Death Notification Form (Form CMS-2746) and the Social Security Death Master
File. The denominator for SMR for a facility is the total number of expected
deaths during all patient-records at the facility. The number of days at risk
in each of these patient-records is used to calculate the expected number of
deaths for that patient-record. The denominator is based on expected
mortality calculated from a Cox model (Cox, 1972; SAS Institute Inc., 2004;
Kalbfleisch and Prentice, 2002; Collett, 1994). The model used is fit in two
stages. The stage 1 model is a Cox model stratified by facility and adjusted
for patient age, race, ethnicity, sex, diabetes, duration of ESRD, nursing
home status, patient comorbidities at incidence, calendar year and body mass
index (BMI) at incidence. This model allows the baseline survival
probabilities to vary between strata (facilities), and assumes that the
regression coefficients are the same across all strata. Stratification by
facility at this stage avoids biases in estimating regression coefficients
that can occur if the covariate distributions vary substantially across
centers. The results of this analysis are estimates of the regression
coefficients in the Cox model and these provide an estimate of the relative
risk for each patient. This is based on a linear predictor that arises from
the Cox model, and is then used as an offset in the stage 2 model, which is
unstratified and includes an adjustment for the race-specific age-adjusted
state population death rates. Assignment of Patients to Facilities We detail
patient inclusion criteria, facility assignment and how to count days at risk,
all of which are required for the risk adjustment model. As patients can
receive dialysis treatment at more than one facility in a given year, we
assign each patient day to a facility (or no facility, in some cases) based on
a set of conventions below. Since a patient’s follow-up in the database can be
incomplete during the first 90 days of ESRD therapy, we only include a
patient’s follow-up into the tabulations after that patient has received
chronic renal replacement therapy for at least 90 days. Thus,
hospitalizations, mortality and survival during the first 90 days of ESRD do
not enter into the calculations. This minimum 90-day period also assures that
most patients are eligible for Medicare, either as their primary or secondary
insurer. It also excludes from analysis patients who die or recover during the
first 90 days of ESRD. In order to exclude patients who only received
temporary dialysis therapy, we assigned patients to a facility only after they
had been on dialysis there for the past 60 days. This 60 day period is used
both for patients who started ESRD for the first time and for those who
returned to dialysis after a transplant. That is, deaths and survival during
the first 60 days of dialysis at a facility do not affect the SMR of that
facility. Identifying Facility Treatment Histories for Each Patient For each
patient, we identify the dialysis provider at each point in time. Starting
with day 91 after onset of ESRD, we attribute patients to facilities according
to the following rules. A patient is attributed to a facility once the patient
has been treated there for the past 60 days. When a patient transfers from one
facility to another, the patient continues to be attributed to the original
facility for 60 days and then is attributed to the destination facility from
day 61. In particular, a patient is attributed to their current facility on
day 91 of ESRD if that facility had treated him or her for the past 60 days.
If on day 91, the facility had not treated a patient for the past 60 days, we
wait until the patient reaches day 60 of continuous treatment at that facility
before attributing the patient to that facility. When a patient is not treated
in a single facility for a span of 60 days (for instance, if there were two
switches within 60 days of each other), we do not attribute that patient to
any facility. Patients were removed from a facility’s analysis upon receiving
a transplant. Patients who withdrew from dialysis or recovered renal function
remain assigned to their treatment facility for 60 days after withdrawal or
recovery. If a period of one year passes with neither paid dialysis claims
nor SIMS information to indicate that a patient was receiving dialysis
treatment, we consider the patient lost to follow-up and do not include that
patient in the analysis. If dialysis claims or other evidence of dialysis
reappears, the patient is entered into analysis after 60 days of continuous
therapy at a single facility. Days at Risk for Each Patient-Record After
patient treatment histories are defined as described above, periods of
follow-up time (or patient-records) are created for each patient. A
patient-record begins each time the patient is determined to be at a different
facility or at the start of each calendar year. The number of days at risk
starts over at zero for each patient record so that the number of days at risk
for any patient-record is always a number between 0 and 365 (or 366 for leap
years). Therefore, a patient who is in one facility for all four years gives
rise to four patient-records and is analyzed the same way as would be four
separate patients in that facility for one year each. When patients are
treated at the same facility for two or more separate time periods during a
year, the days at risk at the facility is the sum of all time spent at the
facility for the year so that a given patient can generate only one
patient-record per year at a given facility. For example, consider a who
patient spends two periods of 100 days assigned to a facility, but is assigned
to a different facility for the 165 days between these two 100-day periods.
This patient will give rise to one patient-record of 200 days at risk at the
first facility, and a separate patient-record of 165 days at risk at the
second facility. Then we use the number of days at risk in each of these
patient-records to calculate the expected number of deaths for that
patient-record, and sum the total number of expected deaths during all
patient-records at the facility as the expected number of death for that
facility. Detailed methodology is described in Statistical Risk Model and
Variables S.14.
- HHS NQS Priority: Making Care Safer
- HHS Data Source: CROWNWeb
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: CMS has updated NQF#0369, and has resubmitted
the measure for endorsement maintenance.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF review
and endorsement of measure updates and examination of SDS
factors.
- Workgroup Rationale: MAP conditionally supported this measure,
pending NQF decision from SDS trial period and re-endorsement of the measure.
MAP believed this to be a good measure in order to increase accountability and
encourage care coordination.
- Public comments received: 7
Rationale for measure provided by HHS
Unplanned readmission rates
are an important indicator of patient morbidity and quality of life. On average,
dialysis patients are admitted to the hospital nearly twice a year and
hospitalizations account for approximately 38 percent of total Medicare
expenditures for dialysis patients (U.S. Renal Data System, 2012). In 2010, more
than 30% of dialysis patient discharges from an all-cause hospitalization were
followed by an unplanned readmission within 30 days (U.S. Renal Data System,
2012). Measures of the frequency of unplanned readmissions, such as SRR, help
efforts to control escalating medical costs, play an important role in providing
cost-effective health care, and support coordination of care across inpatient
and outpatient settings: discharge planning, transition, and follow-up care.
Studies have shown that pre- and post-discharge interventions may reduce
admission and unplanned readmission rates. A variety of studies on non-ESRD
populations that evaluated post-discharge interventions (Dunn 1994; Bostrom
1996; Dudas 2001; Azevedo 2002; Coleman 2004; Coleman 2006; Balaban 2008; Braun
2009) or a combination of pre- and post-discharge interventions (Naylor 1994;
McDonald 2001; Creason 2001; Ahmed 2004; Anderson 2005; Jack 2009; Koehler 2009;
Parry 2009) have indicated a reduction in the risk of unplanned readmissions to
various degrees. In addition, a recent study in the ESRD population found that
certain postdischarge assessments and changes in treatment at the dialysis
facility may be associated with a reduced risk of readmission (Chan 2009).
Altogether, these studies support the potential for modifying unplanned
readmission rates with interventions performed prior to and immediately
following patient discharge. Ahmed A, Thornton P, Perry GJ, Allman RM, DeLong
JF. Impact of atrial fibrillation on mortality and readmission in older adults
hospitalized with heart failure. Eur J Heart Fail. 2004;6(4):421–426. Anderson
MA, Clarke MM, Helms LB, Foreman MD. Hospital readmission from home health care
before and after prospective payment. J Nurs Scholarsh. 2005;37(1):73–79.
Azevedo A, Pimenta J, Dias P, Bettencourt P, Ferreira A, Cerqueira-Gomes M.
Effect of a heart failure clinic on survival and hospital readmission in
patients discharged from acute hospital care. Eur J Heart Fail. 2002
Jun;4(3):353–359. Balaban RB, Weissman JS, Samuel PA, Woolhandler S. Redefining
and redesigning hospital discharge to enhance patient care: a randomized
controlled study. J Gen Intern Med. 2008;23(8):1228–1233. Bostrom J, Caldwell
J, McGuire K, Everson D. Telephone follow-up after discharge from the hospital:
Does it make a difference? Appl Nurs Res. 1996;9:47–52. Braun E, Baidusi A,
Alroy G, Azzam ZS. Telephone follow-up improves patients satisfaction following
hospital discharge. Eur J Internal Med. 2009;20:221–225. Chan K, Lazarus M,
Wingard R, et al. “Association between repeat hospitalization and early
intervention in dialysis patients following hospital discharge.” Kidney
International (2009) 76:331-41. Coleman E, Parry C, Chalmers S, et al. The care
transitions intervention. Arch Internal Med. 2006;166:1822–1828. Creason H.
Congestive heart failure telemanagement clinic. Lippencotts Case Management:
Managing the Process of Patient Care. 2001 Jul-Aug;6(4):146-56. Dudas V,
Bookwalter T, Kerr KM et al. The impact of follow-up telephone calls to patients
after hospitalization. American Journal of Medicine. 2001; 111(9B):26S-30S Dunn
JM, Elliot TB, Lavy JA et al. Outpatient clinic review after arterial
reconstruction: is it necessary? Annals of the Royal College of Surgeons of
England. 1994 Sep;76(5):304-6. Jack B, Chetty V, Anthony D, et al. “A
reengineered hospital discharge program to decrease rehospitalizaton.” Annals of
Internal Medicine (2009) 150:178-88. Koehler BE, Richter KM, Youngblood L et
al. Reduction of 30-day postdischarge hospital readmission or emergency
department (ED) visit rates in high-risk elderly medical patients through
delivery of a targeted care bundle. Journal of Hospital Medicine. 2009
Apr;4(4):211-8. McDonald, MD. The hospitalist movement: wise or wishful
thinking? Nurse management. 2001 Mar;32(3):30-1. Naylor M, Brooten D, Jones R
et al. Comprehensive discharge planning for the hospitalized elderly. A
randomized clinical trial. Annals of Internal Medicine. 1994 Jun
15;120(12):999-1006. Parry C, Min SH, Chugh A et al. Further application of the
care transitions intervention: results of a randomized controlled trial
conducted in a fee-for-service setting. Home Health Care Services Quarterly.
2009;28(2-3):84-99.
Measure Specifications
- NQF Number (if applicable): 2496
- Description: The Standardized Readmission Ratio is the ratio of a
dialysis facility’s (DF) total Medicare-paid index discharges for its dialysis
patients from acute care hospitals (ACHs) that result in an unplanned
Medicare-paid ACH readmission within 30 days to the total readmissions
expected for the DF, given the discharging ACH, the DF, patient/index
hospitalization characteristics, and the US median for DFs. (The endorsed
specifications of the measure are: The Standardized Readmission Ratio (SRR) is
defined to be the ratio of the number of index discharges from acute care
hospitals that resulted in an unplanned readmission to an acute care hospital
within 30 days of discharge for Medicare-covered dialysis patients treated at
a particular dialysis facility to the number of readmissions that would be
expected given the discharging hospitals and the characteristics of the
patients as well as the national norm for dialysis facilities. Note that in
this document, “hospital” always refers to acute care
hospital.)
- Numerator: Each facility’s observed number of hospital discharges
that are followed by an unplanned hospital readmission within 4–30 days of
discharge (The endorsed specifications of the measure are: Each facility’s
observed number of hospital discharges that are followed by an unplanned
hospital readmission within 30 days of discharge)
- Denominator: The expected number of unplanned readmissions in each
facility, which is derived from a model that accounts for patient
characteristics and discharging acute care hospitals.
- Exclusions: Hospital discharges that: Are not live discharges;
Result in a patient dying within 30 days with no readmission; Are against
medical advice; Include a primary diagnosis for cancer, mental health or
rehabilitation; Occur after a patient’s 12th admission in the calendar year;
Are from a PPS-exempt cancer hospital; Result in a transfer to another
hospital on the same day; Are followed by a readmission within 3 days
(inclusive).(The endorsed specifications of the measure are: Hospital
discharges that:• Are not live discharges• Result in a patient dying within 30
days with no readmission• Are against medical advice• Include a primary
diagnosis for cancer, mental health or rehabilitation• Occur after a patient’s
12th admission in the calendar year• Are from a PPS-exempt cancer hospital•
Result in a transfer to another hospital on the same day)
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: Administrative claims
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: The measure was endorsed in December
2014.
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: All-Cause Admissions
and Readmissions Measures
- Review for Importance: The measure meets the Importance
criteria(1a. Evidence, 1b. Performance Gap, 1c. High Impact)1a. Evidence:
Y-17; N-6; 1b. Performance Gap: H-15; M-8; L-0; I-0; 1c. Impact: H-20; M-3;
L-0; I-0Rationale:• There was general agreement that this is a high impact
area of measurement and there is opportunity for improvement, with the overall
readmissions rate at approximately 30 percent and the readmissions rate for
hemodialysis patients at approximately 36 percent.• The Committee agreed that
certain post-discharge assessments and changes in treatment at the dialysis
facility may be associated with a reduced risk of readmissions.• One committee
member was concerned that the cause of the reduced risk of admissions had more
to do with interventions by nephrologists, rather than the dialysis unit.
Further, the member noted that NQF guidance regarding evidence for outcome
measures are not strong enough, suggesting that the quality, quantity, and
consistency of the evidence should be evaluated even for outcome
measures.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria(2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity)2a. Reliability: H-5;
M-17; L-1; I-0 2b. Validity: H-1; M-16; L-7; I-0Rationale:• The Standing
Committee discussed a number of threats to validity of the measure, mainly
focusing on whether the dialysis unit was the accountable entity for 30-day
readmissions back to acute care facilities.o One member argued that there are
limited interventions a dialysis unit can implement that would influence this
particular measure. This member noted that there are limited structures that
allow the medical director or the governing body of the dialysis unit to
compel nephrologists to see patients immediately after discharge from an acute
care facility.o Other Committee members noted that while the locus of control
may not be solely the dialysis facility, this measure and improvement efforts
tied to it may be the type of impetus needed to improve care for this
population. These members also noted that with patients spending nine to 12
hours in these units during the week, more could be done to improve care for
these patients.
- Review for Feasibility: H-11; M-9; L-4; I-0(3a. Clinical data
generated during care delivery; 3b. Electronic sources; 3c.Susceptibility to
inaccuracies/ unintended consequences identified 3d. Data collection strategy
can be implemented)Rationale:• The required data elements are routinely
generated and used during care delivery and all data elements are in defined
fields in electronic claims
- Review for Usability: H-3; M-11; L-10; I-0(Meaningful,
understandable, and useful to the intended audiences for 4a. Public
Reporting/Accountability and 4b. Quality Improvement)Rationale: Some members
were concerned that the threats to validity would cause unintended
consequences with the use of this measure in public reporting or
accountability applications; however, there was limited evidence of unintended
consequences identified.
- Review for Related and Competing Measures: No related or competing
measures noted.
- Endorsement Public Comments: NQF received 10 post-evaluation
comments regarding this measure.There was one supportive comment, arguing that
this measureaddresses an important high priority for measurement with
sufficientroom for improvement in the care processes of dialysis units.
Theremaining comments raised concern about the measure
specifications,including the numerator specifications, denominator
specifications,attribution, temporal logic, risk adjustment, testing, and
intendeduse.
Numerator Specifications
- Commenters were concerned that the numerator definition relieson an
accurate determination of planned admissions using codesfrom a non-ESRD
population. Commenters encouraged validation ofthese codes in the ESRD
population through examination ofpatient-level data from the CMS dry
run.
- Commenters raised strong concern that the numerator of acuteadmissions
does not consider ESRD-specific patient management –noting that this list of
admissions should be tailored toinclude nephrology–related treatment.
Commenters requestedclarification on whether PD catheter placement or
omentectomy,vascular access creation, or transfusion for a
transfusiondependent patient fall is included in the
measure.
Denominator Specifications
- Specifically, a commenter disagreed that the number ofdischarges should
not be the determinant of the denominator, butrather the number of
readmissions should be based on the totalnumber of patients treated in a
facility. Further, the commenterargued that the current measure is
vulnerable to being skewed bythe effect of one or two complex patients
requiring frequenthospitalization.
Attribution
- Many commenters challenged the notion that dialysis facilitieshave the
ability to affect readmissions. Commenters explainedthat dialysis facilities
often do not receive any directcommunication from the discharging hospital
or facility fortheir patients, and are not supported to have
coordinatedpresence in multiple hospitals. One commenter noted that apatient
might be readmitted before ever being seen in thedialysis unit. This
commenter noted that these readmissions arenot actionable by the dialysis
facility and should not beincluded in the measure. Further, commenters noted
a lack ofevidence showing that changes in a dialysis unit are the
factorsdriving performance improvement.
- Additionally, a commenter noted that the majority of dialysisfacilities
do not have the resources for additional personnel,such as case managers, to
improve care coordination betweendialysis facilities and other health care
providers. Thiscommenter argued that dialysis facilities have a role
inreducing all-cause readmissions; however, these facilities maynot be the
locus of control to manage the coordination required.• Further, the
commenter discussed that a dialysis unit has nocontrol over a hospital's
decision to re-admit a patient. Thehospital physician decides whether or not
to admit a patient,and many of these admissions have nothing to do with
thenephrological issues being addressed by the dialysis facilityand should
also be excluded from the measure.
- Commenters also requested clarification on the frequency ofadmissions
that occur prior to the first post-acute visit to adialysis
facility.
Exclusions
- Commenters requested clarification on how specific patientcohorts are
handled in the measure. Additionally, a commenterrequested clarification on
how readmissions as a result ofunsuccessful kidney transplants are handled
in the 6 monthsfollowing the transplant. Another commenter
requestedclarification on the rationale for excluding indexhospitalizations
after the patient’s 12th admission in thecalendar year. Further, this
commenter requested clarificationon why patients without complete claims
histories and those whoare readmitted within the 1-3 days after discharge
are notexcluded from the measure.
Risk Adjustment
- Commenters noted concern with the validity of the two-stagerandom
effects risk-adjustment model. In particular, theyrequested clarification on
how the measure is impacted bycommunities where there is only one major
hospital and/or onemajor dialysis facility versus communities where there is
manyof one or both. The Commenters also noted that the riskadjustment model
should reduce the number of variables to thosethat are clinically
relevant.
- Further, another commenter noted that other comorbiditiesshould be
included in the risk adjustment model, includingsickle cell trait,
angiodysplasia, myelodysplasia, diverticularbleeding, and asthma.
Additionally, the commenter suggestedadjusting for nursing home status in
the risk adjustment model.Commenters also requested clarification on whether
“poisoning bynonmedical substances” includes ongoing/chronic alcohol or
drugabuse and not just acute events.
Reliability and validity
testing
- Commenters noted that the testing results demonstratingcorrelations
between hospitalization and re-hospitalization donot enhance confidence in
the measure. The correlations withaccess and urea reduction ratio (URR) are
statisticallysignificant but of very low magnitude, and the correlation
withthe standardized mortality ratio (SMR) also has a low magnitude.Another
commenter noted that the area under the curve for thefor the receiver
operating characteristic (ROC) curve(C-statistic) for the multivariable
model of <0.65 is quitepoor and suggests that the model is
inadequate.
- Commenters requested clarification on the minimum sample sizerequired to
provide a statistically stable value for themeasure. They expressed concern
that many individual dialysisfacilities may be too small with wide
confidence intervals,limiting the statistical validity of the
results.
Intended use in the specific program (QIP) and its
appropriateness
- Commenters expressed concern regarding the appropriateness ofthe
intended use of this measure for the CMS ESRD QualityIncentive Program
(QIP). Commenters argued that the measureshould focus only on admissions
that are actionable for dialysisfacilities, making stratification by primary
diagnosis forreadmission important.
- Endorsement Committee Recommendation: Y-8; N-12.
Consensus Standards Approval Committee (CSAC) Vote: November 21,2014:
Y-9; N-5; A-3
Decision: Approved for endorsement
Board
of Directors Vote: Pending
Appeals
- On January 28, 2015, the 30-day appeals period for theall-cause
admission and readmission measures closed. NQFreceived an appeal submitted
by the Renal Physicians Association(RPA) and co-signed by the American
Nephrology NursesAssociation, American Society of Nephrology, American
Society ofPediatric Nephrology, Dialysis Patient Citizens, and Kidney
CarePartners.
- NQF staff reviewed the appeal and determined that the issuesraised were
based on NQF process issues, rather thanmeasure-specific issues. The
appellant’s main concern was thatthe CSAC did not consider the Committee
evaluation and Membervoting results, which is the basis for their challenge
of theendorsement decision. The appellants note that the CSAC voted
toapprove the measure despite its having reached only 14 percentapproval
among NQF member councils and 40 percent approval bythe Standing
Committee.
- CSAC reviewed the appeal on February 10, 2015, and voted touphold
endorsement (92% approval).
- CSAC members acknowledged the appellant’s concerns aboutmeasure 2496
but remained supportive of its endorsement of themeasure. The CSAC noted
that the process followed in thereview and endorsement of this measure is
consistent with theapproved process for measures on which consensus is
notreached. Endorsement decisions require the CSAC to balanceinput
received from the project Standing Committee, feedbackby the membership
from commenting, voting, and the NQFall-member call. The CSAC considered
these transparent inputsand they were adequately considered in the final
endorsementrecommendation on this measure.
- The BOD Executive Committee reviewed the appeal on March 5,2015, and
requested that NQF bring together the appellant andthe measure developer to
explore opportunities for a shared pathforward. NQF will engage in further
consensus building regardingthis measure and the measure will come back to
the ExecutiveCommittee when those efforts are
complete.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF annual
update
- Workgroup Rationale: MAP conditionally supported this update to the
name of the measure from “reliability adjusted SIR” to “Adjusted Ranking
Metric (ARM),” pending NQF annual update. The continued use of this measure
will promote SSI prevention activities, which will lead to an improvement in
patient outcomes, reducing avoidable medical costs, patient morbidity and
mortality.
- Public comments received: 9
Rationale for measure provided by HHS
Affects large numbers,
Frequently performed procedures, A leading cause of morbidity/mortality, High
resource use, Severity of illness, Patient/societal consequences of poor
quality. SSIs estimated to account for 20% of all HAIs[1] 290,485 estimated
SSIs/yr[2] Estimated 8,205 deaths associated with SSIs each year[1] Estimated
11% of all deaths occurring in intensive care units are associated with SSIs[1]
$34,670 medical cost/SSI[2] Total >$10 billion attributable to SSI in U.S.
each year[2] Estimated additional 7-10 days of hospitalization for each SSI per
patient[1] [1] Klevens RM, Edwards JR, et al. Estimating healthcare-associated
infection and deaths in U.S. hospitals, 2002. Public Health Reports 2007;
122:160-166. [2] Scott, RD. The Direct Medical Costs of Healthcare-Associated
Infections in U.S. Hospitals and the Benefits of Prevention.
http://www.cdc.gov/ncidod/dhqp/pdf/Scott_CostPaper.pdf accessed April 12, 2010.
Measure Specifications
- NQF Number (if applicable): 753
- Description: Organ/space Surgical Site Infections (SSI) at the
primary incision site among adult patients at least 18 years of age undergoing
inpatient colon procedures and/or abdominal hysterectomies as reported through
the ACS-NSQIP or CDC NHSN. The measure yields separate SIRs for each
procedure. (The endorsed specifications of the measure are: Prototype
measure for the facility adjusted Standardized Infection Ratio (SIR) of deep
incisional and organ/space Surgical Site Infections (SSI) at the primary
incision site among adult patients aged >= 18 years as reported through the
ACS National Surgical Quality Improvement Program (ACS-NSQIP) or CDC National
Health and Safety Network (NHSN). Prototype also includes a systematic,
retrospective sampling of operative procedures in healthcare facilities. This
prototype measure is intended for time-limited use and is proposed as a first
step toward a more comprehensive SSI measure or set of SSI measures that
include additional surgical procedure categories and expanded SSI
risk-adjustment by procedure type. This single prototype measure is applied
to two operative procedures, colon surgeries and abdominal hysterectomies, and
the measure yields separate SIRs for each procedure.)
- Numerator: Deep incisional primary (DIP) and organ/space SSIs
during the 30-day postoperative period among patients at least 18 years of age
undergoing inpatient colon surgeries or abdominal hysterectomies. SSIs will be
identified before discharge from the hospital, upon readmission to the same
hospital, or during outpatient care or admission to another hospital
(post-discharge surveillance). Case accrual will be guided by sampling
algorithms as described below.
- Denominator: Using multivariable logistic regression models for
colon surgeries and abdominal hysterectomies, the expected number of SSIs is
obtained. These expected numbers are summed by facility and surgical procedure
and used as the denominator of this measure
- Exclusions: Persons under the age of 18, those having a procedure
performed on an outpatient basis, those with ASA Class VI (6) are
excluded.(The endorsed specifications of the measure are: Persons under the
age of 18, those having a procedure performed on an outpatient basis, those
with ASA Class VI (6) are excluded. In the NHSN, patients without primary
closure of the surgical incision are not considered eligible cases and are
excluded- the NSQIP will match this practice for this measure, although this
is not standard practice within the NSQIP.)
- HHS NQS Priority: Making Care Safer
- HHS Data Source: National Healthcare Safety Network
- Measure Type: Outcome
- Steward: Centers for Disease Control and Prevention
- Endorsement Status: Endorsed; MUC same as endorsed
version:Yes
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2012
- Project for Most Recent Endorsement Review: Patient Safety
Measures
- Review for Importance: The measure addresses a high impact area.
Each year, approximately 11 percent of all deaths in ICUs are associated with
SSIs, resulting in up to 20,000 deaths and $2 billion in additional costs.2
Moreover, evidence-based interventions have shown significant reductions in
SSI rates and improved health outcomes.
- Review for Scientific Acceptability: See CDP
Recommendation]
- Review for Feasibility: See CDP Recommendation]
- Review for Usability: See CDP Recommendation]
- Review for Related and Competing Measures: See CDP
Recommendation]
- Endorsement Committee Recommendation: The Steering Committee
discussed the newly-harmonized measure in a supplemental conference call,
reviewing the relevant changes, while also receiving clarification from the
developers on several issues. Committee members inquired as to why these two
particular measures had been chosen, and asked for clarification on the plan
for public reporting. The developer explained that the CMS IPPS requirements
released on August 1, 2011, call for abdominal hysterectomies and colon
surgeries to be reported by the CDC to CMS. The NHSN will serve as the single
reporting system for CMS-required reporting. However, facilities may choose
which calculations of performance on the measure can be accomplished using
either the NHSN or NSQIP data system. The measure developer acknowledged that
for hospitals participating in both systems, there could be duplication.The
Steering Committee questioned why both organ space and deep incisional
infections were included in the measure. The developer described the approach
as a long standing precedent and stated that superficial infections are
considered trivial events and therefore not included. However, organ space
infections that drain through the incisions are classified as deep incisional
infections. The combination of organ space and deep incisional infections are
considered a clinically coherent grouping. The Committee expressed their
appreciation for the developers’ efforts at harmonization, and agreed that the
measure continues to meet the four major evaluation criteria. The Steering
Committee recommended this measure for endorsement in a unanimous vote.This
outcome measure replaces NQF-endorsed measure #0299 (Surgical Site Infection
Rate) and addresses the National Priority area of
safety.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Support
- Workgroup Rationale: MAP supported this measure because the PSI
measures were developed to identify harmful healthcare related events that are
potentially preventable. Three additional PSIs have been added to this updated
version of the measure. PSIs were better linked to important changes in
clinical status with “harm weights” that are based on diagnoses that were
assigned after the complication. This is intended to allow the measure to more
accurately reflect the impact of the events.
- Public comments received: 11
Rationale for measure provided by HHS
Each measure used within the
PSI 90 composite is an outcome measure that has been shown to be largely
preventable through improved structures and processes of care. Each measure has
an evidence review form as part of the NQF endorsement process. The literature
to support each measure is updated on a schedule basis.
Measure Specifications
- NQF Number (if applicable): 531
- Description: Patient Safety and Adverse Events Composite (Patient
Safety Indicator, or PSI90) is a composite measure of 10 individual PSIs, each
measuring a different aspect of harm associated with patient safety. Each PSI
is reliability-adjusted (smoothed) and indirectly standardized (risk
adjusted). The composite is the weighted average of the reliability-adjusted,
indirectly standardized, observed-to-expected ratios for component indicators.
The final weight for each component is the product of harm weights and volume
weights (numerator weights). Harm weights are calculated by multiplying
empirical estimates of excess harms associated with the patient safety event
by utility weights linked to each of the harms. Excess harms are estimated
using statistical models comparing patients with a safety-related event to
those without that safety-related event in a CMS Medicare fee-for-service
sample that allowed up to one year of follow-up from the discharge date of the
hospital stay associated with the index event. Volume weights, the second part
of the final weight, are calculated on the basis of the number of
safety-related events for the component indicators in the all-payer reference
population. The observed to expected ratios (indirect standardization) of the
reliability adjusted (smoothed) rates are multiplied by a component weight and
the weighted scores are summed to determine the final PSI 90 score. A score of
1 means that the hospital performs as expected, scores greater than one
indicate worse performance than expected.
- Numerator: Below we list the numerator values for the composite
components. The composite score is calculated as a ratio of the weighted
observed to expected ratios for each of the components. PSI03-Pressure Ulcer
Rate- Discharges, among cases meeting the inclusion and exclusion rules for
the denominator, with any secondary ICD-9-CM diagnosis codes for pressure
ulcer and any secondary ICD-9-CM diagnosis codes for pressure ulcer stage III
or IV (or unstageable). PSI06-Iatrogenic Pneumothorax Rate- Discharges,
among cases meeting the inclusion and exclusion rules for the denominator,
with any secondary ICD-9-CM diagnosis codes for iatrogenic pneumothorax.
PSI08-Postoperative Hip Fracture Rate- Discharges, among cases meeting the
inclusion and exclusion rules for the denominator, with any secondary ICD-9-CM
diagnosis codes for hip fracture. PSI09-Perioperative Hemorrhage and
Hematoma Rate- Discharges, among cases meeting the inclusion and exclusion
rules for the denominator, with either: • any secondary ICD-9-CM diagnosis
codes for perioperative hemorrhage or hematoma and any-listed ICD-9-CM
procedure codes for control of perioperative hemorrhage or evacuation of
hematoma. PSI10-Postoperative Acute Kidney Injury Rate- Discharges, among
cases meeting the inclusion and exclusion rules for the denominator, with
either: • any secondary ICD-9-CM diagnosis codes for acute renal failure and
any-listed ICD-9- CM procedure codes for dialysis. PSI11-Postoperative
Respiratory Failure Rate- Discharges, among cases meeting the inclusion and
exclusion rules for the denominator, with either: • any secondary ICD-9-CM
diagnosis code for acute respiratory failure; or • any-listed ICD-9-CM
procedure codes for a mechanical ventilation for 96 consecutive hours or more
that occurs zero or more days after the first major operating room procedure
code (based on days from admission to procedure); or • any-listed ICD-9-CM
procedure codes for a mechanical ventilation for less than 96 consecutive
hours (or undetermined) that occurs two or more days after the first major
operating room procedure code (based on days from admission to procedure); or
• any-listed ICD-9-CM procedure codes for a reintubation that occurs one or
more days after the first major operating room procedure code (based on days
from admission to procedure). PSI12-Perioperative Pulmonary Embolism and
Deep Vein Thrombosis Rate- Discharges, among cases meeting the inclusion and
exclusion rules for the denominator, with a secondary ICD-9-CM diagnosis code
for deep vein thrombosis or a secondary ICD-9-CM diagnosis code for pulmonary
embolism (omitting cases from the numerator with isolated calf vein DVT).
PSI13-Postoperative Sepsis Rate- Discharges, among cases meeting the inclusion
and exclusion rules for the denominator, with any secondary ICD-9-CM diagnosis
codes for sepsis. PSI14-Postoperative Wound Dehiscence Rate-Discharges,
among cases meeting the inclusion and exclusion rules for the denominator,
with any-listed ICD-9-CM procedure codes for reclosure of postoperative
disruption of the abdominal wall. PSI15-Unrecognized Abdominopelvic
Accidental Puncture or Laceration Rate -Discharges, among cases meeting the
inclusion and exclusion rules for the denominator, with any secondary ICD-9-CM
diagnosis codes for accidental puncture or laceration during a procedure and
second abdominopelvic operation 1 day or more after the index
procedure.
- Denominator: Below we list the denominator values for the composite
components. The composite score is calculated as a ratio of the weighted
observed to expected ratios for each of the components. PSI03-Pressure Ulcer
Rate- Surgical and medical discharges, for patients ages 18 years and older.
Surgical and medical discharges are defined by specific DRG or MS-DRG codes.
PSI06-Iatrogenic Pneumothorax Rate- Surgical and medical discharges, for
patients ages 18 years and older. Surgical and medical discharges are defined
by specific DRG or MS-DRG codes. PSI08-Postoperative Hip Fracture Rate-
Surgical discharges, ages 18 years and older, with any-listed ICD-9-CM
procedure codes for an operating room procedure. Surgical discharges are
defined by specific DRG or MS-DRG codes. PSI09-Perioperative Hemorrhage and
Hematoma Rate- Surgical discharges, for patients ages 18 years and older,
with any-listed ICD-9-CM procedure codes for an operating room procedure.
Surgical discharges are defined by specific DRG or MS-DRG codes.
PSI10-Postoperative Acute Kidney Injury Rate- Elective surgical discharges,
for patients ages 18 years and older, with any-listed ICD-9-CM procedure codes
for an operating room procedure. Elective surgical discharges are defined by
specific DRG or MS-DRG codes with admission type recorded as elective (SID
ATYPE=3). PSI11-Postoperative Respiratory Failure Rate- Elective surgical
discharges, for patients ages 18 years and older, with any-listed ICD-9-CM
procedure codes for an operating room procedure. Elective surgical discharges
are defined by specific DRG or MS-DRG codes with admission type recorded as
elective (SID ATYPE=3). PSI12-Perioperative Pulmonary Embolism and Deep Vein
Thrombosis Rate- Surgical discharges, for patients ages 18 years and older,
with any-listed ICD-9-CM procedure codes for an operating room procedure.
Surgical discharges are defined by specific DRG or MS-DRG codes.
PSI13-Postoperative Sepsis Rate- Elective surgical discharges, for patients
ages 18 years and older, with any-listed ICD-9-CM procedure codes for an
operating room procedure. Elective surgical discharges are defined by specific
DRG or MS-DRG codes with admission type recorded as elective (SID ATYPE=3).
PSI14-Postoperative Wound Dehiscence Rate- Discharges, for patients ages 18
years and older, with any-listed ICD-9-CM procedure codes for abdominopelvic
surgery. PSI15-Unrecognized Abdominopelvic Accidental Puncture or Laceration
Rate- Patients ages 18 years and older with any procedure code for an
abdominopelvic procedure.
- Exclusions: Below we list the exclusions for the composite
components. There are no additional exclusions for the composite measure as a
whole. PSI03 – Pressure Ulcer Rate-Excludes cases with length of stay less
than 5 days, with a principal diagnosis of pressure ulcer or secondary
diagnosis of pressure ulcer present on admission, cases with evidence of
hemiplegia, paraplegia or quadriplegia, spina bifida, anoxic brain damage,
debridement or pedicle graft on the same day as the major operating room
surgery or as the only major operating room procedure, and cases that were
transferred from a different hospital or skilled nursing facility, and cases
with MDC (major diagnostic classification) of 9 (skin, subcutaneous and
breast) or 14 (pregnancy, childbirth and puerperium). PSI06 – Iatrogenic
Pneumothorax Rate - Excludes cases with a principal diagnosis for iatrogenic
pneumothorax or secondary diagnosis of iatrogenic pneumothorax on admission,
cases with evidence of chest trauma, pleural effusion, thoracic surgery, lung
or pleural biopsy, diaphragmatic repair, cardiac procedure, and cases with MDC
(major diagnostic classification) of 14 (pregnancy, childbirth and
puerperium). PSI08 – Postoperative Hip Fracture Rate-Excludes cases with
principal diagnosis of hip fracture or a secondary diagnosis of hip fracture
on admission, cases where the only operating room procedure is hip fracture,
where the procedure for hip fracture occurs before or on the same day as the
first operating room procedure, and cases with a principal diagnosis of
seizure, syncope, stroke and occlusion of arteries, coma, cardiac arrest,
poisoning, trauma, delirium and other psychoses, anoxic brain injury,
metastatic cancer, lymphoid malignancy, bone malignancy, self-inflicted
injury, and cases with MDC (major diagnostic classification) of 8
(musculoskeletal system and connective tissue) or 14 (pregnancy, childbirth
and puerperium). PSI09 – Perioperative Hemorrhage and Hematoma Rate -
Excludes cases with principal diagnosis of perioperative hemorrhage or
postoperative hematoma or secondary diagnosis present of perioperative
hemorrhage on admission, cases where the only operating room procedure is
control of postoperative hemorrhage, drainage of hematoma or miscellaneous
hemorrhage- or hematoma-related procedure, any secondary diagnosis of
perioperative hemorrhage or postoperative hematoma and any-listed procedure
codes for control of perioperative hemorrhage or evacuation of hematoma or
miscellaneous hemorrhage- or hematoma- related procedure occurring before the
first operating room procedure, cases with diagnosis of coagulation disorder
and cases with MDC (major diagnostic classification) of 14 (pregnancy,
childbirth and puerperium). PSI10 – Postoperative Acute Kidney
Injury-Excludes cases with a principal diagnosis or secondary diagnosis on
admission of acute renal failure, acute myocardial infarction, cardiac
arrhythmia, cardiac arrest, shock, hemorrhage, gastrointestinal hemorrhage, or
chronic renal failure, cases with dialysis procedure before on the same day as
the first operating procedure and cases with MDC (major diagnostic
classification) of 14 (pregnancy, childbirth and puerperium). PSI11 –
Postoperative Respiratory Failure Rate - Excludes cases with principal
diagnosis or secondary diagnosis on admission of acute respiratory failure,
cases where the only operating procedure is tracheostomy or a tracheostomy
occurs before the first operating procedure, cases with any listed diagnosis
of neuromuscular disorder, craniofacial anomalies or degenerative neurological
disorder, cases with any listed procedure of laryngeal or pharyngeal, nose,
mouth, or pharynx surgery, procedures involving the face, esophageal
resection, procedures for lung cancer, and cases with MDC (major diagnostic
classification) of 4 (disease of respiratory system), 5 (diseases of the
circulatory system), or 14 (pregnancy, childbirth and puerperium). PSI12 –
Perioperative Pulmonary Embolism and Deep Vein Thrombosis Rate - Excludes
cases with principal diagnosis or secondary diagnosis on admission of DVT,
pulmonary embolism, cases where a procedure for interruption of vena cava
occurs before or on the same day as the first operating room procedure, cases
with any procedure for extracorporeal membrane oxygenation, and cases with MDC
(major diagnostic classification) of 14 (pregnancy, childbirth and
puerperium). PSI13 – Postoperative Sepsis Rate – Excludes cases with
principal diagnosis or secondary diagnosis on admission of sepsis, infection,
cases with evidence of immunocompromised state or cancer, cases with a length
of stay less than 4 days, and cases with MDC (major diagnostic classification)
of 14 (pregnancy, childbirth and puerperium). PSI14 – Postoperative Wound
Dehiscence Rate – Excludes cases with any listed evidence of immunocompromised
state, cases where the procedure for abdominal wall reclosure occurs on or
before the day of the first abdominopelvic surgery procedure, cases with a
length of stay less than 2 days, and cases with MDC(major diagnostic
classification) of 14 (pregnancy, childbirth and puerperium). PSI15 –
Unrecognized Abdominopelvic Accidental Puncture or Laceration Rate-Excludes
cases with a principal diagnosis or secondary diagnosis at admission of
accidental puncture or laceration during a procedure and cases with MDC (major
diagnostic classification) of 14 (pregnancy, childbirth and
puerperium).
- HHS NQS Priority: Making Care Safer
- HHS Data Source: Administrative claims Component measures require:
ICD-9 diagnosis and procedure codes, MDC, MSDRG, procedure day, age in year,
gender, admission type, discharge disposition. All are drawn from
administrative data.
- Measure Type: Composite
- Steward: Agency for Healthcare Research & Quality
- Endorsement Status: Endorsed; MUC same as endorsed
version:Yes
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Patient Safety
2015
- Review for Importance: The measure meets the Importance criteria
(1a. Evidence, 1b. Performance Gap) 1a. Evidence: 16-Y; 8-N I; 1b. Performance
Gap: 9-H; 9-M; 6-L; 0-I; 1c. Composite- Quality Construct and Rationale: 6-H;
7-M; 11-L; 0-I Rationale: · The Committee agreed that the outcomes in this
measure were associated with one or more healthcare actions. However, there
was concern that some of the elements of the composite had variable
preventability. · The developers reported that the items within the composite
are positively correlated. The correlations range in the low 0.08 up to the
30s (not very high). · The developers referenced several processes of care
that are associated with lower rates for each of the components in the
composite.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria (2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity) 2a. Reliability: 4-H;
10-M; 9-L; 1-I 2b. Validity: 2-H; 11-M; 7-L; 2-I 1c. Composite Construction:
4-H; 12-M; 7-L; 1-I Rationale: · The Committee agreed that the updated version
of the measure provided by AHRQ was improved from the 2014 version reviewed by
the Committee, specifically noting that the new weighting focusing on harm
rather than just the frequency of events, was more clinically relevant than
the previous version of the measure. · During reliability testing, the
developers examined the true difference rather than random chance and noise.
Their results show a reliability scores in the 70s, which is comparable to
other endorsed measures · Aggregating a number of individual measures into a
single composite can generate an overall performance score that is more
reliable than if the individual measure scores were taken in isolation. ·
Empirical field validity testing was conducted at the performance measure
score level for the overall composite by correlating the composite scores with
the rates calculated from the 3M Potentially Preventable Readmissions measure.
.The Pearson correlation value, was 0.11 with a p-value of
<0.0001.
- Review for Feasibility: 12-H; 8-M; 3-L; 1-I (3a. Clinical data
generated during care delivery; 3b. Electronic sources; 3c.Susceptibility to
inaccuracies/ unintended consequences identified 3d. Data collection strategy
can be implemented) Rationale: · The Committee had no concerns about the
feasibility of this measure given that it is gathered with administrative
claims data.
- Review for Usability: 12-H; 6-M; 6-L; 0-I (Meaningful,
understandable, and useful to the intended audiences for 4a. Public
Reporting/Accountability and 4b. Quality Improvement) Rationale: · There were
concerns about the use of this measure in value-based purchasing, despite the
improvements the developer has made, because may not accurately reflect that
an actual preventable complication occurred or may focus on preventing
measured events that are less clinically important. · This measure is used to
monitor performance in national and regional reporting. It was also developed
to enable comparative reporting and quality improvement at the provider or the
hospital level.
- Review for Related and Competing Measures: Concerns were raised by
the Committee that some of the elements of this measure, notably the central
line related blood stream infections and post-operative hip fracture, may be
better captured in other NQF approved measures rather than using
administrative claims data. In addition, this measure is related to NQF 532,
which is the pediatric version of the same measure 0347.
- Endorsement Public Comments: Summary pending
- Endorsement Committee Recommendation: 14-Y; 10-N
Since 58% of the Committee voted to recommend this measure, it did not
achieve consensus. It will move forward to the comment period and the
Committee will discuss and revote after the public comment.
This measure was last endorsed in 2009; it is a composite measure of 11
inpatient Patient Safety Indicators. In 2014 the Committee raised concerns
about the weighting of the various components of the composite, specificially
that some of the more heavily weighted components were less clinically
significant (i.e., accidental punctures and lacerations) and/or less
preventable. In addition, there were concerns that the events measured are not
always reflective of an actual patient safety event that resulted in
preventable patient harm. To address the concerns of the 2014 Committee, AHRQ
made several updates to the measure to address the Committee’s concerns.
- Additional PSIs were included (from 8 events to 11 events, which
expanded the type of complications included this measure),
- Two of the component PSIs were redesigned; specifically PSI 12 with the
removal of isolated calf deep vein thromboses (DVT) which have limited
clinical relevance and PSI 15 with a greater focus on accidental punctures
and lacerations that occur during abdominal/pelvic surgery and those that
result in re-operation within one day which reflect events that are more
likely preventable, and
- The measure was modified to more accurately reflect the impact of the
events by better linking the PSIs to important changes in clinical status
with “harm weights” that are based on diagnoses that were assigned after the
complication.
The Committee agreed that the changes to the measure were highly responsive
to the concerns raised during the 2014 Committee discussion. However, new
concerns were raised: some post-operative DVT or other events included in the
composite may not be preventable; the definition of ICD-9 based central line
related blood stream infections may be less precise than other definitions
(i.e., NHSN which reports the information differently); and concerns about
this measure being included in value-based purchasing programs particularly
when it is likely that not all of these events are preventable and that it may
distract from efforts to reduce more impactful safety events. In addition,
there were concerns that some of the indicators of the measure may not reflect
preventable patient safety events because it comes from ICD-9 data of
inpatient complications, which sometimes did not directly reflect that an
actual preventable complication occurred in the validation of the components
of the composite. During the vote, the Committee agreed that the measure meets
the four NQF criteria; however, consensus was not reached on a recommendation
for endorsement (58% yes, 42% no). The Committee will re-consider the
recommendation for endorsement after reviewing the public
comments.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP noted that available discharge codes and
coding practices could cause confusion about the results of this measure and
could also introduce validity concerns. MAP asked for greater clarity about
the intent of these measures, especially how they may impact patients and
consumers. MAP members raised concerns about the multiple ways that
readmissions are being measured and noted that a provider could potentially be
penalized multiple times for the same occurrence. MAP noted the need for
excluding patients who are admitted to hospice to prevent discouraging
discharges to hospice. MAP also noted that discharge to community can reflect
access to social support and the measure may need to reflect this. MAP
indicated the need for these measures to be submitted for NQF review and
endorsement to address psychometric concerns about the measures.MAP members
noted concerns about the risk adjustment of these measures, particularly for
the home health setting. MAP specifically noted the need to appropriately risk
adjust the measures to avoid unintended consequences.
- Public comments received: 14
Rationale for measure provided by HHS
The ultimate goals of
post-acute care are avoiding institutionalization and returning patients to
their previous level of independence and functioning, with discharge to
community being the primary goal for the majority of post-acute patients. For
many, home is a symbol of independence, privacy, and competence. Discharge to
community is considered a valuable outcome to measure because it is a
multifaceted measure that captures the patient’s functional status, cognitive
capacity, physical ability, and availability of social support at home. There
is considerable variation in discharge to community rates within and across
post-acute settings. Studies show geographic variation, variation across patient
socioeconomic characteristics (for example, race and ethnicity), and variation
by facility characteristics (for profit vs. nonprofit, freestanding vs.
hospital-based, urban vs. rural). In the IRF setting, discharge to community
rates vary across providers, ranging from about 60% to 75%. The 2015 MedPAC
report shows that, in FY 2013, the facility-level, mean risk-adjusted discharge
to community rate for IRFs within 100 days of admission was 75.8%, and the mean
observed rate was 74.7%. Discharge to community rates also vary widely in the
SNF setting, ranging from as low as 31% to as high as 65%. The 2015 MedPAC
report shows a mean risk-adjusted discharge to community rate of 37.5% for SNFs
within 100 days of admission, and mean observed rate of 40.1%. A multicenter
study of 23 LTCHs reported that only 28.8% of 1,061 patients who were
ventilator-dependent on admission were discharged to home or assisted living
facility. A study of 66,510 Medicare beneficiaries during pre- and post-HH
episodes, revealed that 64 percent of beneficiaries discharged from HH did not
use any other Medicare-reimbursed acute or post-acute services in the 30 days
following HH discharge. Significant numbers of patients were admitted to
inpatient facilities (29 percent) and lesser numbers to skilled nursing
facilities (7.6 percent), inpatient rehabilitation (1.5 percent) and home health
(7.2 percent) or hospice (3.3 percent) within 30 days of HH discharge (Wolff et
al., 2008).
Measure Specifications
- NQF Number (if applicable):
- Description: This measure describes the risk-standardized rate of
Medicare fee-for-service (FFS) patients/residents/persons who are discharged
to the community, and do not have an unplanned (re)admission to an acute care
hospital or LTCH in the 31 days following discharge to community, and remain
alive during the 31 days following discharge to community.
- Numerator: This measure does not have a simple form for the
numerator and denominator. The numerator is defined as the risk-adjusted
estimate of the number of patients/residents/persons included in the measure
who are discharged to the community, and do not have an unplanned
(re)admission to an acute care hospital or LTCH on the day of discharge or in
the 31 days following discharge to community, and remain alive during the 31
days following discharge to community. The numerator estimate includes risk
adjustment for patient/resident/person characteristics, and a statistical
estimate of the facility/agency effect beyond case mix.
- Denominator: The denominator is computed with the same model used
for the numerator. It is the model developed using all non-excluded
facility/agency stays/episodes in the national data. The measure includes all
facility/agency stays/episodes in the measurement period that are observed in
national Medicare FFS data and do not fall into an excluded category. For a
particular facility/agency, the model is applied to the
patient/resident/person population, but the facility/agency effect term is 0.
In essence, it is the number of discharges to community that would be expected
for that patient/resident/person population at the average
facility/agency.
- Exclusions: i) Age under 18 years; (ii) Discharges to psychiatric
hospital; (iii) Discharges against medical advice; (iv) Discharges to federal
hospitals or disaster alternative care sites; (v) Patients not continuously
enrolled in Part A FFS Medicare for the 12 months prior to the HHA admission
date, and at least 31 days after HHA discharge date; (vi) Patients whose prior
short-term acute-care stay was for non-surgical treatment of cancer (only
applies to those patients whose HHA episode was preceded by an acute care
discharge in the past 30 days); (vii) Discharges to hospice; (viii) HHA
episodes stays that end in transfer to another HHA; (ix) HHA episodes with a
missing risk adjustment authorization code.
- HHS NQS Priority: i) Age under 18 years; (ii) Discharges to
psychiatric hospital; (iii) Discharges against medical advice; (iv) Discharges
to federal hospitals or disaster alternative care sites; (v) Patients not
continuously enrolled in Part A FFS Medicare for the 12 months prior to the
HHA admission date, and at least 31 days after HHA discharge date; (vi)
Patients whose prior short-term acute-care stay was for non-surgical treatment
of cancer (only applies to those patients whose HHA episode was preceded by an
acute care discharge in the past 30 days); (vii) Discharges to hospice; (viii)
HHA episodes stays that end in transfer to another HHA; (ix) HHA episodes with
a missing risk adjustment authorization code.
- HHS Data Source: Claims
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP noted the importance of medication
reconciliation but raised concerns and asked for greater clarity about the
definition of reconciliation versus drug regimen review. Members also noted
the challenge of defining some of the measure components, specifically “a
clinically significant issue” given the large number of medications a patient
may be taking. MAP stressed that medication reconciliation is a step in a drug
regimen review and asked for greater clarity on defining the drug regimen
review process. MAP stressed the importance of conducting a complete
medication review from all sites of care, including the home. MAP members
noted the value of the role of family caregivers in providing this information
and the hope that technology can help to minimize the burden of getting this
information. MAP members asked for greater emphasis of the inclusion of
non-prescription medication (including supplements), noting that this is a
particular concern in the PAC/LTC population.MAP members raised some concerns
about the feasibility of this measure and noted the need to clarify the roles
of the interdisciplinary team. MAP noted the importance of attribution issues
for this measure. Additionally, Workgroup members raised concerns about the
challenges of competing guidelines and need for greater clarity about when a
medication can be withdrawn. MAP stressed that medication reconciliation needs
to be an on-going process. MAP also noted that this is a particular concern
for dual-eligible beneficiaries.
- Public comments received: 11
Rationale for measure provided by HHS
Medication review in
post-acute care is generally considered to include medication reconciliation for
all medications and medication review for what poses as potential clinically
significant medication issues for the patient/resident. As a process measure,
medication reconciliation and medication review for potential clinically
significant medication issues are expected to reduce re-hospitalizations, reduce
adverse events related to medications and improve health outcomes.
(New information provided by CMS on January 19, 2016) Medication
review in post-acute care is generally considered to include medication
reconciliation and drug regimen review for all medications and for what poses as
potential clinically significant medication issues for the patient/resident. As
a process measure, medication reconciliation and drug regimen review for
potential clinically significant medication issues are expected to reduce
re-hospitalizations, reduce adverse events related to medications and improve
health outcomes.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of stays Inpatient Rehabilitation Facility
(IRF), Long Term Care Facility (LTCH), and Skilled Nursing Facility (SNF) or
care episodes Home Health (HH) in which a drug regimen review was conducted at
the Admission (IRF, LTCH or SNF)/ Start of Care (SOC)/ Resumption of Care
(ROC) (HH) and timely follow-up with a physician occurred each time potential
clinically significant medication issues were identified throughout the stay
(IRF, LTCH, or SNF) or care episode (HH).
- Numerator: Number of stays or care episodes where the medical
record contains documentation of a drug regimen review conducted at admission
or start-of-care or resumption-of-care with all potential clinically
significant medication issues identified during the course of care and
followed-up with a physician or physician designee.
- Denominator: Care episodes or stays ending during the reporting
period. Assessment timing is as follows: Beginning of care
episode or stay: • HH – SOC or ROC • SNF – Admission • IRF - Admission • LTCH
– Admission End of care episode or stay: • HH – Transfer, Discharge, or
Death at Home • SNF – Discharge, or expired • IRF – Discharge, or expired •
LTCH – Discharge, or expired
- Exclusions: Denominator Exclusion: NONE Numerator Exclusion: NONE
- HHS NQS Priority: Denominator Exclusion: NONE Numerator Exclusion:
NONE
- HHS Data Source: Patient Assessment Data
- Measure Type: Process
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP noted that this composite measure
addresses falls risk and related clinical intervention assessments, which are
considered safety measures and meet the goals of the Home Health
QRP.
- Public comments received: 12
Rationale for measure provided by HHS
See literature review for
NQF #0537 about the importance of assessing falls among home health patients and
developing interventions.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients who were assessed for falls
risk and whose care plan reflects the assessment and was implemented as
appropriate.
- Numerator: Number of patients who were assessed for falls risk and
whose risk was incorporated in the care plan based on assessment results and
whose care plan was implemented (must meet all 3 conditions)
- Denominator: Number of home health episodes of care ending with a
discharge during the reporting period, other than those covered by generic or
measure-specific exclusions.
- Exclusions: Episodes of care ending with a transfer to an inpatient
setting or death are excluded from the denominator. HHA's with denominator
counts of less than 20 in the sample will be excluded from public reporting
owing to small sample size.
- HHS NQS Priority: Episodes of care ending with a transfer to an
inpatient setting or death are excluded from the denominator. HHA's with
denominator counts of less than 20 in the sample will be excluded from public
reporting owing to small sample size.
- HHS Data Source: OASIS-C1
- Measure Type: Composite
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not encourage further
consideration
- Workgroup Rationale: This measure is a modification of NQF #0179
based on feedback from the NQF Pulmonary and Critical Steering Committee. MAP
disagreed with the denominator approach of focusing on specific populations
(contrary to the Steering Committee recommendation and encouraged a return to
a broader population approach. MAP noted that dyspnea is an important quality
of life issue to patients across PAC settings and should be a focus of
improvement for all suffering from the condition. The workgroup questioned if
hospice patients should be excluded. The group noted that dyspnea is an
important quality issue for that population but noted improvement might not be
possible for some patients near the end of life.
- Public comments received: 10
Rationale for measure provided by HHS
See literature for NQF
measure #0179 about the importance of dyspnea and the potential for home health
to affect outcomes.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of home health episodes of care during
which a patient with a primary diagnosis of CHF, asthma and/or COPD became
less short of breath or dyspneic.
- Numerator: Number of home health episodes of care where a patient
with a primary diagnosis of CHF and/or COPD has less dyspnea at discharge than
at start (or resumption) of care.
- Denominator: Number of home health episodes of care ending with a
primary diagnosis of CHF and/or COPD with a discharge during the reporting
period, other than those covered by generic or measure-specific
exclusions.
- Exclusions: Episodes of care ending with a transfer to an inpatient
setting or death are excluded from the denominator. HHA's with denominator
counts of less than 20 in the sample will be excluded from public reporting
owing to small sample size.
- HHS NQS Priority: Episodes of care ending with a transfer to an
inpatient setting or death are excluded from the denominator. HHA's with
denominator counts of less than 20 in the sample will be excluded from public
reporting owing to small sample size.
- HHS Data Source: OASIS-C1
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Members noted the importance of balancing cost
measures with quality and access. Although the MAP encouraged continued
development, they did note concerns about the potential for unintended
consequences. In particular, the group raised concerns about issues of
premature discharges. The group noted this could put a tremendous burden on
family caregivers who may have to care for a patient they are not fully able
to support. Members also noted the need to consider risk adjustment for
severity and socioeconomic status.
- Public comments received: 10
Rationale for measure provided by HHS
Medicare payments to PAC
have grown at a consistently higher rate than other major Medicare sectors.
Between 2001 and 2013, Medicare PAC spending grew at an annual rate of 6.1
percent and doubled to $59.4 billion.
Measure Specifications
- NQF Number (if applicable):
- Description: The MSPB-PAC Measure for HHAs evaluates providers’
efficiency relative to the efficiency of the national median HHA provider.
Specifically, the MSPB-PAC Measure assesses the cost to Medicare for services
during an episode of care, which consists of a treatment period and an
associated services period. The episode is triggered by the initiation of a 60
day HHA service period. The treatment period begins at the trigger and ends on
the last day of the service period. The associated services period begins at
the trigger and ends 30 days after the end of the treatment period. These
periods constitute the episode window during which beneficiaries’ Medicare
services are counted toward the episode. The MSPB-PAC episode includes all
services during the episode window that are attributable to the HHA provider
and those rendered by other providers, except those services during the
associated services period that are clinically unrelated to HHA
responsibilities (e.g., planned care and routine screening).
- Numerator: The numerator is the attributed provider’s average
MSPB-PAC Amount. The MSPB-PAC Amount for each HHA provider depends on two
factors: i) the average of the ratio of standardized episode spending level
and expected episode spending for each HHA provider; and ii) the average
standardized episode spending across all HHA providers. To calculate the
MSPB-PAC Amount for each HHA, one finds the average of the ratio of the
standardized episode spending over the expected episode spending, and then
multiplies this quantity by the average episode spending level across all
HHAs.
- Denominator: The denominator for a HHA’s MSPB-PAC Measure is the
weighted median MSPB-PAC Amount across all episodes for HHAs
nationally.
- Exclusions: The measure excludes the following episodes: • Any
episode that is triggered by HHA Request for Anticipated Payment (RAP) claims.
• Any episode that is triggered by an HHA claim that happens outside the 50
states or DC. • Any episode that is triggered by an HHA claim for which we see
Part C crossover claims. • Any episode for which standard allowed amount of
the HHA claim could not be calculated or is equal to 0. • Any episode in which
a beneficiary is not enrolled in Medicare Fee-for-Service for the entirety of
the lookback period plus the episode window or is enrolled in Part C for any
part of the lookback plus episode window. • Any episode in which a beneficiary
has a primary payer other than Medicare for any part of the lookback plus
episode window. • Any episode for which the lookback period extends beyond our
observation period.
- HHS NQS Priority: The measure excludes the following episodes: •
Any episode that is triggered by HHA Request for Anticipated Payment (RAP)
claims. • Any episode that is triggered by an HHA claim that happens outside
the 50 states or DC. • Any episode that is triggered by an HHA claim for which
we see Part C crossover claims. • Any episode for which standard allowed
amount of the HHA claim could not be calculated or is equal to 0. • Any
episode in which a beneficiary is not enrolled in Medicare Fee-for-Service for
the entirety of the lookback period plus the episode window or is enrolled in
Part C for any part of the lookback plus episode window. • Any episode in
which a beneficiary has a primary payer other than Medicare for any part of
the lookback plus episode window. • Any episode for which the lookback period
extends beyond our observation period.
- HHS Data Source: Claims
- Measure Type: Cost/Resource Use
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Concerns were raised about potential
unintended consequences of these measures and noted the need for appropriate
risk adjustment. Members noted that facilities may decline complex patients if
these measures are not appropriately adjusted. MAP also raised concerns about
potential overlap between readmission measures and this may introduce multiple
penalties for the same readmission episode due to multiple measures. MAP
members asked for greater clarity about the definition of a potentially
preventable readmission. MAP also noted that patients seldom have only one
diagnosis and raised concerns about the challenges of separating out numerator
and denominators related to each diagnosis. MAP members raised particular
concerns about this measure for the home health setting, especially as the
patient may not be under the care of the home health agency immediately
post-discharge.
- Public comments received: 15
Rationale for measure provided by HHS
This is the environmental
scan conducted that demonstrates potentially preventable readmissions is a
concern for community dwelling individuals and that home health interventions
can reduce the risk of readmission.
Measure Specifications
- NQF Number (if applicable):
- Description: All-condition risk-adjusted potentially preventable
hospital readmission rates.
- Numerator: This measure does not have a simple form for the
numerator and denominator. The numerator is defined as the risk-adjusted
estimate of the number of unplanned, potentially preventable readmissions that
occurred within 30 days from discharge from the prior proximal acute
hospitalization. The numerator, as defined, includes risk adjustment for
patient characteristics and a statistical estimate of the facility effect
beyond patient mix.
- Denominator: The denominator is computed with the same model used
for the numerator. It is the model developed using all non-excluded episodes
in the national data. The measure includes all episodes in the measurement
period that are observed in national Medicare FFS data and do not fall into an
excluded category. For a particular agency, the model is applied to the
patient population, but the agency effect term is 0. In essence, it is the
number of unplanned potentially preventable readmissions that would be
expected for that patient population at the average agency.
(New
information provided by CMS on January 19, 2016) The denominator is
computed with the same model used for the numerator. It is the model developed
using all non-excluded HH stays in the national data.
- Exclusions: i) Patients who are under 18 years old; (ii) Patients
not continuously enrolled in Part A FFS Medicare for the 12 months prior to
the HH episode admission date, and at least 30 days after discharge date;
(iii) Patients who died during the HH episode; (iv) Patients with a missing
risk adjustment authorization code; (v) Patients who leave HH against medical
advice; (vi) Patients transfer at the end of a stay to another setting; (vii)
Patients who did not have a short-term acute care stay within 30 days prior to
the HH episode admission date; (viii) Patient who had the following principal
diagnoses in the prior proximal hospitalization: medical (nonsurgical)
treatment of cancer; primary psychiatric diseases; rehabilitation care/fitting
of prostheses and for the adjustment of devices.
- HHS NQS Priority: i) Patients who are under 18 years old; (ii)
Patients not continuously enrolled in Part A FFS Medicare for the 12 months
prior to the HH episode admission date, and at least 30 days after discharge
date; (iii) Patients who died during the HH episode; (iv) Patients with a
missing risk adjustment authorization code; (v) Patients who leave HH against
medical advice; (vi) Patients transfer at the end of a stay to another
setting; (vii) Patients who did not have a short-term acute care stay within
30 days prior to the HH episode admission date; (viii) Patient who had the
following principal diagnoses in the prior proximal hospitalization: medical
(nonsurgical) treatment of cancer; primary psychiatric diseases;
rehabilitation care/fitting of prostheses and for the adjustment of
devices.
- HHS Data Source: Administrative claims
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP encouraged further development of this
measure at the city and/or county level because the group recognized the
importance of a community-based approach to decrease smoking. This type of
county-based measure indicates the need for hospital collaboration with the
surrounding community to work together to provide tobacco
cessation.
- Public comments received: 11
Rationale for measure provided by HHS
Tobacco use and exposure to
secondhand smoke caused more than 400,000 in the U.S. in each year between 2000
and 2004, according to the CDC. These deaths represent more than 5 million years
of potential life lost (YPLL).1 At the state level, the median annual number of
lives lost per state was 5,534, though there was a great deal of variation by
state.2 National Cost of Tobacco Use The Centers for Disease Control and
Prevention (CDC) estimates that, in the U.S. in each year from 2001 through
2004, an average of $96 billion was spent on health care due to smoking.1 A 2007
study calculates the cost of smoking to the U.S. Medicaid system, concluding
that the projected lifetime costs of smoking to Medicaid, for a single
cohort—current 24-year-old smokers—is nearly $1 billion. 1. Centers for Disease
Control and Prevention (CDC). Smoking attributable mortality, years of potential
life lost, and productivity losses--United States, 2000-2004. MMWR Morb Mortal
Wkly Rep. 2008 Nov 14;57(45):1226-8. 2. Centers for Disease Control and
Prevention (CDC). State-specific smoking-attributable mortality and years of
potential life lost--United States, 2000-2004. MMWR Morb Mortal Wkly Rep. 2009
Jan 23;58(2):29-33. Erratum in: MMWR Morb Mortal Wkly Rep. 2009 Feb 6;58(4):91.
3. Trogdon J, Pais J. Saving Lives, Saving Money II: Tobacco-Free States Spend
Less on Medicaid. A Policy Report of the American Legacy Foundation. 2007. 4.
Centers for Disease Control and
Measure Specifications
- NQF Number (if applicable): 2020
- Description: Percentage of adult (age 18 and older) U.S. population
that currently smoke, defined as adults who reported having smoked at least
100 cigarettes in their lifetime and currently smoke. (The endorsed
specifications of the measure are: Percentage of adult (age 18 and older) U.S.
population that currently smoke.)
- Numerator: The numerator is current adult smokers (age 18 and
older) in a geographically defined area who live in households. (The
endorsed specifications of the measure are: The numerator is current adult
smokers (age 18 and older) in the U.S. who live in
households.)
- Denominator: The adult (age 18 and older) population in a
geographically defined area who live in households. One adult per household
is interviewed.(The endorsed specifications of the measure are: The adult
(age 18 and older) population of the U.S. who live in households. One adult
per household is interviewed.)
- Exclusions: Adults 18 years or older are asked to take part in the
survey and only one adult is interviewed per household. Adults living in
vacation homes not occupied by household members for more than 30 days per
year, group homes, institutions, prisons, hospitals and college dorms are
excluded.(The endorsed specifications of the measure are: Adults 18 years
or older are asked to take part in the survey and only one adult is
interviewed per household. Adults living in vacation homes not occupied by
household members for more than 30 days per year, group homes, institutions,
prisons, hospitals and college dorms are excluded. Military services members
and adults who speak a language other than English and Spanish are also
excluded.)
- HHS NQS Priority: Effective Prevention and Treatment, Best Practice
of Healthy Living
- HHS Data Source: BRFSS. Please see:
http://www.cdc.gov/brfss/technical_infodata/surveydata/2011.htm
- Measure Type: Structure
- Steward: Centers for Disease Control and Prevention, Centers for
Medicare & Medicaid Services
- Endorsement Status: Endorsed; MUC same as endorsed
version:No
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has not been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2012
- Project for Most Recent Endorsement Review: Population Health
Endorsement Maintenance: Phase II
- Review for Importance: The measure meets the Importance
criteria.(1a. High Impact: 1b. Performance Gap, 1c. Evidence)1a. Impact: H-9;
M-2; L-0; I-0; 1b. Performance Gap: H-5; M-6; L-0; I-0 1c. Evidence: Y-10;
N-0; I-1Rationale:• Sufficient evidence about the burden of smoking at state
and national levels, and evidence-based interventions to reduce the burden.•
Useful community assessment to help determine resource allocation and
strategic plans for combatting smoking.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria.(2a. Reliability – precise specifications,
testing; 2b. Validity – testing, threats to validity)2a. Reliability: H-8;
M-3; L-0; I-0 2b. Validity: H-7; M-4; L-0; I-0Rationale:• Concern about
validity because of the exclusion of people serving in the military and those
that are institutionalized. Although these are relatively small populations,
smoking prevalence is high among these groups.• Some Committee members stated
an additional limitation of using NHIS as a data source:o Lower age limit –
perhaps consider those younger than 18 years, which data show high
prevalence.• Several concerns about the survey questions and apparent and/or
potential lack of harmonization with similar smoking survey measures,
including BRFSS etc.o “Have you smoked at least 100 cigarettes in your entire
life? (Yes, No, Refused, Don’t Know)” does not appear to be aligned with other
survey questions, which ask “do you smoke every day, some days, or at all…”
The former is listed twice in the measure submission form.• Why are
non-combustibles and other tobacco products omitted from the measure?Following
the in-person meeting, the steward and developer provided the following
responses:• The measure, as currently specified, is based on the National
Health Interview Survey (NHIS) measure of current smoking, which tracks the
Healthy People 2020 measure for smoking prevalence among adults.• The measure
uses the following questions, which are harmonized with BRFSS:o Have you
smoked at least 100 cigarettes in your entire life? (Yes, No, Refused, Don’t
Know) and,o Do you now smoke every day, some days, or not at all (asked of
those who smoked 100 cigarettes in the above question)? (Every day, Some days,
Not at all, Refused, Don’t know)The developer agreed to utilize the BRFSS
question for smoking prevalence, which can be assessed at the state level. The
developer updated the measure submission form accordingly. In response to the
Committee’s concern about non-combustible tobacco products, the CDC recognizes
the importance of this assessment and adds that some of their surveys “…are
moving towards a question like: In the past 30 days have you smoked a
cigarette, cigar or pipe (FDA/NIDA proposed question in PATH study) and a
separate question on non-combustibles like, In the past 30 days have you used
smokeless tobacco such as chewing tobacco, snuff, snus, or dip (FDA/NIDA
proposed question in PATH study).” The CDC and the developer are considering
the addition of a question on non-combustibles in a future iteration of the
measure.
- Review for Feasibility: H-8; M-3; L-0; I-0(4a. Clinical data
generated during care process; 4b. Electronic sources; 4c. Exclusions-no
additional data source; 4d. Susceptibility to inaccuracies/unintended
consequences identified; 4e. Data collection strategy can be
implemented)Rationale:• Data are accessible from existing survey.
- Review for Usability: H-9; M-2; L-0; I-0(3a. Meaningful/useful for
public reporting and quality improvement; 3b. Harmonized; 3c. Distinctive or
additive value to exiting measures)Rationale:• Concern about the incentive to
drive quality improvement at the national level only, if the measure cannot be
drilled down to lower levels of aggregation.• Consider harmonization with
other measures. For example, smoking-related measure from NCQA in ongoing
Behavioral Health project. Need more to review measure specifications – what
questions are used in NCQA’s CAHPS survey measure? Are these aligned with
other national surveys? Following the
meeting, the developer agreed to use BRFSS’ state-level smoking prevalence
measure. The developer revised the measure submission accordingly. In
addition, NQF staff reviewed NCQA’s 0027: Medical assistance with smoking and
tobacco use cessation. The survey questions used to assess smoking prevalence
are generally standardized, except NCQA also assess tobacco use. The survey
reads, “Do you now smoke cigarettes or use tobacco every day, some days, or
not at all.” CDC asks, “Do you know smoke cigarettes every day, some days, or
not at all”.
- Endorsement Public Comments: July 19-August 17, 2012]Comments
include:
- Concerns about the systematic biases related to validity and accuracy of
responses across different populations for patient-reported data.Developer
response: This measure assesses members of the population, not patients.
Generally, self-reported smoking status is a valid indicator of
population-level smoking prevalence, and most national surveys in the United
States that assess health behavior rely on self-reported data, such as NHIS
and NSDUH. A study by Assaf et al., which examined potential gender
differences in self-reported smoking data, compared self-reported smoking
behavior to serum thiocyanate and serum cotinine levels. The authors
concluded that although there were some differences in self-reporting of
smoking status by gender, the results were similar between self-reports and
biochemical tests. The authors asserted that the results lent “credibility
to the use of self-reports as low-cost accurate approach to obtaining
information on smoking behaviors among both men and women in large
population-based surveys” (Assaf 2002).
- Harmonize measure 2020 with measure 0027 Medical assistance with smoking
tobacco use cessation (under consideration in the ongoing Behavioral Health
project). Developer response: The two metrics assess different aspects of
smoking and/or tobacco use. The denominator population for measure 0027
includes health plan members that currently smoke and use tobacco and those
that have received tobacco use and smoking cessation advice during a
specific time period. Measure 2020 assesses current smoking prevalence
(only) among the adult population in the United States. Therefore,
harmonization would not be practical or necessary.
- Include military personnel in the measure’s denominator. Developer
response: This would be ideal. While the BRFSS does not include this
population in their sample, there is no reason why future iterations of this
measure could not accurately assess smoking status in the military as
compared to the general population. Many studies examining smoking status in
a military population have relied on self-reported data and have used
measures similar to the measure used in the BRFSS.
- Include an assessment of smokeless tobacco. Developer response: This
would require a separate measure, with specific validity and reliability
testing data. This current smoking prevalence measure is thoroughly tested
and has been in use for several years.Steering Committee response: The
Committee accepted the developer’s responses and did not change their
endorsement consideration. The Committee agreed that military personnel and
smokeless tobacco are important assessments to add to the measure in the
future.
- Endorsement Committee Recommendation: Steering Committee
Recommendation for Endorsement: Y-10; N-0Rationale: The Committee is in favor
of developer’s proposed revision to use the BRFSS survey
questions.Recommendation: The Steering Committee encourages harmonization with
NCQA’s measure #0027 Medical assistance with smoking and tobacco use cessation
if possible.
CSAC Review [October 3, 2012]: Y-11; N-0Decision: Approved for endorsement
Board Review [October 19, 2012]Decision: Ratified for
endorsement
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF review
and endorsement of measure updates
- Workgroup Rationale: MAP conditionally supported this update to the
name of the measure from “reliability adjusted SIR” to “Adjusted Ranking
Metric (ARM),” pending NQF annual update. The continued use of this measure
will promote SSI prevention activities, which will lead to an improvement in
patient outcomes, reducing avoidable medical costs, patient morbidity and
mortality.
- Public comments received: 4
Rationale for measure provided by HHS
Affects large numbers,
Frequently performed procedures, A leading cause of morbidity/mortality, High
resource use, Severity of illness, Patient/societal consequences of poor
quality. SSIs estimated to account for 20% of all HAIs[1] 290,485 estimated
SSIs/yr[2] Estimated 8,205 deaths associated with SSIs each year[1] Estimated
11% of all deaths occurring in intensive care units are associated with SSIs[1]
$34,670 medical cost/SSI[2] Total >$10 billion attributable to SSI in U.S.
each year[2] Estimated additional 7-10 days of hospitalization for each SSI per
patient[1] [1] Klevens RM, Edwards JR, et al. Estimating healthcare-associated
infection and deaths in U.S. hospitals, 2002. Public Health Reports 2007;
122:160-166. [2] Scott, RD. The Direct Medical Costs of Healthcare-Associated
Infections in U.S. Hospitals and the Benefits of Prevention.
http://www.cdc.gov/ncidod/dhqp/pdf/Scott_CostPaper.pdf accessed April 12, 2010.
Measure Specifications
- NQF Number (if applicable): 753
- Description: Organ/space Surgical Site Infections (SSI) at the
primary incision site among adult patients at least 18 years of age undergoing
inpatient colon procedures and/or abdominal hysterectomies as reported through
the ACS-NSQIP or CDC NHSN. The measure yields separate SIRs for each
procedure. (The endorsed specifications of the measure are: Prototype
measure for the facility adjusted Standardized Infection Ratio (SIR) of deep
incisional and organ/space Surgical Site Infections (SSI) at the primary
incision site among adult patients aged >= 18 years as reported through the
ACS National Surgical Quality Improvement Program (ACS-NSQIP) or CDC National
Health and Safety Network (NHSN). Prototype also includes a systematic,
retrospective sampling of operative procedures in healthcare facilities. This
prototype measure is intended for time-limited use and is proposed as a first
step toward a more comprehensive SSI measure or set of SSI measures that
include additional surgical procedure categories and expanded SSI
risk-adjustment by procedure type. This single prototype measure is applied
to two operative procedures, colon surgeries and abdominal hysterectomies, and
the measure yields separate SIRs for each procedure.)
- Numerator: Deep incisional primary (DIP) and organ/space SSIs
during the 30-day postoperative period among patients at least 18 years of age
undergoing inpatient colon surgeries or abdominal hysterectomies. SSIs will be
identified before discharge from the hospital, upon readmission to the same
hospital, or during outpatient care or admission to another hospital
(post-discharge surveillance). Case accrual will be guided by sampling
algorithms as described below.
- Denominator: Using multivariable logistic regression models for
colon surgeries and abdominal hysterectomies, the expected number of SSIs is
obtained. These expected numbers are summed by facility and surgical procedure
and used as the denominator of this measure
- Exclusions: Persons under the age of 18, those having a procedure
performed on an outpatient basis, those with ASA Class VI (6) are
excluded.(The endorsed specifications of the measure are: Persons under the
age of 18, those having a procedure performed on an outpatient basis, those
with ASA Class VI (6) are excluded. In the NHSN, patients without primary
closure of the surgical incision are not considered eligible cases and are
excluded- the NSQIP will match this practice for this measure, although this
is not standard practice within the NSQIP.)
- HHS NQS Priority: Making Care Safer
- HHS Data Source: National Healthcare Safety Network
- Measure Type: Outcome
- Steward: Centers for Disease Control and Prevention
- Endorsement Status: Endorsed; MUC same as endorsed
version:Yes
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2012
- Project for Most Recent Endorsement Review: Patient Safety
Measures
- Review for Importance: The measure addresses a high impact area.
Each year, approximately 11 percent of all deaths in ICUs are associated with
SSIs, resulting in up to 20,000 deaths and $2 billion in additional costs.2
Moreover, evidence-based interventions have shown significant reductions in
SSI rates and improved health outcomes.
- Review for Scientific Acceptability: See CDP
Recommendation]
- Review for Feasibility: See CDP Recommendation]
- Review for Usability: See CDP Recommendation]
- Review for Related and Competing Measures: See CDP
Recommendation]
- Endorsement Committee Recommendation: The Steering Committee
discussed the newly-harmonized measure in a supplemental conference call,
reviewing the relevant changes, while also receiving clarification from the
developers on several issues. Committee members inquired as to why these two
particular measures had been chosen, and asked for clarification on the plan
for public reporting. The developer explained that the CMS IPPS requirements
released on August 1, 2011, call for abdominal hysterectomies and colon
surgeries to be reported by the CDC to CMS. The NHSN will serve as the single
reporting system for CMS-required reporting. However, facilities may choose
which calculations of performance on the measure can be accomplished using
either the NHSN or NSQIP data system. The measure developer acknowledged that
for hospitals participating in both systems, there could be duplication.The
Steering Committee questioned why both organ space and deep incisional
infections were included in the measure. The developer described the approach
as a long standing precedent and stated that superficial infections are
considered trivial events and therefore not included. However, organ space
infections that drain through the incisions are classified as deep incisional
infections. The combination of organ space and deep incisional infections are
considered a clinically coherent grouping. The Committee expressed their
appreciation for the developers’ efforts at harmonization, and agreed that the
measure continues to meet the four major evaluation criteria. The Steering
Committee recommended this measure for endorsement in a unanimous vote.This
outcome measure replaces NQF-endorsed measure #0299 (Surgical Site Infection
Rate) and addresses the National Priority area of
safety.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because
although cost is important to measure, data supporting variation in costs for
this procedure was not provided. The group also noted that measuring resource
use (cost) is different from appropriateness of care; the cost of a service is
not indicative of quality care.
- Public comments received: 8
Rationale for measure provided by HHS
Episode-based performance
measurement allows meaningful comparisons between providers based on resource
use for certain clinical conditions or procedures, as noted in the NQF report
for the “Episode Grouper Evaluation Criteria” project (available at
http://www.qualityforum.org/Publications/2014/09/Evaluating_Episode_Groupers__A_Report_from_the_National_Quality_Forum.aspx)
and in various peer-reviewed articles (e.g., Hussey, P. S., Sorbero, M. E.,
Mehrotra, A., Liu, H., & Damberg, S. L. (2009). Episode-Based Performance
Measurement and Payment: Making It a Reality. Health Affairs, 28(5), 1406-1417.
doi:10.1377/hlthaff.28.5.1406). While reliability analyses have been conducted
on similar performance measures, we plan to conduct our own reliability analysis
for this specific measure and propose a minimum number of cases for reporting.
The analysis will likely mirror the 2012 MSPB reliability analysis:
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/hospital-value-based-purchasing/Downloads/MSPBReliabilityAnalysis-Jul-18-12.pdf
Measure Specifications
- NQF Number (if applicable):
- Description: The measure constructs a clinically coherent group of
services to inform providers about resource use and effectiveness. It sums
Parts A and B payments related to an aortic aneurysm procedure inpatient (IP)
stay and attributes them to the hospital where the index IP stay occurred. It
includes abdominal aortic aneurysm and thoracic aortic aneurysm
subtypes.
- Numerator: The numerator of the Aortic Aneurysm Procedure Clinical
Episode-Based Payment Measure is the risk-adjusted sum of a provider’s
spending and the preadmission and post-discharge medical services that are
clinically related to the aortic aneurysm procedures across a hospital’s
eligible aortic aneurysm procedure episodes during the period of performance.
A clinical episode begins 3 days prior to the initial (i.e., index) admission
and extends 30 days following the index hospital stay discharge
date.
- Denominator: A count of the provider’s condition-specific episodes
during the period of performance.
- Exclusions: Episode Exclusions: 1. Beneficiaries who do not have
continuous enrollment in Medicare Parts A and B from 90 days prior to IP
admission through the end of the episode with Medicare as the primary payer.
2. Beneficiaries who enroll in Medicare Advantage during the period that
starts 90 days prior to IP admission through the end of the
episode.
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: Claims
- Measure Type: Efficiency
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because
although cost is important to measure, data supporting variation in costs for
this procedure was not provided. The group also noted that measuring resource
use (cost) is different from appropriateness of care; the cost of a service is
not indicative of quality care.
- Public comments received: 7
Rationale for measure provided by HHS
Episode-based performance
measurement allows meaningful comparisons between providers based on resource
use for certain clinical conditions or procedures, as noted in the NQF report
for the “Episode Grouper Evaluation Criteria” project (available at
http://www.qualityforum.org/Publications/2014/09/Evaluating_Episode_Groupers__A_Report_from_the_National_Quality_Forum.aspx)
and in various peer-reviewed articles (e.g., Hussey, P. S., Sorbero, M. E.,
Mehrotra, A., Liu, H., & Damberg, S. L. (2009). Episode-Based Performance
Measurement and Payment: Making It a Reality. Health Affairs, 28(5), 1406-1417.
doi:10.1377/hlthaff.28.5.1406). While reliability analyses have been conducted
on similar performance measures, we plan to conduct our own reliability analysis
for this specific measure and propose a minimum number of cases for reporting.
The analysis will likely mirror the 2012 MSPB reliability analysis:
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/hospital-value-based-purchasing/Downloads/MSPBReliabilityAnalysis-Jul-18-12.pdf
Measure Specifications
- NQF Number (if applicable):
- Description: The measure constructs a clinically coherent group of
services to inform providers about resource use and effectiveness. It sums
Parts A and B payments related to a Cholecystectomy and Common Duct
Exploration IP stay and attributes them to the hospital where the index IP
stay occurred.
- Numerator: The numerator of the Cholecystectomy and Common Duct
Exploration Clinical Episode-Based Payment Measure is the risk-adjusted sum of
a provider’s spending and the preadmission and post-discharge medical services
that are clinically related to cholecystectomy and common duct exploration
across a hospital’s eligible Cholecystectomy and Common Duct Exploration
episodes during the period of performance. A clinical episode begins 3 days
prior to the initial (i.e., index) admission and extends 30 days following the
index hospital stay discharge date.
- Denominator: A count of the provider’s condition-specific episodes
during the period of performance.
- Exclusions: Episode Exclusions: 1. Beneficiaries who do not have
continuous enrollment in Medicare Parts A and B from 90 days prior to IP
admission through the end of the episode with Medicare as the primary payer.
2. Beneficiaries who enroll in Medicare Advantage during the period that
starts 90 days prior to IP admission through the end of the
episode.
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: Claims
- Measure Type: Efficiency
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF review
and endorsement and examination of SDS factors
- Workgroup Rationale: MAP conditionally supported this measure
pending NQF review and endorsement. MAP also stated that the Standing
Committee reviewing this measure should consider SDS factors that examine the
true hospital vs. community role in readmissions and consider parsimony with
regard to multiple pneumonia readmission measures.
- Public comments received: 8
Rationale for measure provided by HHS
Pneumonia results in
approximately 1.2 million hospital admissions each year and accounts for more
than $10 billion annually in hospital expenditures. Approximately 20% of
pneumonia patients were rehospitalized within thirty days, representing the
second-highest proportion of all rehospitalizations at 6.3% (Jencks et al.,
2009). Acute care utilization after discharge (return to the emergency
department, observation stay and readmission), for any reason, is disruptive to
patients and caregivers, costly to the healthcare system, and puts patients at
additional risk of hospital-acquired infections and complications. Although some
readmissions are unavoidable, they may also result from poor quality of care or
inadequate transitional care. Numerous studies have found an association between
quality of inpatient or transitional care and early (typically 30-day)
readmission rates for a wide range of conditions including pneumonia (Frankl et
al., 1991; Corrigan et al., 1992; Oddone et al., 1996; Ashton et al., 1997;
Benbassat et al., 2000; Courtney et al., 2003; Halfon et al., 2006; Dean et al.,
2006). Several studies also have reported on the relationship between inpatient
admissions and other types of hospital care including ED visits and observation
stays. Two recent studies conducted in patients of all ages have shown that 9.5%
of patients return to the ED within 30 days of hospital discharge and that about
12% of these patients are discharged from the ED and are not captured by current
CMS readmissions measures (Rising et al., 2013; Vashi et al., 2013). Rising
rates of observation stays among Medicare beneficiaries have gained the
attention of patients, providers, and policymakers (Feng et al., 2012; Rising et
al., 2013; Vashi et al., 2013). A report from the Office of the Inspector
General (OIG) notes the potential relationship between hospital use of
observation stays as an alternative to short-stay inpatient hospitalizations as
a response to changing hospital payment incentives (Wright, 2013). Thus, in the
context of the publicly reported CMS 30-day readmission measures, the increasing
use of ED visits and observation stays has raised concerns that current
readmission measures do not capture the full range of unplanned acute care in
the post-discharge period. References: Ashton CM, Del Junco DJ, Souchek J,
Wray NP, Mansyur CL. The association between the quality of inpatient care and
early readmission: a meta-analysis of the evidence. Med Care. Oct
1997;35(10):1044-1059. Benbassat J, Taragin M. Hospital readmissions as a
measure of quality of health care: advantages and limitations. Archives of
Internal Medicine. Apr 24 2000;160(8):1074-1081. Corrigan JM, Martin JB.
Identification of factors associated with hospital readmission and development
of a predictive model. Health Serv Res. Apr 1992;27(1):81-101. Courtney EDJ,
Ankrett S, McCollum PT. 28-Day emergency surgical re-admission rates as a
clinical indicator of performance. Ann R Coll Surg Engl. Mar 2003;85(2):75-78.
Dean NC, Bateman KA, Donnelly SM, Silver MP, Snow GL, Hale D. Improved clinical
outcomes with utilization of a community-acquired pneumonia guideline. Chest.
2006;130(3):794-799 Feng Z, Wright B, Mor V. Sharp rise in Medicare enrollees
being held in hospitals for observation raises concerns about causes and
consequences. Health affairs (Project Hope). Jun 2012;31(6):1251-1259. Frankl
SE, Breeling JL, Goldman L. Preventability of emergent hospital readmission. Am
J Med. Jun 1991;90(6):667-674. Halfon P, Eggli Y, Pr, et al. Validation of the
potentially avoidable hospital readmission rate as a routine indicator of the
quality of hospital care. Medical Care. Nov 2006;44(11):972-981. Jencks SF,
Williams MV, Coleman EA. Rehospitalizations among patients in the Medicare
fee-for-service program. N Engl J Med. 2009;360(14):1418-28. Oddone EZ,
Weinberger M, Horner M, et al. Classifying general medicine readmissions. Are
they preventable? Veterans Affairs Cooperative Studies in Health Services Group
on Primary Care and Hospital Readmissions. Journal of General Internal Medicine.
1996;11(10):597-607. Rising KL, White LF, Fernandez WG, Boutwell AE. Emergency
Department Visits After Hospital Discharge: A Missing Part of the Equation.
Annals of Emergency Medicine. Vashi AA, Fox JP, Carr BG, et al. Use of
hospital-based acute care among patients recently discharged from the hospital.
JAMA : the journal of the American Medical Association. Jan 23
2013;309(4):364-371. Wright S. Hospitals’ Use of Observation Stays and Short
Inpatient Stays for Medicare Beneficiaries. Washington, DC: OIG;2013
Measure Specifications
- NQF Number (if applicable):
- Description: This measure assesses the difference (“excess”)
between the average number of risk-adjusted days a hospital’s patients spend
in an ED, observation, or readmission in the 30 days following a
hospitalization for pneumonia (“predicted”) and the number of days in acute
care that they would have been expected to spend if discharged from an average
hospital.
- Numerator: This outcome measure does not have a traditional
numerator and denominator. We use this field to describe the outcome. The
outcome of the measure is the average number of days the patient spends in
acute care (ED treat-and-release visits, observation stays, and readmissions)
during the first 30 days after discharge from the hospital. An ED visit is
defined as a visit with revenue center codes ‘0450’, ‘0451’, ‘0452’, ‘0459’,
or ‘0981’. Each ED visit is counted as one half-day (0.5 days). An
observation stay is defined as a visit with revenue center code ‘0762’ or
Healthcare Common Procedure Coding System (HCPCS) code ‘G0378’ (in the
outpatient data files) or Current Procedural Terminology (CPT) codes ‘99217’
to ‘99220’ or ‘99234’ to ‘99236’ (in the Physician Carrier data files).
Observation stays are recorded in terms of hours and converted for the measure
into half-days (rounded up). A readmission is defined as any unplanned acute
care hospital inpatient hospitalization within 30 days of the discharge date
for the index hospitalization. “Planned” readmissions are those planned by
providers for anticipated medical treatment or procedures that must be
provided in the inpatient setting. To exclude planned readmissions, we use the
planned readmission algorithm previously developed for the CMS 30-day
pneumonia readmission measure. Each rehospitalization is counted according to
the length of stay, calculated as the discharge date minus the admission date.
Admissions that extend beyond the 30-day follow-up period are truncated on day
30. When an ED visit, observation stay, or readmission overlaps with another
event, we count only the most severe of the overlapping events
- Denominator: This outcome measure does not have a traditional
numerator and denominator. We use this field to define the measure cohort.
The denominator includes Medicare FFS beneficiaries aged 65 years and older
hospitalized at non-Federal hospitals with a principle discharge diagnosis of
pneumonia, aspiration pneumonia, and sepsis in cases where sepsis is
accompanied by secondary diagnosis of pneumonia present on admission. To be
included in the cohort the patients must have been continuously enrolled in
Medicare FFS Parts A and B for the 12 months prior to the index
hospitalization.
- Exclusions: This measure excludes index admissions for patients who
leave the hospital against medical advice. This measure also excludes index
admissions for patients without at least 30 days post-discharge enrollment in
FFS Medicare.
- HHS NQS Priority: Making Care Safer, Patient and Family Engagement,
Communication and Care Coordination, Best Practice of Healthy
Living
- HHS Data Source: Administrative claims The Medicare data sources
used to create this measure were: 1. Medicare Enrollment Database (EDB) (to
determine eligibility). This dataset contains Medicare beneficiary
demographic, benefit/coverage, enrollment status, and vital status
information. 2. Medicare hospital inpatient and outpatient claims, and
physician Carrier claims. 3. CCW 100% condition-specific datasets.
Specifically, the measure uses the outpatient hospital institutional claims
file and physician Carrier file (also known as the Physician/Supplier Part B
claims file). This third data source is used to capture the outcome of acute
care days of ED visits and observation stays.
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF review
and endorsement
- Workgroup Rationale: MAP conditionally supported this measure
pending NQF review and endorsement and asked that CMS consider a phased
approach in regards to implementation to avoid multiple versions of the same
measure. MAP also noted that mortality is not the most meaningful outcome for
stroke patients and to consider cognitive or functional outcomes such as
impaired capacity.
- Public comments received: 14
Rationale for measure provided by HHS
Post-stroke mortality rates
have been shown to be influenced by critical aspects of care at the hospital
such as response to complications, speediness of delivery of care, organization
of care, and appropriate imaging [Smith et al., 2006; Reeves et al., 2009;
Lingsma et al., 2008; Hong et al., 2008; Fonarow et al., 2014]. This research
demonstrates the relationship between hospital organizational factors and
performance on the stroke mortality measure, and supports the ability of
hospitals to impact these rates.
Measure Specifications
- NQF Number (if applicable):
- Description: This stroke mortality measure will estimate the
hospital-level, risk-standardized mortality rate (RSMR) for patients
discharged from the hospital with a principal discharge diagnosis of acute
ischemic stroke. The outcome is all-cause 30-day mortality, defined as death
from any cause within 30 days of the index admission date, including
in-hospital death, for stroke patients. The measure uses Medicare
fee-for-service (FFS) administrative claims to derive the cohort and outcome,
and for risk adjustment. The major revision is to include NIH Stroke Scale as
a measure of stroke severity in the risk-adjustment.
- Numerator: This outcome measure does not have a traditional
numerator and denominator. We use this field to define the measure outcome.
The measure outcome is death from any cause within 30 days of the admission
date of the index admission for patients with a principal discharge diagnosis
of acute ischemic stroke.
- Denominator: The cohort includes inpatient admissions for patients
aged 65 years and older who were discharged from short-term acute care
hospitals with a principal discharge diagnosis of acute ischemic
stroke.
- Exclusions: The measure excludes admissions for patients: -with
inconsistent or unknown vital status or other unreliable data (unreliable or
missing data limit the validity of the risk-adjustment model); -enrolled in
the Medicare hospice program at any time in the 12 months prior to the index
admission, including the first day of the index admission (because these
patients are likely continuing to seek comfort measures only and mortality is
not necessarily an adverse outcome or signal of poor quality care for these
patients); and -discharged against medical advice (because providers did not
have the opportunity to deliver full care and prepare the patient for
discharge).
- HHS NQS Priority: Making Care Safer, Communication and Care
Coordination, Effective Prevention and Treatment
- HHS Data Source: Administrative claims. The measure uses Medicare
administrative claims data. The Medicare data sources used to create the
measure were: 1) Medicare Part A inpatient and Outpatient and Part B
outpatient claims from the Standard Analytic File, including inpatient and
outpatient claims for the 12 months prior to an index admission. This dataset
was used to identify the cohort (Part A inpatient) and to identify
comorbidities (Part A inpatient and outpatient and Part B outpatient). 2)
Medicare Enrollment Database (EDB): This database contains Medicare
beneficiary demographic, benefit/coverage, and vital status information. This
dataset was used to obtain information on several inclusions/exclusions
indicators such as Medicare status on admission, and to ascertain the outcome
(death).
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF review
and endorsement of measure updates and examination of SDS factors
- Workgroup Rationale: MAP conditionally supported this measure
pending NQF review and endorsement of the expanded population and the Standing
Committee consider SDS factors other than race in the risk-adjustment
model.
- Public comments received: 8
Rationale for measure provided by HHS
Medicare spending is
estimated to have been $525.0 billion in 2010 with annual growth rates projected
to be 6.3% for 2013 through 2020 due to both an increase in the Medicare
population as well as Medicare spending on each beneficiary[1]. Further
projections anticipate an exhaustion of Medicare‘s Hospital Insurance Trust Fund
(Part A) by 2024 [2]. The growth in spending is unsustainable and highlights the
need to understand the value of care Medicare buys with every dollar spent.
Given the urgency of the state of the Medicare Hospital Insurance Trust Fund and
the fact that Medicare pays for 40-50% of hospitalizations nationally [3],
hospital costs are a natural venue in which to deconstruct payments for Medicare
patients. Yet payments to hospitals are difficult to interpret in isolation.
Some high payment hospitals may have better clinical outcomes when compared with
low payment hospitals; other high payment hospitals may not. For this reason,
the value of hospital care is more clearly assessed when pairing hospital
payments with hospital quality. A measure of payments for Medicare patients to
hospitals that is aligned with current quality of care measures will facilitate
profiling hospital value (payments and quality). This measure will reflect
differences in the management of care for patients with pneumonia both during
hospitalization and immediately post-discharge. Pneumonia is a condition with
substantial range in costs of care and for which there are well-established
publicly reported quality measures and is therefore an ideal condition for
assessing relative value for an episode-of-care that begins with an acute
hospitalization. By focusing on one specific condition, value assessments may
provide actionable feedback to hospitals and incentivize targeted improvements
in care. 1. Ash AS, Byrne-Logan S. How Well Do Models Work? Predicting Health
Care Costs. Proceedings of the Section on Statistics in Epidemiology. American
Statistical Association. 1998. 2. Medpac. Report to the Congress: Medicare
Payment Policy 9/17/12 2012. 3. National Hospital Discharge Survey.
http://www.cdc.gov/nchs/nhds.htm. Accessed 08/07/2012.
Measure Specifications
- NQF Number (if applicable): 2579
- Description: This measure estimates hospital-level,
risk-standardized payment for a pneumonia episode of care starting with
inpatient admission to a short term acute-care facility and extending 30 days
post-admission for Medicare fee-for-service (FFS) patients who are 65 years of
age or older with a principal discharge diagnosis of pneumonia, aspiration
pneumonia, and sepsis in cases where sepsis is accompanied by secondary
diagnosis of pneumonia present on admission. (The endorsed specifications
of the measure are: This measure estimates hospital-level, risk-standardized
payment for a pneumonia episode of care starting with inpatient admission to a
short term acute-care facility and extending 30 days post-admission for
Medicare fee-for-service (FFS) patients who are 65 years of age or older with
a principal discharge diagnosis of pneumonia.)
- Numerator: This outcome measure does not have a traditional
numerator and denominator. We are using this field to define the outcome. The
outcome for this measure is a hospital-level, risk-standardized payment for
Medicare patients for a pneumonia episode-of-care. The payment timeframe
starts from the admission date of an index hospitalization through 30 days
post-admission. We include payments for the index admission, as well as
payments for subsequent inpatient, outpatient, skilled nursing facility, home
health, hospice, physician/clinical laboratory/ambulance services, supplier
Part B items, and durable medical equipment, prosthetics/orthotics, and
supplies. In order to compare payments for Medicare patients related to
clinical care, we remove geography and policy adjustment from our payment
calculation whenever possible. If the data for a specific care setting do not
allow for the removal of these adjustments, we calculate an average payment
for each item across all geographic areas and replace the claim payment amount
in the data with the average payment amount for that item.
- Denominator: This outcome measure does not have a traditional
numerator and denominator. We use this field to define the measure cohort.
The measure cohort includes admissions to non-federal, short-stay, acute-care
hospitals for Medicare FFS patients age 65 years and older with a principal
discharge diagnosis of pneumonia, or aspiration pneumonia, or sepsis in cases
where sepsis is accompanied by secondary diagnosis of pneumonia present on
admission. Patients must also have continuous enrollment in Medicare Part A
and Part B benefits for the 12 months prior to the index admission and 30 days
post- admission.
- Exclusions: The measure excludes patients with: 1. Incomplete
administrative data in the 30 days following the index admission (if alive)
2. Same or next day discharge and patient did not die or get transferred 3.
Transfers into the hospital 4. Inconsistent or unknown mortality status 5.
Unreliable data 6. Patients who leave hospital against medical advice (AMA)
7. Patients enrolled in hospice in year prior to admission or day of admission
8. Transfers to Federal hospitals 9. Patients without an index admission DRG
or DRG weight 10. Admissions within 30 days of a previous index
admission
- HHS NQS Priority: Communication and Care Coordination, Making Care
Affordable
- HHS Data Source: Administrative claims. Medicare administrative
claims data for certain Part A and Part B services in the 12 months prior to
and during the index admission are used for risk adjustment. The data also
contain price-standardized payments for Medicare patients across multiple care
settings, services, and supplies (i.e., inpatient, outpatient, SNF, home
health, hospice, physician/clinical laboratory/ambulance services, and durable
medical equipment, prosthetics/orthotics, and supplies). The
price-standardized payment data element is harmonized across CMS cost and
resource use measures
- Measure Type: Cost/Resource Use
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: CMS is expanding the cohort to match the
pneumonia mortality measure. In addition to patients with pneumonia as the
principle discharge diagnosis the measure will also include patients with a
principle discharge diagnosis of aspiration pneumonia, and sepsis in cases
where sepsis is accompanied by secondary diagnosis of pneumonia present on
admission.
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has not been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Endorsing Cost and
Resource Use Measures: Phase 3
- Review for Importance: The measure meets the Importance criteria1a.
High Priority: H-17; M-5; L-0; I-0; IE-0; 1b. Opportunity for Improvement:
H-19; M-2; L-1; I-0; 1c. Measure Intent: H-18; M-4; L-0; I-0 1. Overall
Importance: H-18; M-4; L-0; I-0Rationale:• The Committee stated that the
measure is high priority given that pneumonia is one of the leading causes of
hospitalization for Medicare patients sixty-five years of age and older, with
Medicare paying roughly ten billion dollars in aggregate costs for
hospitalized beneficiaries with pneumonia. • The developer presented evidence
indicating that there is a threefold variation in cost for the medical
treatment of pneumonia patients, which the Committee agreed signified that
there is a substantial opportunity for improving the overall costs for
pneumonia patients.• The Committee stated that by using this measure in
conjunction with a measure capturing the quality of care for pneumonia
patients, there is an opportunity to begin to understand the value of the care
provided by the hospitals and other providers in treating this
condition.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria(2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity)2a. Reliability: H-10;
M-11; L-1; I-0 2b. Validity: H-3; M-18; L-1; I-0Rationale:• The Committee
stated that the measure specifications were precise and that the measure was
well-constructed. This measure captures risk-standardized payments for a
thirty-day episode of care for Medicare patients diagnosed admitted to the
hospital with a diagnosis of pneumonia through administrative claims data.•
The developer provided reliability testing at the level of the performance
measure score; testing was performed by calculating the Intraclass Correlation
Coefficient (ICC) score by calculating the risk standardized payment using a
split-sample of the combined 2008-2009 data from hospitals. The ICC score was
0.825, indicating significant agreement between the two samples, which the
Committee found sufficient.• The Committee questioned the validity of
specifying the measure for a thirty-day episode triggered by admission for
pneumonia, as the treatment of pneumonia may require care coordination
post-discharge that may extend past thirty days. The Committee stated that
this could affect payments captured during the post-discharge period,
artificially inflating or deflating the costs for some patients simply because
of the construct of the measure.• The Committee raised concerns regarding the
attribution approach and the implications for attribution of costs if a
patient were transferred to another hospital. The developer clarified that
only 0.4 percent of cohorts are transferred for pneumonia, which represents a
small number of beneficiaries. In the case of transfer patients, costs for the
patient will be attributed to the initial admitting hospital, as hospitals are
increasingly responsible for care delivered up to 30 days after discharge. The
Committee found this approach to attribution to be acceptable.• The Committee
stated concern that the low r-squared value (.07) for the risk model may
indicate that case mix is not being appropriately adjusted for through the
risk model. The developer clarified that at lower patient volumes, there is
less certainty when estimating cost. The measure uses a continuous outcome
which results in a more accurate estimate than would result from a binary
outcome. Additionally, the measure uses hierarchical risk modeling that
adjusts hospitals with low patient volume towards the mean. The Committee
found this explanation to be sufficient.• The Committee questioned whether
adjustments for sociodemographic status (SDS) factors should be incorporated
into the risk adjustment model. NQF clarified that it is in the early stages
of reviewing our policy on risk adjusting for SDS factors. The recommendations
for modifying NQF’s current policy on adjusting for SDS factors have not yet
been finalized. As such, we ask that Committees continue to evaluate measures
according to our current guidelines, that SDS factors are not included in the
risk adjustment model, but are used to stratify the measure. If in the future
the recommendations for adjusting for SDS factors become NQF policy, measures
that may be improved from incorporating these adjustments will be updated and
reviewed by the Committee through one of NQF’s measure maintenance
processes.
- Review for Feasibility: H-20; M-2; L-0; I-0(3a. Byproduct of Care
Processes; and 3b. Electronic sources; and 3c. Data Collection
Strategy)Rationale: The Committee stated that this measure is feasible to
implement because the measure is specified using administrative claims data
which is created as a byproduct of care delivery and available
electronically.
- Review for Usability: H-10; M-11; L-1; I-0(4a.
Accountability/transparency (used in accountability w/in 3 yr, public
reporting w/in 6 yr, or if new - credible plan); and 4b. Improvement –
progress demonstrated (if new - credible rationale); and 4c. Unintended
Consequences - benefits outweigh evidence of unintended negative consequences
(to patients/populations); and 4d. Measure Deconstruction – can be
deconstructed to facilitate transparency and understanding)Rationale:• The
Committee found the measure to be useful for providers, giving them access to
detailed data of cost for hospital care for pneumonia.• The Committee
questioned the availability of information on costs for providers other than
the hospital to which the patient has been attributed, stating that for this
measure to be most useful there needs to be documentation of the reimbursement
amounts for each provider treating the patient.
- Review for Related and Competing Measures: No related or competing
measures identified.
- Endorsement Public Comments: August 14, 2014 - September 12,
2014Comments received:• One measure-specific comment was received regarding
the appropriateness of the attribution approach for measure #2579. The
commenter suggested that the current attribution approach is inappropriate and
only reflects an episode-of-care attributed to a hospital as the responsible
entity and does not account for the care of multiple providers across the
health care delivery system. The commenter suggested this approach would be
more appropriate for an integrated health system or an organization accepting
bundled payments.• Two comments regarding risk adjustment for sociodemographic
status for this measure. Some commenters believed that it would be appropriate
to stratify claims by sociodemographic factors and document non-clinical
elements that negatively impact patient outcomes when calculating risk
adjusted costs.• One measure-specific comment was received regarding validity
of exclusions for measure this measure. A commenter proposed the inclusion of
ICD-9 code 507.0 in the denominator for aspiration pneumonia, which was
estimated to account for 15% of Medicare patients discharged with
pneumonia.Developer response:• Yale addressed the concern of integrating the
ICD-9 code 507.0 in the denominator for aspiration pneumonia and based on the
prevalence of the code, developers will plan to reevaluate including
aspiration pneumonia in future versions of the measure.Committee responses:•
The Committee acknowledged and many shared the concerns with the attribution
approach used in this measure; however, they also stated that hospitals are
increasingly responsible for care delivered up to 30 days after discharge.
Consequently, hospitals are in the unique position of being able to push
coordination of care, and this measure may serve as an impetus for this to
occur.• The Committee recognizes the importance of adequately adjusting for
sociodemographic status in the appropriate applications. While NQF continues
to work on their implementation of the guidance from the SDS Expert Panel,
measures currently under review have been recommended with additional guidance
to stratify for SDS, as appropriate.• Based on the NQF criteria for validity,
the Committee has agreed that this measure has met the criteria for validity
and has recommended it for endorsement. A few committee members support the
inclusion of ICD-9 code 507.0 within this measure, which will assist with
documenting the presence of pneumonia aspiration among admission.
- Endorsement Committee Recommendation: Standing Committee
Recommendation for Endorsement: Y-21; N-1.
NQF Member Voting: October
6, 2014- October 20, 2014
Representatives of 18 member organizations voted,
with 50% approval;consensus was not reached.
Consensus Standards
Approval Committee (CSAC) Vote: November 12,2014; Y-13, N-0
Endorsed with
the same conditions the CMS cardiovascular hospitallevel episode-based
measures from phase II.
Board of Directors Executive Committee
Vote: December 22, 2014
Ratified endorsement with the following
conditions:
- One- year Look Back Assessment of Unintended Consequences: NQFstaff will
work with Cost and Resource Standing Committee andCMS to determine a plan
for assessing potential unintendedconsequences of this measure in use. The
evaluation ofunintended consequences will be initiated in approximately
oneyear and possible changes to the measures based on this data.
- Consideration for SDS trial period: The Cost and Resource UseStanding
Committee will consider whether the measure should beincluded in the NQF
trial period for sociodemographic statusadjustments.
- Attribution: NQF will consider opportunities to address theattribution
issue.
Appeals: December 30, 2014 -January 28, 2015
No
appeals submitted.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF review
and endorsement
- Workgroup Rationale: MAP conditionally supported this measure
pending NQF review and endorsement and asked that CMS consider a phased
approach in regards to implementation to avoid multiple versions of the same
measure. MAP also noted that mortality is not the most meaningful outcome for
stroke patients and to consider cognitive or functional outcomes such as
impaired capacity.
- Public comments received: 12
Rationale for measure provided by HHS
Post-stroke mortality rates
have been shown to be influenced by critical aspects of care at the hospital
such as response to complications, speediness of delivery of care, organization
of care, and appropriate imaging [Smith et al., 2006; Reeves et al., 2009;
Lingsma et al., 2008; Hong et al., 2008; Fonarow et al., 2014]. This research
demonstrates the relationship between hospital organizational factors and
performance on the stroke mortality measure, and supports the ability of
hospitals to impact these rates. The hybrid measure addresses a limitation of
the claims-only measure by incorporating clinical data collected at the time of
admission to assess the condition of the patient before care has been
administered.
Measure Specifications
- NQF Number (if applicable):
- Description: This hybrid stroke mortality measure will estimate the
hospital-level, risk-standardized mortality rate (RSMR) for patients
discharged from the hospital with a principal discharge diagnosis of acute
ischemic stroke. The outcome is all-cause 30-day mortality, defined as death
from any cause within 30 days of the index admission date, including
in-hospital death, for stroke patients. The measure is referred to as a hybrid
because it will use Medicare fee-for-service (FFS) administrative claims to
derive the cohort and outcome, and claims and clinical EHR data for risk
adjustment.
- Numerator: This outcome measure does not have a traditional
numerator and denominator. We use this field to define the measure outcome.
The measure outcome is death from any cause within 30 days of the admission
date of the index admission for patients with a principal discharge diagnosis
of acute ischemic stroke.
- Denominator: The cohort includes inpatient admissions for patients
aged 65 years and older who were discharged from short-term acute care
hospitals with a principal discharge diagnosis of acute ischemic
stroke.
- Exclusions: The measure excludes admissions for patients: -with
inconsistent or unknown vital status or other unreliable data); -enrolled in
the Medicare hospice program at any time in the 12 months prior to the index
admission, including the first day of the index admission and -discharged
against medical advice
- HHS NQS Priority: Making Care Safer, Communication and Care
Coordination, Effective Prevention and Treatment
- HHS Data Source: Administrative claims (cohort, outcome assessment;
risk adjustment), Clinical EHR data: risk adjustment. The measure uses
Medicare administrative claims data and clinical data that are extracted from
electronic health records (EHRs). Because there is currently no large national
dataset that includes patient-level EHR data related to patients with acute
ischemic stroke, this measure was developed using Medicare administrative
claims and data collected in the American Heart Association (AHA)/American
Stroke Association (ASA)’s Get With The Guidelines (GWTG)-Stroke registry for
model development and validation. Administrative claims data were obtained
from Medicare Inpatient/Outpatient Claims Databases as well as Medicare’s
Enrollment Database (EDB), containing Medicare beneficiary demographic
(including age, gender, and birth date), benefit/coverage, and vital status
information (such as whether the patient was dead or alive, and date of
death).
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because
according to the measure developer, this version of the measure did not
perform as well as the claims-based only measure and the EHR plus claims-based
measure. In addtion, MAP noted that mortality is not the most meaningful
outcome for stroke patients and to consider cognitive or functional outcomes
such as impaired capacity.
- Public comments received: 12
Rationale for measure provided by HHS
Post-stroke mortality rates
have been shown to be influenced by critical aspects of care at the hospital
such as response to complications, speediness of delivery of care, organization
of care, and appropriate imaging [Smith et al., 2006; Reeves et al., 2009;
Lingsma et al., 2008; Hong et al., 2008; Fonarow et al., 2014]. This research
demonstrates the relationship between hospital organizational factors and
performance on the stroke mortality measure, and supports the ability of
hospitals to impact these rates. The hybrid measure addresses a limitation of
the claims-only measure by incorporating clinical data collected at the time of
admission to assess the condition of the patient before care has been
administered.
Measure Specifications
- NQF Number (if applicable):
- Description: This hybrid stroke mortality measure will estimate the
hospital-level, risk-standardized mortality rate (RSMR) for patients
discharged from the hospital with a principal discharge diagnosis of acute
ischemic stroke. The outcome is all-cause 30-day mortality, defined as death
from any cause within 30 days of the index admission date, including
in-hospital death, for stroke patients. The measure is referred to as a hybrid
because it will use Medicare fee-for-service (FFS) administrative claims to
derive the cohort and outcome, and clinical data (EHR extracted) for risk
adjustment.
- Numerator: This outcome measure does not have a traditional
numerator and denominator. We use this field to define the measure outcome.
The measure outcome is death from any cause within 30 days of the admission
date of the index admission for patients with a principal discharge diagnosis
of acute ischemic stroke.
- Denominator: The cohort includes inpatient admissions for patients
aged 65 years and older who were discharged from short-term acute care
hospitals with a principal discharge diagnosis of acute ischemic
stroke.
- Exclusions: The measure excludes admissions for patients: -with
inconsistent or unknown vital status or other unreliable data); -enrolled in
the Medicare hospice program at any time in the 12 months prior to the index
admission, including the first day of the index admission and -discharged
against medical advice
- HHS NQS Priority: Making Care Safer, Communication and Care
Coordination, Effective Prevention and Treatment
- HHS Data Source: Administrative claims ( cohort, outcome
assessment; risk adjustment), EHR data: risk adjustment. The measure uses
Medicare administrative claims data and clinical data that are extracted from
electronic health records (EHRs). Because there is currently no large national
dataset that includes patient-level EHR data related to patients with acute
ischemic stroke, this measure was developed using Medicare administrative
claims (for cohort derivation and outcome assessment) and data collected in
the American Heart Association (AHA)/American Stroke Association (ASA)’s Get
With The Guidelines (GWTG)-Stroke registry for model development and
validation. Administrative claims data were obtained from Medicare
Inpatient/Outpatient Claims Databases as well as Medicare’s Enrollment
Database (EDB), containing Medicare beneficiary demographic (including age,
gender, and birth date), benefit/coverage, and vital status information (such
as whether the patient was dead or alive, and date of death).
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending optional
eCQM pathway
- Workgroup Rationale: MAP conditionally supported this measure an
optional eCQM pathway and asked that its performance be monitored. MAP
recognized that this is an important patient safety issue, but stated that it
should be optional for hospitals because not all vendors may be able to
support the implementation of this measure.
- Public comments received: 9
Rationale for measure provided by HHS
An analysis of the Food and
Drug Administration’s (FDA) Adverse Drug Event Reporting System found that
warfarin ranked seventh overall in drugs identified to cause death, disability,
or other serious adverse outcomes (Moore, Cohen, & Furberg, 2007). Evidence
suggests that low INR (INR < 2) is associated with an increased risk of
stroke and high INR (INR > 3) is associated with increased risk of bleeding
(Reynolds, 2004). A study by White et al. (2007) found that patients with poor
INR control suffered higher rates of mortality and major bleeding when compared
to those with good or moderate INR control. Patients in the transition period
from hospital to home are at particular risk for adverse events from medication
errors in general, and for warfarin in particular, as they move from a tightly
controlled environment to one with limited supervision and support (Forster et
al., 2005). A timely INR test shortly after hospital discharge is expected to
lead to the stabilization of the patient’s warfarin regimen and avoidance of
non-therapeutic INR levels and, therefore, result in fewer warfarin-related
bleeding, thromboembolic events, and lower mortality. The 2012 American College
of Chest Physicians guidelines for antithrombotic therapy and prevention of
thrombosis recommend INR monitoring within 1-2 weeks for patients with a
sub-therapeutic or supra-therapeutic INR (Holbrook et al., 2012). Three recent
studies have been published on INR monitoring after hospital discharge and/or
INR monitoring after an out-of-range value. In a population-based sample of
Canadian patients on warfarin (Van Walraven et al., 2007), hospitalization was
associated with less time in the therapeutic range, more time with INR <1.5,
and more time with INR >=5.0. Qualls et al. (2013) compared patients with
heart failure with and without at least one INR test within 45 days of discharge
and found that those who had been tested had lower risks of mortality and
myocardial infarction one year after discharge. Finally, in a study of patients
in VA anticoagulation clinics (Rose et al., 2011), longer follow-up intervals
for repeat tests after both INR values above and below the therapeutic range
were found to be associated with worse control of anticoagulation among
ambulatory patients at the clinic level. Food and Drug Administration. (2011).
Warfarin (Coumadin) product labeling. Reference ID 3022954. Retrieved Oct. 16,
2013, from
http://www.accessdata.fda.gov/drugsatfda_docs/label/2011/009218s107lbl.pdf
Forster, A. J., Murff, H. J., Peterson, J. F., Gandhi, T. K., & Bates, D. W.
(2005). Adverse drug events occurring following hospital discharge. Journal of
General Internal Medicine, 20(4), 317–323. Holbrook, A., Schulman, S., Witt, D.
M., Vandvik, P. O., Fish, J., Kovacs, M. J., ... & Guyatt, G. H. (2012).
Evidence-based management of anticoagulant therapy: antithrombotic therapy and
prevention of thrombosis: American College of Chest Physicians evidence-based
clinical practice guidelines. CHEST Journal, 141(2_suppl), e152S-e184S. Moore,
T. J., Cohen, M. R., & Furberg, C. D. (2007). Serious adverse drug events
reported to the Food and Drug Administration, 1998-2005. Archives of Internal
Medicine, 167(16), 1752-1759. Qualls, L. G., Greiner, M. A., Eapen, Z. J.,
Fonarow, G. C., Mills, R. M., Klaskala, W., . . . Curtis, L. H. (2013).
Postdischarge international normalized ratio testing and long-term clinical
outcomes of patients with heart failure receiving warfarin: Findings from the
ADHERE registry linked to Medicare claims. Clinical Cardiology, 36(12), 757-765.
Reynolds, M. W., Fahrbach, K., Hauch, O., Wygant, G., Estok, R., Cella, C.,
& Nalysnyk, L. (2004). Warfarin anticoagulation and outcomes in patients
with atrial fibrillation: a systematic review and metaanalysis. CHEST Journal,
126(6), 1938-1945. Rose, A. J., Ozonoff, A., Henault, L. E., & Hylek, E. M.
(2008). Warfarin for atrial fibrillation in community-based practise. Journal of
Thrombosis and Haemostasis, 6(10), 1647-1654. Van Walraven, C., Austin, P. C.,
Oake, N., Wells, P., Mamdani, M., Forster, A. J. (2007). The effect of
hospitalization on oral anticoagulation control: A population-based study.
Thrombosis Research 119(6), 705–714. White, H. D., M. Gruber, Feyzi, J., Kaatz,
S., Tse, H. F., Husted, S., et al. (2007). Comparison of outcomes among patients
randomized to warfarin therapy according to anticoagulant control: results from
SPORTIF III and V. Archives of Internal Medicine, 167(3), 239-245.
Measure Specifications
- NQF Number (if applicable): 2732
- Description: Percentage of adult inpatient hospital discharges to
home for which the individual was on warfarin and discharged with a
non-therapeutic International Normalized Ratio (INR) who had an INR test
within 14 days of hospital discharge
- Numerator: Individuals in the denominator who had an INR test
within 14 days of discharge
- Denominator: Adult inpatient discharges to home for which the
individual had active warfarin therapy within 1 day prior to discharge and the
last monitored INR within 7 days of discharge was <=1.5 or >=
4
- Exclusions: 1) Inpatient discharges for which the individuals
received dabigatran, rivaroxaban, or apixaban within one day prior to
discharge 2) Inpatient discharges for which the individuals are monitoring
INR at home 3) Inpatient discharges for which the individuals expired within
14 days post-discharge 4) Inpatient discharges for which the individuals
received hospice care within 14 days post-discharge 5) Inpatient discharges
for which the individuals had a hospital inpatient admission within 14 days
post-discharge 6) Inpatient discharges for which the individuals were
admitted to a skilled nursing facility (SNF) within 14 days post-discharge 7)
Inpatient discharges for which the end date of the 14-day follow-up period
occurs after the end of the measurement period 8) Inpatient discharges for
which the individual is not enrolled in Medicare Part A and Part B at the time
of discharge and during the 14-day follow-up period post
discharge.
- HHS NQS Priority: Making Care Safer
- HHS Data Source: Hybrid: This measure is specified in part as an
electronic clinical quality measure. Some data elements in the denominator and
exclusions used to calculate the measure score are taken from the EHR.
Portions of the denominator, most exclusions, and the numerator are derived
from administrative claims.
- Measure Type: Process
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Submitted
- Is the measure specified as an electronic clinical quality measure?
Yes
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Patient Safety 2015
(Draft report available as of 9/17/15)
- Review for Importance: The measure meets the Importance criteria
(1a. Evidence, 1b. Performance Gap) 1a. Evidence: 7-H; 11-M; 3-L; 0-I; 1b.
Performance Gap: 7-H; 12-M; 2-L; 0-I; Rationale: · The developers provided
several studies and a systematic review that support the measure
specifications and its importance to measure. · There were concerns about the
measures therapeutic range based on the evidence provided by the developers as
well as the number of days for follow-up. · The developers show that there is
a mean performance rate of about 50 percent, which indicates there is a
performance gap.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria (2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity) 2a. Reliability: 3-H;
15-M; 3-L; 0-I 2b. Validity: 3-H; 12-M; 5-L; 0-I Rationale: · Seven hospitals
were assessed and five of them had scores that were at the acceptable
threshold for reliability. Two of the seven that had smaller sample sizes were
below the specified threshold. · Validity testing was done with empirical
testing at the data element and performance score measure. · 97.8% of the data
elements found in the medical record correctly matched the EHR data extract
received from the participating hospitals. The data element with the lowest
criterion validity score (<95%) was the “discharge status” at 91.4%. ·
There were concerns about the patients that are readmitted or died during the
follow-up period and how that would be a threat to validity. The developers
noted that the onus is no longer on the hospital to do a follow-up for the
first encounter once they have been readmitted and there are not enough
patients who die to have a significant impact on the measure.
- Review for Feasibility: 8-H; 11-M; 1-L; 0-I (3a. Clinical data
generated during care delivery; 3b. Electronic sources; 3c.Susceptibility to
inaccuracies/ unintended consequences identified 3d. Data collection strategy
can be implemented) Rationale: · Data are drawn from claims and EMR and it
seems to be done successfully.
- Review for Usability: 3-H; 16-M; 1-L; 0-I (Meaningful,
understandable, and useful to the intended audiences for 4a. Public
Reporting/Accountability and 4b. Quality Improvement) Rationale: · The measure
is intended to be used in public reporting programs as well as internal and
external quality improvement and bench marking. · There were concerns about
how the measure could be applied in settings outside of those provided by the
developers and level for responsibility of the provider for
follow-up.
- Review for Related and Competing Measures: This measure is related
to the following measures: o 0555 : INR Monitoring for Individuals on Warfarin
o 0556 : INR for Individuals Taking Warfarin and Interacting Anti-Infective
Medications o 0586 : Warfarin_PT/ INR Test · It is harmonized with 0555 and
0556. · Measure 0586 is potentially competing, but the Committee did not
discuss this issue since 0586 is not currently under review.
- Endorsement Public Comments: Not yet available
- Endorsement Committee Recommendation: Standing Committee
Recommendation for Endorsement: 18-Y; 2-N
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because it
adds little value to this measure set since VBAC rates would be calculated
using only CMS claims data.
- Public comments received: 8
Rationale for measure provided by HHS
The evidence supporting VBAC
is robust and well-summarized in the ACOG and AAFP guidelines.
Measure Specifications
- NQF Number (if applicable):
- Description: Vaginal births per 1,000 deliveries by patients with
previous Cesarean deliveries. Excludes deliveries with complications (abnormal
presentation, preterm delivery, fetal death, multiple gestation diagnoses, or
breech procedure).
- Numerator: Number of vaginal deliveries, identified by DRG or
MS-DRG code, among cases meeting the inclusion and exclusion rules for the
denominator. DRG codes: 372, 373, 374, 375 MS-DRG codes: 767, 768, 774,
775
- Denominator: All deliveries identified by DRG or MS-DRG code, with
any-listed ICD-9-CM diagnosis codes for previous Cesarean delivery. DRG
codes: 370, 371, 372, 373, 374, 375 MS-DRG codes: 765, 766, 767, 768, 774,
775
- Exclusions: Exclude cases: • with any-listed ICD-9-CM diagnosis
codes for abnormal presentation, preterm, fetal death, or multiple gestation
• with any-listed ICD-9-CM procedure codes for breech • with missing gender
(SEX=missing), age (AGE=missing), quarter (DQTR=missing), year (YEAR=missing)
or principal diagnosis (DX1=missing) See Inpatient Quality Indicators
Appendices: • Appendix A – Abnormal Presentation, Preterm, Fetal Death and
Multiple Gestation Diagnosis Codes • Appendix B – Breech Procedure Codes
(available here:
http://www.qualityindicators.ahrq.gov/Downloads/Modules/IQI/V50/TechSpecs/IQI_Appendices.pdf)
- HHS NQS Priority: Making Care Safer, Patient and Family Engagement,
Communication and Care Coordination
- HHS Data Source: Administrative clinical data
- Measure Type: Outcome
- Steward: Agency for Healthcare Research & Quality
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending the Centers
for Disease Control recommendation that the measure is ready for use in public
reporting, and pending resubmission to MAP for review of implementation data
- Workgroup Rationale: MAP conditionally supported this measure since
the measure developer stated that the measure is intended for use in the
National Healthcare Safety Network (NHSN) and wishes to gain greater
experience and gather more information before using it for reporting or
payment. MAP recognized the high importance of antimicrobial stewardship and
conditionally support the inclusion of this measure in the IQR program to
allow for the opportunity for additional testing to address feasibility
issues. However, MAP noted these issues should be addressed before the measure
is reported on Hospital Compare.
- Public comments received: 10
Rationale for measure provided by HHS
Numerous individual studies
and systematic reviews provide strong evidence that measurement of antimicrobial
use and data-driven interventions by antimicrobial stewardship programs (ASPs)
lead to more judicious use of antibiotics, reduced antimicrobial resistance, and
other favorable healthcare outcomes (Feazel 2014; Davey 2006; Davey 2013; Kaki
2011). Antimicrobial use measurement enables ASPs to understand prescribing
practices, focus efforts on improvement, and determine the impact of their
activities (Pollack, 2014). Although standardized metrics have been developed to
measure antibiotic use, differences in measurement, limited uptake, and
variation among facilities has impeded the ability to compare antibiotic use
among hospitals. The measure will serve as a quantitative guide for hospital
and health system ASPs, enabling them to benchmark antibiotic use in their
facilities and patient care locations against nationally aggregated data. The
measure focuses on antibiotic agents that have been shown to be high value
targets for antimicrobial stewardship programs activities such as protocols for
use or post-prescription reviews to determine need for de-escalation,
dose-optimization or oral conversion. Knowledge about antibiotic use patterns of
these agents is a primary means to prioritize and evaluate antimicrobial
stewardship efforts.
Measure Specifications
- NQF Number (if applicable): 2720
- Description: Assesses antimicrobial use (AU) in hospitals based on
medication administration data hospitals collect electronically at the point
of care and report via electronic file submissions to NHSN. AU data included
in the measure are antibacterial agents administered to adult and pediatric
patients in a specified set of hospital ward and intensive care unit
locations.
- Numerator: Days of antimicrobial therapy for antibacterial agents
administered to adult and pediatric patients in medical, medical/surgical, and
surgical wards and medical, medical/surgical, and surgical intensive care
units.
- Denominator: Days present for each patient care location—adult and
pediatric medical, medical/surgical, and surgical wards and adult and
pediatric medical, medical/surgical, and surgical intensive care units—is
defined as the number of patients who were present for any portion of each day
of a calendar month for each location. The day of admission, discharge, and
transfer to and from locations are included in days present. All days present
are summed for each location and month, and the aggregate sums for each
location-month combination comprise the denominator data for the
measure
- Exclusions: Hospital patient care locations other than adult and
pediatric medical, medical/surgical, and surgical wards and adult and
pediatric medical, medical/surgical, and surgical intensive care units are
excluded from this measure.
- HHS NQS Priority: Making Care Safer, Effective Prevention and
Treatment
- HHS Data Source: National Healthcare Safety Network
- Measure Type: Process
- Steward: Centers for Disease Control and Prevention
- Endorsement Status: Submitted – In the measure submission form it
is stated that “The measure is being submitted for public health surveillance
for quality measurement and improvement, not for public reporting or payment;
the developer wishes to gain greater experience and gather more information
before using it for reporting or payment. It is intended for use in the
National Healthcare Safety Network.” The Patient Safety committee recommended
this measure for endorsement and it is currently in the voting
phase.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Support
- Workgroup Rationale: MAP supported this measure because the PSI
measures were developed to identify harmful healthcare related events that are
potentially preventable. Three additional PSIs have been added to this updated
version of the measure. PSIs were better linked to important changes in
clinical status with “harm weights” that are based on diagnoses that were
assigned after the complication. This is intended to allow the measure to more
accurately reflect the impact of the events.
- Public comments received: 10
Rationale for measure provided by HHS
Each measure used within the
PSI 90 composite is an outcome measure that has been shown to be largely
preventable through improved structures and processes of care. Each measure has
an evidence review form as part of the NQF endorsement process. The literature
to support each measure is updated on a schedule basis.
Measure Specifications
- NQF Number (if applicable): 531
- Description: Patient Safety and Adverse Events Composite (Patient
Safety Indicator, or PSI90) is a composite measure of 10 individual PSIs, each
measuring a different aspect of harm associated with patient safety. Each PSI
is reliability-adjusted (smoothed) and indirectly standardized (risk
adjusted). The composite is the weighted average of the reliability-adjusted,
indirectly standardized, observed-to-expected ratios for component indicators.
The final weight for each component is the product of harm weights and volume
weights (numerator weights). Harm weights are calculated by multiplying
empirical estimates of excess harms associated with the patient safety event
by utility weights linked to each of the harms. Excess harms are estimated
using statistical models comparing patients with a safety-related event to
those without that safety-related event in a CMS Medicare fee-for-service
sample that allowed up to one year of follow-up from the discharge date of the
hospital stay associated with the index event. Volume weights, the second part
of the final weight, are calculated on the basis of the number of
safety-related events for the component indicators in the all-payer reference
population. The observed to expected ratios (indirect standardization) of the
reliability adjusted (smoothed) rates are multiplied by a component weight and
the weighted scores are summed to determine the final PSI 90 score. A score of
1 means that the hospital performs as expected, scores greater than one
indicate worse performance than expected.
- Numerator: Below we list the numerator values for the composite
components. The composite score is calculated as a ratio of the weighted
observed to expected ratios for each of the components. PSI03-Pressure Ulcer
Rate- Discharges, among cases meeting the inclusion and exclusion rules for
the denominator, with any secondary ICD-9-CM diagnosis codes for pressure
ulcer and any secondary ICD-9-CM diagnosis codes for pressure ulcer stage III
or IV (or unstageable). PSI06-Iatrogenic Pneumothorax Rate- Discharges,
among cases meeting the inclusion and exclusion rules for the denominator,
with any secondary ICD-9-CM diagnosis codes for iatrogenic pneumothorax.
PSI08-Postoperative Hip Fracture Rate- Discharges, among cases meeting the
inclusion and exclusion rules for the denominator, with any secondary ICD-9-CM
diagnosis codes for hip fracture. PSI09-Perioperative Hemorrhage and
Hematoma Rate- Discharges, among cases meeting the inclusion and exclusion
rules for the denominator, with either: • any secondary ICD-9-CM diagnosis
codes for perioperative hemorrhage or hematoma and any-listed ICD-9-CM
procedure codes for control of perioperative hemorrhage or evacuation of
hematoma. PSI10-Postoperative Acute Kidney Injury Rate- Discharges, among
cases meeting the inclusion and exclusion rules for the denominator, with
either: • any secondary ICD-9-CM diagnosis codes for acute renal failure and
any-listed ICD-9- CM procedure codes for dialysis. PSI11-Postoperative
Respiratory Failure Rate- Discharges, among cases meeting the inclusion and
exclusion rules for the denominator, with either: • any secondary ICD-9-CM
diagnosis code for acute respiratory failure; or • any-listed ICD-9-CM
procedure codes for a mechanical ventilation for 96 consecutive hours or more
that occurs zero or more days after the first major operating room procedure
code (based on days from admission to procedure); or • any-listed ICD-9-CM
procedure codes for a mechanical ventilation for less than 96 consecutive
hours (or undetermined) that occurs two or more days after the first major
operating room procedure code (based on days from admission to procedure); or
• any-listed ICD-9-CM procedure codes for a reintubation that occurs one or
more days after the first major operating room procedure code (based on days
from admission to procedure). PSI12-Perioperative Pulmonary Embolism and
Deep Vein Thrombosis Rate- Discharges, among cases meeting the inclusion and
exclusion rules for the denominator, with a secondary ICD-9-CM diagnosis code
for deep vein thrombosis or a secondary ICD-9-CM diagnosis code for pulmonary
embolism (omitting cases from the numerator with isolated calf vein DVT).
PSI13-Postoperative Sepsis Rate- Discharges, among cases meeting the inclusion
and exclusion rules for the denominator, with any secondary ICD-9-CM diagnosis
codes for sepsis. PSI14-Postoperative Wound Dehiscence Rate-Discharges,
among cases meeting the inclusion and exclusion rules for the denominator,
with any-listed ICD-9-CM procedure codes for reclosure of postoperative
disruption of the abdominal wall. PSI15-Unrecognized Abdominopelvic
Accidental Puncture or Laceration Rate -Discharges, among cases meeting the
inclusion and exclusion rules for the denominator, with any secondary ICD-9-CM
diagnosis codes for accidental puncture or laceration during a procedure and
second abdominopelvic operation 1 day or more after the index
procedure.
- Denominator: Below we list the denominator values for the composite
components. The composite score is calculated as a ratio of the weighted
observed to expected ratios for each of the components. PSI03-Pressure Ulcer
Rate- Surgical and medical discharges, for patients ages 18 years and older.
Surgical and medical discharges are defined by specific DRG or MS-DRG codes.
PSI06-Iatrogenic Pneumothorax Rate- Surgical and medical discharges, for
patients ages 18 years and older. Surgical and medical discharges are defined
by specific DRG or MS-DRG codes. PSI08-Postoperative Hip Fracture Rate-
Surgical discharges, ages 18 years and older, with any-listed ICD-9-CM
procedure codes for an operating room procedure. Surgical discharges are
defined by specific DRG or MS-DRG codes. PSI09-Perioperative Hemorrhage and
Hematoma Rate- Surgical discharges, for patients ages 18 years and older,
with any-listed ICD-9-CM procedure codes for an operating room procedure.
Surgical discharges are defined by specific DRG or MS-DRG codes.
PSI10-Postoperative Acute Kidney Injury Rate- Elective surgical discharges,
for patients ages 18 years and older, with any-listed ICD-9-CM procedure codes
for an operating room procedure. Elective surgical discharges are defined by
specific DRG or MS-DRG codes with admission type recorded as elective (SID
ATYPE=3). PSI11-Postoperative Respiratory Failure Rate- Elective surgical
discharges, for patients ages 18 years and older, with any-listed ICD-9-CM
procedure codes for an operating room procedure. Elective surgical discharges
are defined by specific DRG or MS-DRG codes with admission type recorded as
elective (SID ATYPE=3). PSI12-Perioperative Pulmonary Embolism and Deep Vein
Thrombosis Rate- Surgical discharges, for patients ages 18 years and older,
with any-listed ICD-9-CM procedure codes for an operating room procedure.
Surgical discharges are defined by specific DRG or MS-DRG codes.
PSI13-Postoperative Sepsis Rate- Elective surgical discharges, for patients
ages 18 years and older, with any-listed ICD-9-CM procedure codes for an
operating room procedure. Elective surgical discharges are defined by specific
DRG or MS-DRG codes with admission type recorded as elective (SID ATYPE=3).
PSI14-Postoperative Wound Dehiscence Rate- Discharges, for patients ages 18
years and older, with any-listed ICD-9-CM procedure codes for abdominopelvic
surgery. PSI15-Unrecognized Abdominopelvic Accidental Puncture or Laceration
Rate- Patients ages 18 years and older with any procedure code for an
abdominopelvic procedure.
- Exclusions: Below we list the exclusions for the composite
components. There are no additional exclusions for the composite measure as a
whole. PSI03 – Pressure Ulcer Rate-Excludes cases with length of stay less
than 5 days, with a principal diagnosis of pressure ulcer or secondary
diagnosis of pressure ulcer present on admission, cases with evidence of
hemiplegia, paraplegia or quadriplegia, spina bifida, anoxic brain damage,
debridement or pedicle graft on the same day as the major operating room
surgery or as the only major operating room procedure, and cases that were
transferred from a different hospital or skilled nursing facility, and cases
with MDC (major diagnostic classification) of 9 (skin, subcutaneous and
breast) or 14 (pregnancy, childbirth and puerperium). PSI06 – Iatrogenic
Pneumothorax Rate - Excludes cases with a principal diagnosis for iatrogenic
pneumothorax or secondary diagnosis of iatrogenic pneumothorax on admission,
cases with evidence of chest trauma, pleural effusion, thoracic surgery, lung
or pleural biopsy, diaphragmatic repair, cardiac procedure, and cases with MDC
(major diagnostic classification) of 14 (pregnancy, childbirth and
puerperium). PSI08 – Postoperative Hip Fracture Rate-Excludes cases with
principal diagnosis of hip fracture or a secondary diagnosis of hip fracture
on admission, cases where the only operating room procedure is hip fracture,
where the procedure for hip fracture occurs before or on the same day as the
first operating room procedure, and cases with a principal diagnosis of
seizure, syncope, stroke and occlusion of arteries, coma, cardiac arrest,
poisoning, trauma, delirium and other psychoses, anoxic brain injury,
metastatic cancer, lymphoid malignancy, bone malignancy, self-inflicted
injury, and cases with MDC (major diagnostic classification) of 8
(musculoskeletal system and connective tissue) or 14 (pregnancy, childbirth
and puerperium). PSI09 – Perioperative Hemorrhage and Hematoma Rate -
Excludes cases with principal diagnosis of perioperative hemorrhage or
postoperative hematoma or secondary diagnosis present of perioperative
hemorrhage on admission, cases where the only operating room procedure is
control of postoperative hemorrhage, drainage of hematoma or miscellaneous
hemorrhage- or hematoma-related procedure, any secondary diagnosis of
perioperative hemorrhage or postoperative hematoma and any-listed procedure
codes for control of perioperative hemorrhage or evacuation of hematoma or
miscellaneous hemorrhage- or hematoma- related procedure occurring before the
first operating room procedure, cases with diagnosis of coagulation disorder
and cases with MDC (major diagnostic classification) of 14 (pregnancy,
childbirth and puerperium). PSI10 – Postoperative Acute Kidney
Injury-Excludes cases with a principal diagnosis or secondary diagnosis on
admission of acute renal failure, acute myocardial infarction, cardiac
arrhythmia, cardiac arrest, shock, hemorrhage, gastrointestinal hemorrhage, or
chronic renal failure, cases with dialysis procedure before on the same day as
the first operating procedure and cases with MDC (major diagnostic
classification) of 14 (pregnancy, childbirth and puerperium). PSI11 –
Postoperative Respiratory Failure Rate - Excludes cases with principal
diagnosis or secondary diagnosis on admission of acute respiratory failure,
cases where the only operating procedure is tracheostomy or a tracheostomy
occurs before the first operating procedure, cases with any listed diagnosis
of neuromuscular disorder, craniofacial anomalies or degenerative neurological
disorder, cases with any listed procedure of laryngeal or pharyngeal, nose,
mouth, or pharynx surgery, procedures involving the face, esophageal
resection, procedures for lung cancer, and cases with MDC (major diagnostic
classification) of 4 (disease of respiratory system), 5 (diseases of the
circulatory system), or 14 (pregnancy, childbirth and puerperium). PSI12 –
Perioperative Pulmonary Embolism and Deep Vein Thrombosis Rate - Excludes
cases with principal diagnosis or secondary diagnosis on admission of DVT,
pulmonary embolism, cases where a procedure for interruption of vena cava
occurs before or on the same day as the first operating room procedure, cases
with any procedure for extracorporeal membrane oxygenation, and cases with MDC
(major diagnostic classification) of 14 (pregnancy, childbirth and
puerperium). PSI13 – Postoperative Sepsis Rate – Excludes cases with
principal diagnosis or secondary diagnosis on admission of sepsis, infection,
cases with evidence of immunocompromised state or cancer, cases with a length
of stay less than 4 days, and cases with MDC (major diagnostic classification)
of 14 (pregnancy, childbirth and puerperium). PSI14 – Postoperative Wound
Dehiscence Rate – Excludes cases with any listed evidence of immunocompromised
state, cases where the procedure for abdominal wall reclosure occurs on or
before the day of the first abdominopelvic surgery procedure, cases with a
length of stay less than 2 days, and cases with MDC(major diagnostic
classification) of 14 (pregnancy, childbirth and puerperium). PSI15 –
Unrecognized Abdominopelvic Accidental Puncture or Laceration Rate-Excludes
cases with a principal diagnosis or secondary diagnosis at admission of
accidental puncture or laceration during a procedure and cases with MDC (major
diagnostic classification) of 14 (pregnancy, childbirth and
puerperium).
- HHS NQS Priority: Making Care Safer
- HHS Data Source: Administrative claims Component measures require:
ICD-9 diagnosis and procedure codes, MDC, MSDRG, procedure day, age in year,
gender, admission type, discharge disposition. All are drawn from
administrative data.
- Measure Type: Composite
- Steward: Agency for Healthcare Research & Quality
- Endorsement Status: Endorsed; MUC same as endorsed version:Yes.
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Patient Safety
2015
- Review for Importance: The measure meets the Importance criteria
(1a. Evidence, 1b. Performance Gap) 1a. Evidence: 16-Y; 8-N I; 1b. Performance
Gap: 9-H; 9-M; 6-L; 0-I; 1c. Composite- Quality Construct and Rationale: 6-H;
7-M; 11-L; 0-I Rationale: · The Committee agreed that the outcomes in this
measure were associated with one or more healthcare actions. However, there
was concern that some of the elements of the composite had variable
preventability. · The developers reported that the items within the composite
are positively correlated. The correlations range in the low 0.08 up to the
30s (not very high). · The developers referenced several processes of care
that are associated with lower rates for each of the components in the
composite.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria (2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity) 2a. Reliability: 4-H;
10-M; 9-L; 1-I 2b. Validity: 2-H; 11-M; 7-L; 2-I 1c. Composite Construction:
4-H; 12-M; 7-L; 1-I Rationale: · The Committee agreed that the updated version
of the measure provided by AHRQ was improved from the 2014 version reviewed by
the Committee, specifically noting that the new weighting focusing on harm
rather than just the frequency of events, was more clinically relevant than
the previous version of the measure. · During reliability testing, the
developers examined the true difference rather than random chance and noise.
Their results show a reliability scores in the 70s, which is comparable to
other endorsed measures · Aggregating a number of individual measures into a
single composite can generate an overall performance score that is more
reliable than if the individual measure scores were taken in isolation. ·
Empirical field validity testing was conducted at the performance measure
score level for the overall composite by correlating the composite scores with
the rates calculated from the 3M Potentially Preventable Readmissions measure.
.The Pearson correlation value, was 0.11 with a p-value of
<0.0001.
- Review for Feasibility: 12-H; 8-M; 3-L; 1-I (3a. Clinical data
generated during care delivery; 3b. Electronic sources; 3c.Susceptibility to
inaccuracies/ unintended consequences identified 3d. Data collection strategy
can be implemented) Rationale: · The Committee had no concerns about the
feasibility of this measure given that it is gathered with administrative
claims data.
- Review for Usability: 12-H; 6-M; 6-L; 0-I (Meaningful,
understandable, and useful to the intended audiences for 4a. Public
Reporting/Accountability and 4b. Quality Improvement) Rationale: · There were
concerns about the use of this measure in value-based purchasing, despite the
improvements the developer has made, because may not accurately reflect that
an actual preventable complication occurred or may focus on preventing
measured events that are less clinically important. · This measure is used to
monitor performance in national and regional reporting. It was also developed
to enable comparative reporting and quality improvement at the provider or the
hospital level.
- Review for Related and Competing Measures: Concerns were raised by
the Committee that some of the elements of this measure, notably the central
line related blood stream infections and post-operative hip fracture, may be
better captured in other NQF approved measures rather than using
administrative claims data. In addition, this measure is related to NQF 532,
which is the pediatric version of the same measure 0347.
- Endorsement Public Comments: Summary pending
- Endorsement Committee Recommendation: 14-Y; 10-N
Since 58% of the Committee voted to recommend this measure, it did not
achieve consensus. It will move forward to the comment period and the
Committee will discuss and revote after the public comment.
This measure was last endorsed in 2009; it is a composite measure of 11
inpatient Patient Safety Indicators. In 2014 the Committee raised concerns
about the weighting of the various components of the composite, specificially
that some of the more heavily weighted components were less clinically
significant (i.e., accidental punctures and lacerations) and/or less
preventable. In addition, there were concerns that the events measured are not
always reflective of an actual patient safety event that resulted in
preventable patient harm. To address the concerns of the 2014 Committee, AHRQ
made several updates to the measure to address the Committee’s concerns.
- Additional PSIs were included (from 8 events to 11 events, which
expanded the type of complications included this measure),
- Two of the component PSIs were redesigned; specifically PSI 12 with the
removal of isolated calf deep vein thromboses (DVT) which have limited
clinical relevance and PSI 15 with a greater focus on accidental punctures
and lacerations that occur during abdominal/pelvic surgery and those that
result in re-operation within one day which reflect events that are more
likely preventable, and
- The measure was modified to more accurately reflect the impact of the
events by better linking the PSIs to important changes in clinical status
with “harm weights” that are based on diagnoses that were assigned after the
complication.
The Committee agreed that the changes to the measure were highly responsive
to the concerns raised during the 2014 Committee discussion. However, new
concerns were raised: some post-operative DVT or other events included in the
composite may not be preventable; the definition of ICD-9 based central line
related blood stream infections may be less precise than other definitions
(i.e., NHSN which reports the information differently); and concerns about
this measure being included in value-based purchasing programs particularly
when it is likely that not all of these events are preventable and that it may
distract from efforts to reduce more impactful safety events. In addition,
there were concerns that some of the indicators of the measure may not reflect
preventable patient safety events because it comes from ICD-9 data of
inpatient complications, which sometimes did not directly reflect that an
actual preventable complication occurred in the validation of the components
of the composite. During the vote, the Committee agreed that the measure meets
the four NQF criteria; however, consensus was not reached on a recommendation
for endorsement (58% yes, 42% no). The Committee will re-consider the
recommendation for endorsement after reviewing the public
comments.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because
although cost is important to measure, data supporting variation in costs for
this procedure was not provided. The group also noted that measuring resource
use (cost) is different from appropriateness of care; the cost of a service is
not indicative of quality care.
- Public comments received: 9
Rationale for measure provided by HHS
Episode-based performance
measurement allows meaningful comparisons between providers based on resource
use for certain clinical conditions or procedures, as noted in the NQF report
for the “Episode Grouper Evaluation Criteria” project (available at
http://www.qualityforum.org/Publications/2014/09/Evaluating_Episode_Groupers__A_Report_from_the_National_Quality_Forum.aspx)
and in various peer-reviewed articles (e.g., Hussey, P. S., Sorbero, M. E.,
Mehrotra, A., Liu, H., & Damberg, S. L. (2009). Episode-Based Performance
Measurement and Payment: Making It a Reality. Health Affairs, 28(5), 1406-1417.
doi:10.1377/hlthaff.28.5.1406). While reliability analyses have been conducted
on similar performance measures, we plan to conduct our own reliability analysis
for this specific measure and propose a minimum number of cases for reporting.
The analysis will likely mirror the 2012 MSPB reliability analysis:
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/hospital-value-based-purchasing/Downloads/MSPBReliabilityAnalysis-Jul-18-12.pdf
Measure Specifications
- NQF Number (if applicable):
- Description: The measure constructs a clinically coherent group of
services to inform providers about resource use and effectiveness. It sums
Parts A and B payments related to a Spinal Fusion IP stay and attributes them
to the hospital where the index IP stay occurred.
- Numerator: The numerator of the Spinal Fusion Clinical
Episode-Based Payment Measure is the risk-adjusted sum of a provider’s
spending and the preadmission and post-discharge medical services that are
clinically related to spinal fusions across a hospital’s eligible Spinal
Fusion episodes during the period of performance. A clinical episode begins 3
days prior to the initial (i.e., index) admission and extends 30 days
following the index hospital stay discharge date.
- Denominator: A count of the provider’s condition-specific episodes
during the period of performance.
- Exclusions: Episode Exclusions: 1. Beneficiaries who do not have
continuous enrollment in Medicare Parts A and B from 90 days prior to IP
admission through the end of the episode with Medicare as the primary payer.
2. Beneficiaries who enroll in Medicare Advantage during the period that
starts 90 days prior to IP admission through the end of the
episode.
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: Claims
- Measure Type: Efficiency
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because
although cost is important to measure, data supporting variation in costs for
this procedure was not provided. The group also noted that measuring resource
use (cost) is different from appropriateness of care; the cost of a service is
not indicative of quality care.
- Public comments received: 5
Rationale for measure provided by HHS
Episode-based performance
measurement allows meaningful comparisons between providers based on resource
use for certain clinical conditions or procedures, as noted in the NQF report
for the “Episode Grouper Evaluation Criteria” project (available at
http://www.qualityforum.org/Publications/2014/09/Evaluating_Episode_Groupers__A_Report_from_the_National_Quality_Forum.aspx)
and in various peer-reviewed articles (e.g., .Hussey, P. S., Sorbero, M. E.,
Mehrotra, A., Liu, H., & Damberg, S. L. (2009). Episode-Based Performance
Measurement and Payment: Making It a Reality. Health Affairs, 28(5), 1406-1417.
doi:10.1377/hlthaff.28.5.1406). While reliability analyses have been conducted
on similar performance measures, we plan to conduct our own reliability analysis
for this specific measure and propose a minimum number of cases for reporting.
The analysis will likely mirror the 2012 MSPB reliability analysis:
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/hospital-value-based-purchasing/Downloads/MSPBReliabilityAnalysis-Jul-18-12.pdf
Measure Specifications
- NQF Number (if applicable):
- Description: The measure constructs a clinically coherent group of
services to inform providers about resource use and effectiveness. It sums
Parts A and B payments related to a TURP IP stay and attributes them to the
hospital where the index IP stay occurred.
- Numerator: The numerator of the TURP Clinical Episode-Based Payment
Measure is the risk-adjusted sum of a provider’s spending and the preadmission
and post-discharge medical services that are clinically related to the TURPs
across a hospital’s eligible TURP episodes during the period of performance. A
clinical episode begins 3 days prior to the initial (i.e., index) admission
and extends 30 days following the index hospital stay discharge
date.
- Denominator: A count of the provider’s condition-specific episodes
during the period of performance.
- Exclusions: Episode Exclusions: 1. Beneficiaries who do not have
continuous enrollment in Medicare Parts A and B from 90 days prior to IP
admission through the end of the episode with Medicare as the primary payer.
2. Beneficiaries who enroll in Medicare Advantage during the period that
starts 90 days prior to IP admission through the end of the
episode.
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: Claims
- Measure Type: Efficiency
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF review
and endorsement, with a consideration for CDP standing committee to consider
the exclusions and risk-adjustment
- Workgroup Rationale: MAP conditionally supported the measure,
recommending that the measure be submitted for NQF endorsement with a special
consideration for SDS adjustments and the selection of exclusions. MAP members
noted the potential for the measure to increase care coordination and spur
patient activation.
- Public comments received: 7
Rationale for measure provided by HHS
Cancer patients receiving
chemotherapy have much higher rates of admissions and ED use than other
patients. A study of 2007 commercial claims data for more than 14 million
patients found that cancer patients average one admission per year; 40 percent
of those admissions were chemotherapy related (Kolodziej et al. 2011). The
authors also found that cancer patients average approximately two ED visits per
year, about half of which were chemotherapy related. Common complications of
chemotherapy treatment include nausea, emesis, anemia, neutropenic fever,
diarrhea, dehydration, and pain (Burton et al. 2007; Crawford et al. 2004;
Groopman and Itri 2000; Osoba et al. 1997; Richardson and Dobish 2007; Stein et
al. 2010). Chemotherapy-related admissions and ED visits may be due to
outpatient chemotherapy patients having unmet needs and gaps in care, which, if
addressed, could reduce admissions and ED visits and increase patients’ quality
of life (Hassett et al. 2006; Mayer et al. 2011; McKenzie et al. 2011). Although
it is extremely unlikely that all admissions and ED visits related to
chemotherapy can be avoided by prevention and treatment of side effects and
complications, there is evidence and consensus among providers on ways to
prevent and treat each of the symptoms included in the numerator of this
measure. Measurement of admissions and ED visits for patients receiving
outpatient chemotherapy should encourage reporting facilities to take steps to
prevent and improve management of side effects and complications from treatment.
Poor performance on the measure would reflect high resource use and significant
consequences for patient/society due to poor quality; admissions and ED visits
are costly to payers and reduce quality of life for patients. Burton, A.W.,
G.J. Fanciullo, R.D. Beasley, and M.J. Fisch. “Chronic Pain in the Cancer
Survivor: A New Frontier”. Pain Medicine, vol. 8, 2007, pp. 189–198. Crawford,
J.C., D.C. Dale, and G.H. Lyman. “Chemotherapy-Induced Neutropenia.” Cancer,
vol. 15, 2004, pp. 228–237. Groopman, J.E., and L.M. Itri.
“Chemotherapy-Induced Anemia in Adults: Incidence and Treatment.” Journal of the
National Cancer Institute, vol. 91, 2000, pp. 1616–1634. Hassett, M.J., J.
O’Malley, J.R. Pakes, J.P. Newhouse, and C.C. Earle. “Frequency and Cost of
Chemotherapy-Related Serious Adverse Effects in a Population Sample of Women
with Breast Cancer.” Journal of the National Cancer Institute, vol. 98, no. 16,
2006, pp. 1108–1117. Kolodziej, M., J.R. Hoverman, J.S. Garey, J. Espirito, S.
Sheth, A. Ginsburg, M.A. Neubauer, D. Patt, B. Brooks, C. White, M. Sitarik, R.
Anderson, and R. Beveridge. “Benchmarks for Value in Cancer Care: An Analysis of
a Large Commercial Population.” Journal of Oncology Practice, vol. 7, 2011, pp.
301–306. Mayer, D.K., D. Travers, A. Wyss, A. Leak, A. Waller. “Why Do Patients
with Cancer Visit Emergency Departments? Results of a 2008 Population Study in
North Carolina.” Journal of Clinical Oncology, vol. 26, no. 19, 2011, pp.
2683–2688. McKenzie, H., L. Hayes, K. White, K. Cox, J. Fethney, M. Boughton,
and J. Dunn. “Chemotherapy Outpatients’ Unplanned Presentations to Hospital: A
Retrospective Study.” Support Care Cancer, vol. 19, 2011, pp. 963–969. Osoba,
D., B. Zee, D. Warr, J. Latreilee, L. Kaizer, and J. Pater. “Effect of
Postchemotherapy Nausea and Vomiting on Health-Related Quality of Life.” Support
Care Cancer, vol. 5, 1997, pp. 307–313. Richardson, G., and R. Dobish.
“Chemotherapy Induced Diarrhea.” Journal of Oncology Pharmacy Practice, vol. 13,
no.4, 2007, pp. 181–98. Stein, A., W. Voigt, and K. Jordan.
“Chemotherapy-Induced Diarrhea: Pathophysiology, Frequency, and Guideline-Based
Management.” Therapeutic Advances Medical Oncology, vol. 2, 2010, pp. 51–63.
Measure Specifications
- NQF Number (if applicable):
- Description: Measure estimates risk-adjusted rates of inpatient
admissions or emergency department (ED) visits for cancer patients >18
years of age with at least one of the following diagnoses—anemia, dehydration,
diarrhea, emesis, fever, nausea, neutropenia, pain, pneumonia, or
sepsis—within 30 days of hospital outpatient chemotherapy treatment. Two rates
are reported.
- Numerator: The outcomes for this measure are one or more inpatient
admissions or one or more emergency department (ED) visits for one of the
following diagnoses—anemia, dehydration, diarrhea, emesis, fever, nausea,
neutropenia, pain, pneumonia, or sepsis—within 30 days among cancer patients
receiving a hospital outpatient chemotherapy treatment. Qualifying diagnosis
on the admission or ED visit claim must be listed as (1) the primary diagnosis
or (2) a secondary diagnosis accompanied by a primary diagnosis of cancer.
Outcomes are identified separately for the inpatient and ED categories. A
patient can only qualify for an outcome once. Patients who experience both an
inpatient admission and an ED visit during the measurement period are counted
towards the inpatient admission outcome. Among those with no qualifying
inpatient admissions, qualifying ED visits will be counted. Outcome
Attribution: The outcome is attributed to the hospital outpatient facility
where the patient received chemotherapy treatment during the 30 days prior to
the outcome.
- Denominator: The measure cohort includes Medicare Fee-for-Service
(FFS) patients aged 18 years and older as of the start of the measurement
period with a diagnosis of any cancer (except leukemia) who received at least
one hospital outpatient chemotherapy treatment at the reporting facility
during the measurement period.
- Exclusions: 1) Patients with a diagnosis of leukemia at any time
during the measurement period. 2) Patients who were not enrolled in Medicare
FFS Parts A and B in the year prior to the first outpatient chemotherapy
treatment during the measurement period. 3) Patients who received chemotherapy
treatments for whom Medicare FFS Parts A and B enrollment is not maintained
for the 30-days following treatment for at least one chemotherapy treatment
during the measurement period.
- HHS NQS Priority: Communication and Care Coordination, Effective
Prevention and Treatment
- HHS Data Source: Claims
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Support
- Workgroup Rationale: MAP supported the measure, citing the vital
importance of measures that help facilities reduce unnecessary hospital
visits. Some members cautioned that because the measure was endorsed ny NQF
before the start of the SDS trial period, the measure should be re-examined
during maintenance to determine whether SDS adjustments are
needed.
- Public comments received: 9
Rationale for measure provided by HHS
Nearly 70% of all surgeries
in the US are now performed in the outpatient setting with most performed as
same-day surgeries at HOPDs.[1] While most outpatient surgery is safe, there are
well-described and potentially preventable adverse events that occur after
outpatient surgery, such as uncontrolled pain, urinary retention, infection,
bleeding, and venous thromboembolism, which can result in unanticipated hospital
visits. Similarly, direct admissions after surgery that are primarily caused by
non-clinical patient considerations, such as lack of transport home upon
discharge, or hospital logical issues, such as delayed start of surgery, are
common causes of unanticipated yet preventable hospital admissions following
same-day surgery. Hospital utilization following same-day surgery is an
important and accepted patient-centered outcome reported in the literature.
National estimates of hospital visit rates following surgery vary from 0.5-9.0%
based on the type of surgery, outcome measured (admissions alone or admissions
and emergency department [ED] visits), and timeframe for measurement after
surgery.[2-9] Furthermore, hospital visit rates vary among HOPDs,[7] suggesting
variation in surgical and discharge care quality. However, providers (HOPDs and
surgeons) are often unaware of their patients’ hospital visits after surgery
since patients often present to the ED or to different hospitals.[10] Therefore,
a quality measure of hospital visits following outpatient same-day surgery can
improve transparency, inform patients and providers, and foster quality
improvement. The literature suggests 1.3-13.6% of outpatient surgeries at HOPDs
result in an inpatient admission with the admission rate varying by type of
surgery and HOPD case mix.[3,7-9,11-21] Of these admissions, 40-60% are reported
to be due to adverse effects of the surgery, anesthesia, or due to other
suspected medical problems such as chest pain.[3,7-9,11-21] A smaller proportion
of admissions are due to non-clinical reasons such as lack of transport home or
logistical issues such as delayed start of surgery.[3,7-9,11-19] When
specifically assessed, up to 40% of direct admissions after outpatient surgery
have been found to be preventable.[19] Major and minor adverse events, such as
uncontrolled pain, urinary retention, infection, bleeding, and venous
thromboembolism, are well documented to occur post-discharge and result in
unanticipated hospital visits.[12,13,22] Some hospital visits post-discharge are
for scheduled follow-up care provided after surgery (e.g., visits for
rehabilitation). We remove these ‘planned’ hospital visits from the outcome. We
limit the outcome of hospital visits to 7 days since existing literature
suggests the vast majority of adverse events after surgery occur within the
first 7 days following the surgery.[4,12] We observed in our own data the
highest rates of hospital visits occurring within 7 days of surgery.
References: 1. Cullen KA, Hall MJ, Golosinskiy A. Ambulatory surgery in the
United States, 2006. National health statistics reports. Jan 28 2009(11):1-25.
2. Majholm B, Engbaek J, Bartholdy J, et al. Is day surgery safe? A Danish
multicentre study of morbidity after 57,709 day surgery procedures. Acta
anaesthesiologica Scandinavica. Mar 2012;56(3):323-331. 3. Linares-Gil MJ,
Pelegri-Isanta MD, Pi-Siqués F, Amat-Rafols S, Esteva-Ollé MT, Gomar C.
Unanticipated admissions following ambulatory surgery. Ambulatory Surgery. 12//
1997;5(4):183-188. 4. Fleisher LA, Pasternak LR, Herbert R, Anderson GF.
Inpatient hospital admission and death after outpatient surgery in elderly
patients: importance of patient and system characteristics and location of care.
Archives of surgery (Chicago, Ill. : 1960). Jan 2004;139(1):67-72. 5. Coley KC,
Williams BA, DaPos SV, Chen C, Smith RB. Retrospective evaluation of
unanticipated admissions and readmissions after same day surgery and associated
costs. Journal of clinical anesthesia. Aug 2002;14(5):349-353. 6. Hollingsworth
JM, Saigal CS, Lai JC, Dunn RL, Strope SA, Hollenbeck BK. Surgical quality among
Medicare beneficiaries undergoing outpatient urological surgery. The Journal of
urology. Oct 2012;188(4):1274-1278. 7. Bain J, Kelly H, Snadden D, Staines H.
Day surgery in Scotland: patient satisfaction and outcomes. Quality in health
care : QHC. Jun 1999;8(2):86-91. 8. Fortier J, Chung F, Su J. Unanticipated
admission after ambulatory surgery--a prospective study. Canadian journal of
anaesthesia = Journal canadien d'anesthesie. Jul 1998;45(7):612-619. 9.
Aldwinckle RJ, Montgomery JE. Unplanned admission rates and postdischarge
complications in patients over the age of 70 following day case surgery.
Anaesthesia. Jan 2004;59(1):57-59. 10. Mezei G, Chung F. Return hospital visits
and hospital readmissions after ambulatory surgery. Annals of surgery. Nov
1999;230(5):721-727. 11. Margovsky A. Unplanned admissions in day-case surgery
as a clinical indicator for quality assurance. The Australian and New Zealand
journal of surgery. Mar 2000;70(3):216-220. 12. Mattila K, Toivonen J, Janhunen
L, Rosenberg PH, Hynynen M. Postdischarge symptoms after ambulatory surgery:
first-week incidence, intensity, and risk factors. Anesthesia and analgesia. Dec
2005;101(6):1643-1650. 13. Minatti WR, Flavio B, Pablo C, Raúl R, Guillermo P,
Miguel S. Postdischarge unplanned admission in ambulatory surgery—a prospective
study. Ambulatory Surgery. 1// 2006;12(3):107-112. 14. Morales R, Esteve N,
Casas I, Blanco C. Why are ambulatory surgical patients admitted to hospital?:
Prospective study. Ambulatory Surgery. 3/15/ 2002;9(4):197-205. 15. Ogg T,
Hitchock M, Penn S. Day surgery admissions and complications. Ambulatory
Surgery. 1998;6:101-106. 16. Mingus ML, Bodian CA, Bradford CN, Eisenkraft JB.
Prolonged surgery increases the likelihood of admission of scheduled ambulatory
surgery patients. Journal of clinical anesthesia. Sep 1997;9(6):446-450. 17.
Laeeque R, Samad A, Raja AJ. Day care surgery at a university hospital--who is
responsible after discharge. JPMA. The Journal of the Pakistan Medical
Association. Dec 2001;51(12):422-427. 18. Crew JP, Turner KJ, Millar J,
Cranston DW. Is day case surgery in urology associated with high admission
rates? Annals of the Royal College of Surgeons of England. Nov
1997;79(6):416-419. 19. Awan FN, Zulkifli MS, McCormack O, et al. Factors
involved in unplanned admissions from general surgical day-care in a modern
protected facility. Irish medical journal. May 2013;106(5):153-154. 20. Rudkin
GE, Bacon AK, Burrow B, et al. Review of efficiencies and patient satisfaction
in Australian and New Zealand day surgery units: a pilot study. Anaesthesia and
intensive care. Feb 1996;24(1):74-78. 21. Paez A, Redondo E, Linares A, Rios E,
Vallejo J, Sanchez-Castilla M. Adverse events and readmissions after day-case
urological surgery. International braz j urol : official journal of the
Brazilian Society of Urology. May-Jun 2007;33(3):330-338. 22. Twersky R,
Fishman D, Homel P. What happens after discharge? Return hospital visits after
ambulatory surgery. Anesthesia and analgesia. Feb 1997;84(2):319-324.
Measure Specifications
- NQF Number (if applicable): 2687
- Description: The measure score is a hospital-level, post-surgical
risk-standardized hospital visit (RSHV) ratio, which is a ratio of the
predicted to expected number of all-cause, unplanned hospital visits within 7
days of a same-day surgery at a hospital outpatient department (HOPD) among
Medicare fee-for-service (FFS) patients aged 65 years and older. (The
endorsed specifications of the measure are: Facility-level, post-surgical
risk-standardized hospital visit ratio (RSHVR) of the predicted to expected
number of all-cause, unplanned hospital visits within 7 days of a same-day
surgery at a hospital outpatient department (HOPD) among Medicare
fee-for-service (FFS) patients aged 65 years and older.)
- Numerator: This is a risk-standardized outcome measure, so we use
this field to describe the outcome (not the numerator of the measure score).
The outcome is all-cause, unplanned hospital visits, defined as 1) an
inpatient admission directly after the surgery or 2) an unplanned hospital
visit post discharge (emergency department [ED] visit, observation stay, or
unplanned inpatient admission) occurring after discharge and within 7 days of
the surgical procedure. If more than one unplanned hospital visit occurs, only
the first hospital visit within the outcome timeframe is counted in the
outcome. (The endorsed specifications of the measure are: The outcome is
all-cause, unplanned hospital visits, defined as 1) an inpatient admission
directly after the surgery or 2) an unplanned hospital visit (emergency
department [ED] visit, observation stay, or unplanned inpatient admission)
occurring after discharge and within 7 days of the surgical
procedure.)
- Denominator: Outpatient same-day surgeries performed at HOPDs for
Medicare FFS patients aged 65 years and older.(The endorsed specifications
of the measure are: Outpatient same-day surgeries performed at HOPDs for
Medicare FFS patients aged 65 years and older with the exception of eye
surgeries and same day surgeries performed concurrently with high-risk
procedures.)
- Exclusions: The measure excludes: • Surgeries for patients without
continuous enrollment in Medicare FFS Parts A and B in the 1 month after the
surgery, to ensure all patients have full data for outcome assessment.(The
endorsed specifications of the measure are: The measure excludes surgeries for
patients without continuous enrollment in Medicare FFS Parts A and B in the 1
month after the surgery. The measure excludes these patients to ensure all
patients have full data available for outcome assessment. The exclusion
prevents unfair distortion of performance results. The measure excludes
surgeries for patients without continuous enrollment in Medicare FFS Parts A
and B in the 1 month after the surgery.)
- HHS NQS Priority: Making Care Safer, Communication and Care
Coordination
- HHS Data Source: Claims, Other; Measure also uses CMS enrollment
database (EDB) for demographics and FFS enrollment information.
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: As of 9/3/2015
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Surgery (2014
phase)
- Review for Importance: The measure meets the Importance criteria
(1a. Evidence: 1b. Performance Gap) 1a. Evidence: Y-15; N-3; 1b. Performance
Gap: H-5; M-13; L-2; I-0
Rationale:
- The developers provided a rationale for the measure, specifically that
there are interventions and strategies that may reduce unplanned hospital
visits after same-day surgery, including appropriate patient selection,
patient education, and nausea and pain management. The developer clarified
the difference between an unplanned and planned visit and noted that they
recommend reporting the measure as a ratio rather than a rate.
- The Committee concluded there is minimal evidence that ties specific
processes to the outcome but that the rationale is sufficient to support the
measure.
- The developer assessed provider-level variation in performance scores
using data from a 20 percent sample of 2010 Medicare fee-for-service claims
that represented 4,234 HOPDs and 212,104 surgeries. The measure developers
found that the high performing HOPD’s (at or below the 5th percentile) had
at least 24 percent fewer than expected surgical hospital visits and those
in the 95th percentile had at least 34 percent more hospital visits than
what they were expecting given the case and surgical procedure mix.
- Some Committee members had concerns about being able to determine if
there is a performance gap given a small sample size; however, the Committee
generally agreed that the evidence is sufficient.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria (2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity) 2a. Reliability: H-2;
M-15; L-0; I-0; 2b. Validity: H-3; M-16; L-0; I-0
Rationale:
- The data used in testing the reliability of the performance measure
score were derived from 2009-2011 Medicare fee-for-service (FFS) claims.
These data included a 20 percent sample of same-day surgery claims from Part
B (physician) claims, which were then matched to the corresponding hospital
claims. The developer conducted a “test-retest” approach by randomly
selecting half of the patients from each HOPD into two datasets. They then
calculated the risk-standardized hospital visit ratios for each HOPD in each
of the datasets, then compared the agreement between the scores for the
HOPDs using the Intraclass Correlation Coefficient (ICC) The ICC value was
0.50 (95 percent CI: 0.48-0.53), indicating “moderate” agreement according
to the categorization by Landis and Koch.
- Face validity of the performance measure score was assessed by a
Technical Expert Panel comprised of 15 patient representatives, expert
clinicians, methodologist, researchers, and providers. Of the 13 experts who
responded, 92.3 percent either strongly or moderately agreed that this
measure can accurately distinguish better and worse quality facilities.
- The Committee generally found the reliability and validity information
submitted by the developers to be sufficient.
- Review for Feasibility: H-16; M-3; L-0; I-0 (3a. Clinical data
generated during care delivery; 3b. Electronic sources; 3c.Susceptibility to
inaccuracies/ unintended consequences identified 3d. Data collection strategy
can be implemented)
Rationale:
- The data source for this measure is Medicare administrative claims and
enrollment data, and therefore all data elements are in defined fields.
- The Committee was satisfied with the feasibility of this
measure.
- Review for Usability: H-6; M-11; L-1; I-0 (Meaningful,
understandable, and useful to the intended audiences for 4a. Public
Reporting/Accountability and 4b. Quality Improvement)
Rationale: The Committee was generally satisfied with the use and usability
of this measure and would like the comments that have been made to be
addressed at the next cycle for the measure.
- Review for Related and Competing Measures:
- This measure is related to 2539 Facility 7-Day Risk-Standardized
Hospital Visit Rate after Outpatient Colonoscopy, Rate of risk-standardized,
all-cause, unplanned hospital visits within 7 days of an outpatient
colonoscopy among Medicare fee-for-service (FFS) patients aged 65 years and
older.
- The Committee recommended that the need for two similar measures, as
well as harmonization and unintended consequences should be assessed during
annual updates once the two new measures have been in use for some time so
that any potentially needed adjustments could be considered for each measure
independently.
- Endorsement Public Comments: April 17, 2015 – May 18, 2015
(Additional 15-day Public and Member Comment: May 22, 2015 to June 5, 2015)
Comments received:
- One commenter expressed uncertainty about the feasibility of this
measure, citing that a free-standing surgical center would have no mechanism
to recall patients. Additionally, hospitals and ambulatory surgical centers
that have urgent care facilities would be penalized for providing patient
access, per the current measure language.
- Another commenter noted that CMS Planned Readmission Algorithm 3.0 was
used to identify those procedures or conditions that typically result in
planned admissions. The commenter noted that this algorithm has been tested
for the inpatient care and has not been tested for the ambulatory care
setting. The commenter further noted that outpatient surgery procedures that
are planned admissions are different and unique to this setting; and
questioned that by using this inpatient algorithm, that there has been a
compromise in developing a comprehensive list of planned admissions for
procedures performed in ambulatory surgery centers.
- Lastly, two commenters noted that NQF is currently holding a trial
period under which measures may be risk-adjusted for patients’ socioeconomic
status and other demographic factors (SDS). The commenters suggested that
SDS adjustment for measure #2687 (Hospital Visits After Outpatient Surgery)
may be appropriate, and questioned why this had not been discussed or
considered by the Standing Committee. Commenters also observed that a
measure (#2539: Facility 7-Day Risk-Standardized Hospital Visit Rate after
Outpatient Colonoscopy) similar to measure #2687 (Hospital Visits after
Hospital Outpatient Surgery) was recently endorsed by NQF’s Readmissions
Standing Committee, and questioned why the Surgery Standing Committee had
not addressed harmonization of these two measures
NQF response: NQF appreciates your comment and the opportunity to provide
clarification. Previous NQF policy prohibited the inclusion of
sociodemographic status (SDS) factors in risk-adjustment approaches out of
concern that doing so might conceal inequalities in care and result in lower
standards of provider performance for certain subpopulations. However, in
2014, NQF convened a multi-stakeholder panel of experts in healthcare
performance measurement and disparities to consider if, when, and how
performance measures should be adjusted for SDS. After its deliberations, the
Expert Panel recommended that NQF should allow inclusion of SDS factors in the
risk-adjustment approach for performance measures when conceptual reasons and
empirical evidence demonstrate it is appropriate. The NQF Board of Directors
reviewed the Expert Panel’s recommendations and decided to temporarily change
NQF’s policy and evaluate its impact during the course of a two-year trial
period. This trial period went into effect on April 15, 2015, meaning that
projects with measure submission deadlines before that date fell under NQF’s
previous policy/guidance on SDS adjustment, while projects with measure
submission deadlines after that date are subject to the trial policy on SDS
adjustment. The2015 Surgery project’s measure submission deadline was January
14, 2015, prior to the start of NQF’s SDS trial period. Therefore, both the
developer and the Surgery Standing Committee conformed to the previous policy
regarding inclusion of SDS factors in the risk-adjustment approach.
Developer response:
- Thank you for raising these two potential concerns; we would like to
clarify, however, that the measure as designed does not assess either
ambulatory surgery centers or free standing urgent care facilities. The
measure includes outpatient same-day surgeries performed at hospital
outpatient departments only; it does not include procedures performed at
ambulatory surgery centers. Likewise, the measure does not affect urgent care
facilities. They are not measured, and visits to urgent care facilities are
not counted in the measure outcome, which only includes hospital emergency
department visits, observation stays, or unplanned inpatient admissions.
- We appreciate the question and the opportunity to clarify why it makes
sense to use an algorithm developed for hospital readmission measures in this
measure, which as you note focuses on same-day surgery rather than admitted
patients. The CMS Planned Readmission Algorithm was developed to identify all
admissions (rather than readmissions per se) that are planned. That is, it
uses condition and procedure codes to distinguish between admissions to
address acute illness and injury from admissions of stable patients that are
for planned procedures (such as for chemotherapy or a hip replacement). We use
the algorithm in this measure because our goal here is the same as it was for
the hospital readmission measures – we do not want to include in our measure
outcome admissions that are planned, since they are not a signal of care
quality. We did review the algorithm carefully to make sure the way we
identify the planned admissions makes sense in the context of this surgery
measure, and shared the details of the algorithm with our technical expert
panel, the public, and NQF reviewers. If you have specific suggestions for
ways the algorithm should be adapted for this particular measure, we are happy
to consider them.
- We appreciate your concern about the potential effects of SDS on the
measure score. We wanted to address your comments on both the process of
review and the substance of our conclusions in the NQF application based on
the SDS analysis we conducted for the application. Regarding the process, the
surgery measure is not technically in NQF’s SDS pilot. “This trial period went
into effect on April 15, 2015. This means that projects with measure
submission deadlines before that date fell under NQF’s previous
policy/guidance on SDS adjustment, while projects with measure submission
deadlines after that date are subject to the trial policy on SDS adjustment.
Since the 2015 Surgery project’s measure submission deadline was January 14,
2015, both the developer and the Surgery Standing Committee conformed to the
[pre-trial] policy regarding inclusion of SDS factors in the risk-adjustment
approach (email from Andrew Lyzenga at NQF, June 15, 2015).”
Regarding the
substance of your concern, consistent with the pre-trial NQF guidance on SDS,
we evaluated the potential effects of risk adjusting for two SDS indicators –
Medicaid-dual eligibility and race. These variable are readily available in
the CMS claims data. In addition, use of Medicaid eligibility status as a
proxy for SDS is consistent with prior research as well as NQF recommendations
(http://www.qualityforum.org/projects/Patient_Outcome_Measures_Phases1-2.aspx).
Our results show that adjusting for these factors at the patient level does
little to change the measure scores; unadjusted and adjusted HOPD
risk-standardized hospital visit (RSHV) ratios are highly correlated (Pearson
correlation 0.990 and 0.998 for adjustment for Medicaid-dual eligibility and
race, respectively). This suggests that including a patient-level risk
adjuster for SDS will make little difference in the measure results after
accounting for other factors already adjusted for in the model, such as age,
comorbidities, and the complexity of the surgery.
In addition, to explore
whether there might be differences in HOPD RSHV ratios by the proportion of
lower SDS patients hospitals care for, we examined the distribution of measure
scores by quartiles of both percentage of dual-eligible patients and
percentage of African American patients. Although the results show a trend
toward higher measure scores in the highest quartile of lower SDS patients,
they also show that some hospitals with relatively high proportions of lower
SDS patients can and do perform well on the measure. We cannot tell from these
analyses what is causing the observed differences across quartiles of
proportion of lower SDS patients. One of the potential causes is differences
related to quality. For example, some hospitals may be better able than other
hospitals to meet the needs of patients with low literacy. Given these
findings, on balance we do not recommend adjusting the measure for SDS at this
time. Doing so will not appreciably change the measure scores and might
contribute to masking disparities in care.
CMS is participating fully in
the NQF trial and is actively working to further consider issues related to
adjusting for SDS. In addition, CMS notes that the Office of the Assistant
Secretary for Planning and Evaluation (ASPE) is conducting research on the
issue of risk adjustment for socioeconomic status as directed by the IMPACT
Act and will issue a report to Congress by October 2016. CMS will closely
examine the recommendations issued by ASPE and consider how they apply to this
and other CMS quality measures.
CMS did consider the effect of adjusting
for SDS and reported the results in the NQF application. As discussed in the
application and in response to the question above, we do not recommend
adjusting for SDS at this time, so testing the reliability of the measure with
SDS adjustment is not necessary at this time. As you note, reliability testing
yielded an intraclass correlation coefficient (ICC) of 0.50, which according
to conventional interpretation is “moderate.” It should be noted that this ICC
value is consistent with those of other CMS claims-based measures. In
addition, measure testing was conducted using a 20% sample of Medicare
Fee-for-Service data. We expect the reliability score will be higher in the
national 100% sample where individual facility volumes would be higher
yielding more reliable individual facility results. The 100% sample would be
used for public reporting.
The present measure (NQF # 2687) is already
fully harmonized with NQF # 2539 (Facility 7-Day Risk-Standardized Hospital
Visit Rate after Outpatient Colonoscopy) on areas of the methodology that are
analogous. Specifically, both measures use the same outcome. For both the
outpatient surgery measure and the outpatient colonoscopy measure, the outcome
is identically specified as all-cause, unplanned hospital visits, defined as
1) an inpatient admission directly after the procedure, or 2) an unplanned
hospital visit (emergency department visit, observation stay, or unplanned
inpatient admission) occurring after discharge and within 7 days of the
outpatient procedure.
We believe that the measure will yield important
information that will help facilities improve patient care. Measure testing
demonstrated significant variation in risk-standardized performance across
facilities, indicating opportunities for quality improvement. Facilities with
a higher than expected number of outcomes will be able to review and improve
their processes around preparing the patient for surgery, the surgery itself,
and follow-up care. In addition, in implementing the measure, CMS would
provide each facility with patient-level data so that facilities could examine
the specific causes of higher than expected outcome.
Reliability testing
yielded an intraclass correlation coefficient (ICC) of 0.50, which according
to conventional interpretation is “moderate.” It should be noted that this ICC
value is consistent with those of other CMS claims-based measures. In
addition, measure testing was conducted using a 20% sample of Medicare
Fee-for-Service data. We expect the reliability score will be higher in the
national 100% sample where individual facility volumes would be higher
yielding more reliable individual facility results. The 100% sample would be
used for public reporting.
Committee Response:
- The Committee appreciates the opportunity to provide clarification
regarding the setting of interest. Given the care setting to which the measure
applies, the Committee believes the expressed concerns are mitigated.
- The Committee also appreciates the precision requested by the commenter as
well as the clarity provided by the developer. During the in-person meeting
the Committee agreed that the specifications of the measure were appropriate.
- Finally, the Committee appreciates the position of NQF, the participation
by CMS in the SDS trial as outlined in NQF policy, and CMS commitment
regarding recommendations from ASPE research. During the in-person meeting the
Committee agreed that the datasets, approach to testing and testing outcome
was sufficient to move the measure forward. As part of the annual update to
the measure, the Committee anticipates updated information about SDS impact
including any changes to the measure to increase SDS sensitivity as well as
any changes required to ensure its full alignment with 2539. With respect to
harmonization, the Committee agreed that it was appropriate to assess the
impact and implementation of the two new measures independently before further
consideration about how additional alignment might occur.
Endorsement Committee Recommendation: Standing Committee
Recommendation for Endorsement: Y-18; N-1
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Although MAP encouraged continued development,
members noted the need to balance this measure with what is relevant to the
patient, and not limit to only check box quality measures.
- Public comments received: 19
Rationale for measure provided by HHS
Treatment Preferences and
Spiritual Care The Hospice and Palliative Care - Treatment Preferences measure
addresses patient autonomy for patients with high severity of illness and risk
of death, including seriously and incurably ill patients enrolled in hospice or
hospital-based palliative care. The National Priorities Partnership has
identified palliative and end-of-life care as one of its national priorities. A
goal of this priority is to ensure that all patients with life-limiting illness
have the right to express preferences that guide use of invasive or
life-sustaining forms of treatment. The affected populations are large; in 2009,
1.56 million people with life-limiting illness received hospice care.(NHPCO
2010) In 2008, 58.5% of US hospitals with 50 or more beds had some form of
palliative care service, and national trends show steady expansion of these
services.(Center to Advance Palliative Care 2010) Patients and family
caregivers rate control over treatment decisions as a high priority when living
with serious and life-limiting illnesses. (Singer et al 1999) From a recent
systematic review of clinical trials, moderate evidence supports multicomponent
interventions to increase advance directives, and "care planning through
engaging values, involving skilled facilitators, and focusing on key decision
makers.” These studies found improved outcomes of patient-physician
communication, improved satisfaction with care, and increased hospice
enrollment.( Lorenz et al 2008) The more recently published Coping with Cancer
Study, a prospective observational study of over 300 patients with advanced
cancer, found that communication of patient treatment preferences was associated
with use of treatments honoring those preferences and wish lesser use of
aggressive, high-cost treatments.(Wright et al 2010; 2008) Spiritual care also
has been shown to be a critical element of quality of life at the end of
life.(Boston et al 2011; Cohen et al 1996; Puchalski et al 2009; Steinhauser et
al 2000) References Boston P, Bruce A, Schrieber R. Existential suffering in
the palliative care setting: an integrated literature review. J Pain Symptom
Manage. 2011 Mar;41(3):604-18. Epub 2010 Dec 8. Center to Advance Palliative
Care http://www.capc.org/news-and-events/releases/04-05-10 Cohen SR, Mount BM,
Tomas JJN, Mount LF. Existential well-being is an important determinant of
quality of life. Cancer 1996; 77:576-86. Lorenz KA, Lynn J, Dy SM et al.
Evidence for improving palliative care at the end of life: a systematic review.
Ann Intern Med 2008: 148:147-159. NHPCO Facts and figures: hospice care in
America 2010 edition
http://www.nhpco.org/files/public/Statistics_Research/Hospice_Facts_Figures_Oct-2010.pdf
Puchalski C, Ferrell B, Virani R, Otis-Green S, Baird P, Bull J, Chochinov H,
Handzo G, Nelson-Becker H, Prince-Paul M, Pugliese K, Sulmasy D. Improving the
quality of spiritual care as a dimension of palliative care: the report of the
Consensus Conference. J Palliat Med. 2009 Oct;12(10):885-904. Review. Singer
PA, Martin DK, Kelner M. Quality end-of-life care: patients´ perspective. JAMA
1999; 281: 163-168. Steinhauser KE, Christakis NA, Clipp EC, McNeilly M,
McIntyre L, Tulsky JA. Factors considered important at the end of life by
patients, family, physicians, and other care providers. JAMA 2000 Nov
15;284(19):2476-82. Wright AA, Zhang B, Ray A et al. Associations between
end-of-life discussions, patient mental health, medical care near death, and
caregiver bereavement adjustment. JAMA 2008; 300:1665-1673. Wright AA, Mack JW,
Kritek PA, Balboni TA, Massaro AF, Matulonis UA, Block SD, Prigerson HG.
Influence of patients’ preferences and treatment site on cancer patients’ end of
life care. Cancer. 2010 Oct 1;116(19):4656-63. Pain Research on care of
patients with serious incurable illness and those nearing the end of life shows
they experience high rates of pain (40-70% prevalence) and other physical,
emotional, and spiritual causes of distress. (SUPPORT, 1995; Gade et al 2008)
The National Priorities Partnership has identified palliative and end-of-life
care as one of its national priorities. A goal of this priority is to ensure
that all patients with life-limiting illness have access to effective treatment
for symptoms such as pain and shortness of breath. The affected populations are
large; in 2009, 1.56 million people with life-limiting illness received hospice
care. (NHPCO, 2010) In 2008, 58.5% of US hospitals with 50 or more beds had some
form of palliative care service, and national trends show steady expansion of
these services.(Center to Advance Palliative Care 2010) Patients and family
caregivers rate pain management as a high priority when living with serious and
life-limiting illnesses. (Singer, 1999) The consequences of inadequate
screening, assessment and treatment for pain include physical suffering,
functional limitation, and development of apathy and depression. (Gordon 2005)
References: Center to Advance Palliative Care
http://www.capc.org/news-and-events/releases/04-05-10 Gade G, Venohr I, Conner
D, et al. Impact of an inpatient palliative care team: a randomized control
trial. J Palliat Med. 2008;11(2):180–190. Gordon DB, Dahl JL, Miaskowski C et
al. American Pain Society recommendations for improving the quality of acute and
cancer pain management. Arch Intern Med 2005; 165:1574-1580. NHPCO Facts and
figures: hospice care in America 2010 edition
http://www.nhpco.org/files/public/Statistics_Research/Hospice_Facts_Figures_Oct-2010.pdf
Singer PA, Martin DK, Kelner M. Quality end-of-life care: patients´
perspective. JAMA 1999; 281: 163-168. The Writing Group for the SUPPORT
Investigators. A controlled trial to improve care for seriously ill hospitalized
patients. The study to understand prognosis and preferences for outcomes and
risks of treatments (SUPPORT). JAMA. 1995;274:1591-1598.
http://www.nationalprioritiespartnership.org/PriorityDetails.aspx?id=608
Shortness of Breath Dyspnea is a common symptom in serious illness, more common
than pain for patients with chronic obstructive lung disease, lung cancer,
cystic fibrosis, and restrictive lung diseases such as pulmonary fibrosis.(Luce
et al 2001) Unlike pain, dyspnea severity is associated with the risk of
death.(Olajidae et al 2007) Between 50-70% of patients with advanced lung cancer
experience dyspnea near the end of life. As detailed in a recent systematic
review, opioids, oxygen and non-pharmacologic nursing interventions demonstrate
efficacy in randomized controlled trials of treatment for dyspnea in cancer and
in other serious illness.( Ben-Aharon et al 2008; Lorenz et al 2008)
Unfortunately, dyspnea is often persistent and under-treated in advanced cancer
and other end-stage diseases.( Roberts et al 1993 ) References: Ben-Aharon I,
Gafter-Gvili A, Paul M et al. Interventions for alleviating cancer-related
dyspnea: a systematic review. J Clin Oncol 2008; 26:2396-2404. Lorenz KA, Lynn
J, Dy SM et al. Evidence for improving palliative care at the end of life: a
systematic review. Ann Intern Med 2008; 148:147-159. Luce JM, Luce JA.
Management of dyspnea in patients with far-advanced lung disease. JAMA 2001;
285:1331-1337. Olajidae O, Hanson LC, Usher BM et al. Validation of the
Palliative Performance Score in the acute tertiary hospital setting. J Palliat
Med 2007; 10:111-117 Roberts DK, Thorne SE, Pearson C. Cancer Nurs 1993;
16:310-320 Bowel Regimen Opioids are commonly used in the management of
moderate to severe pain, and constipation is a common adverse effect. (Myotoku
2010; Tuteja 2010; Pappagallo 2001) A systematic review evaluating the extent
and management of opioid-related side effects in both cancer and non-cancer
patients indicated that tolerance is not developed to opioid-induced
constipation and confirmed the need for prophylaxis. (McNicol 2003) Risk of
constipation is further aggravated by immobility and dehydration in older people
with pain. The American Pain Society and American Geriatrics Society as well as
expert consensus opinion recognize the frequency of constipation with opioid use
and the necessity for prophylactic therapy. (APS 2005; RANO 2002; AGS 2002; APS
2002; Weiner 2001; Davis 2003; Etzioni 2007; Dy 2008) A study of 194,017
emergency department visits made by 76,759 cancer patients in the final 6 months
of life revealed that 3,392 visits were made for constipation. (Barbera 2010) A
Cochrane systematic review of 26 studies of patients at least 18 years old
taking opioids for at least 6 months for non-cancer pain revealed
gastrointestinal complaints (e.g., constipation, nausea, dyspepsia) as the most
commonly reported side effect. (Noble 2010) References: AGS Panel on
Persistent Pain in Older Persons. The management of persistent pain in older
persons. J Am Geriatr Soc 2002;50(6 Suppl):S205-24 American Pain Society (APS).
Guideline for the management of cancer pain in adults and children. 2005
American Pain Society (APS). Guideline of the management of pain in
osteoarthritis, rheumatoid arthritis, and juvenile chronic arthritis. 2002.
Barbera L, Taylor C, Dudgeon D. Why do patients with cancer visit the emergency
department near the end of life? Can Med Assoc J 2010;182(6):563-569 Davis MP,
Srivastava M. Demographics, assessment and management of pain in the elderly.
Drugs Aging 2003;20(1):23-57 Dy SM, Asch SM, Naeim A, et al. Evidence-based
standards for cancer pain. J Clin Oncol 2008;26(23):3879-3885 Etzioni S,
Chodosh J, Ferrell BA, et al. Quality indicators for pain management in
vulnerable elders. JAGS 2007;55:S403-S408 McNicol E, Horowicz-Mehler N, Fisk RA
et al. Management of opioid side effects in cancer-related and chronic noncancer
pain: a systematic review. J Pain 2003;4(5):231-56 Myotoku M, Nakanishi A,
Kanematsu M, et al. Reduction in opioid side effects by prophylactic measures of
palliative care team may result in improved quality of life. J Pall Care
2010;13(4):401-406 Noble M, Treadwell JR, Tregear SJ, et al. Long-term opioid
treatment for chronic noncancer pain. Cochrane Database Sys Rev
2010;(1):CD006605 Pappagallo M. Incidence, prevalence, and management of opioid
bowel dysfunction. Am J Surg 2001;182(5A Suppl):11s-8s Registered Nurses
Association of Ontario (RNAO). Assessment and management of pain. 2002. (Nursing
Best Practice Guideline: Shaping the Future of Nursing) Tuteja AK, Biskupiak J,
Stoddard GJ, et al. Opioid-induced bowel disorders and narcotic bowel syndrome
in patients with chronic non-cancer pain. Neurogastroenterol Motil
2010;22:424-e96 Weiner DK, Hanlon JT. Pain in nursing home residents:
management strategies. Drugs Aging 2001;18(1):13-29
Measure Specifications
- NQF Number (if applicable):
- Description: This measure will assess percentage of hospice
patients who received care processes consistent with guidelines at admission.
This is a composite measure based on select measures from 7 NQF-endorsed
measures: NQF #1641, NQF #1647, NQF #1634, NQF #1637, NQF #1639, NQF #1638,
NQF #1617.
- Numerator: The numerator is patients who meet the numerator
criteria for all of the select measures of the 7 NQF-endorsed measures: 1641,
1647 (modified), 1634, 1637, 1639, 1638, and 1617. Specifically, these
measures are: NQF #1641 Hospice and Palliative Care – Treatment Preferences
NQF #1647 (modified) Beliefs/Values Addressed (if desired by the patient) NQF
#1634 Hospice and Palliative Care – Pain Screening NQF #1637 Hospice and
Palliative Care – Pain Assessment NQF #1639 Hospice and Palliative Care –
Dyspnea Screening NQF #1638 Hospice and Palliative Care – Dyspnea Treatment
NQF #1617 Patients Treated with an Opioid Who Are Given a Bowel
Regimen
- Denominator: All hospice patients
- Exclusions: Patients under 18 years of age
- HHS NQS Priority: Patients under 18 years of age
- HHS Data Source: This is a composite measure based on 7
NQF-endorsed measures. The data to calculate the 7 NQF-endorsed measures are
collected through the Hospice Item Set (HIS). CMS implemented the HIS, a
standardized, patient-level data collection instrument, as part of the Hospice
Quality Reporting Program (HQRP) in the FY 2014 Hospice Wage Index final rule
(78 FR 48234–48281). Medicare-certified hospices are required to submit an
HIS-Admission record and an HIS-Discharge record for each patient admission on
or after July 1, 2014. Thus, the data elements needed for this measure are
readily available at national level.
- Measure Type: Composite
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: CMS noted that based on pilot results and
feedback from the TEP and Caregiver Workgroup, this measure was recently
updated and is now a set of two measures. Measure 1 assesses percent of
patients receiving at least one visit from registered nurses, physicians,
nurse practitioners or physician assistants in the last three days of life.
Measure 2 assesses percent of patients receiving at least two visits from
medical social workers, chaplains or spiritual counselors, licensed practical
nurses and hospice aides in the last seven days of life. CMS also noted that
due to these revisions, the measure(s) would require further testing and
analytics prior to implementation.
- Public comments received: 19
Rationale for measure provided by HHS
The literature supports
hospice visits when death is imminent as a high priority in end-of-life care by
showing the last week of life as the point in the terminal illness trajectory
with the highest symptom burden. Particularly during the last few days before
death, patients experience myriad physical and emotional symptoms, necessitating
close care and attention from the integrated hospice team. Physical symptoms
with high prevalence in the last week of life include fatigue, pain, dyspnea,
respiratory secretions/death rattle, anorexia, dry mouth, nausea and/or
vomiting, affecting a quarter to more than 80 percent of imminently dying
patients. The specific prevalence of each symptom varies across studies,
reflecting the heterogeneity of the samples and the range of assessment
techniques used.(Lynn, Teno et al. 1997, Klinkenberg, Willems et al. 2004, Kehl
and Kowalkowski 2012) Psychosocial symptoms with high prevalence in the last
week of life include confusion, anxiety, depression and delirium, affecting a
third to more than half of imminently dying patients.(Klinkenberg, Willems et
al. 2004) A study of after-death interviews with close relatives of terminal
patients found that 75 percent of patients experienced at least two symptoms
requiring management in the last week of life.(Klinkenberg, Willems et al. 2004)
The symptom burden typically increases significantly in the last few days of
life compared to the previous stage,(Currow, Smith et al. 2010) further
supporting care of the imminently dying patient as a high priority aspect of
healthcare. Studies focusing on the expectations of patients and families also
demonstrate the importance of care and attention from the hospice team in the
days leading up to death. Caregivers of dying patients agree overwhelmingly with
the importance of preparation at the end of life. Hospice assistance, ranging
from legal to logistical to emotional, is paramount in preparing hospice
patients and their families for imminent death. (Steinhauser, Christakis et al.
2000) Bereaved family members and friends from a variety of settings identified
the provision of physical comfort and emotional support to dying patients and
their families as fundamental aspects of high-quality care.(Steinhauser,
Christakis et al. 2000) References: Currow, D.C., et al., Do the Trajectories
of Dyspnea Differ in Prevalence and Intensity By Diagnosis at the End of Life? A
Consecutive Cohort Study. Journal of Pain and Symptom Management, 2010. 39(4):
p. 680-690. Kehl, K.A. and J.A. Kowalkowski, A Systematic Review of the
Prevalence of Signs of Impending Death and Symptoms in the Last 2 Weeks of Life.
American Journal of Hospice & Palliative Medicine, 2012. 30(6): p. 601-616.
Klinkenberg, M., et al., Symptom Burden in the Last Week of Life. J Pain Symptom
Manage., 2004. 27(1): p. 5-13. Lynn, J., et al., Perceptions by Family Members
of the Dying Experience of Older and Seriously Ill Patients. Annals of Internal
Medicine, 1997. 126(2): p. 97-106. Steinhauser, K.E., et al., Factors
Considered Important at the End of Life by Patients, Family, Physicians, and
Other Care Providers. JAMA, 2000. 284(19): p. 2476-2482.
Measure Specifications
- NQF Number (if applicable):
- Description: This measure will assess hospice staff visits to
patients and caregivers in the last week of life.
(New information
provided by CMS on December 2, 2015)Hospice Visits When Death Is Imminent
is a set of two measures. Measure 1 assesses percent of patients receiving at
least one visit from registered nurses, physicians, nurse practitioners or
physician assistants in the last three days of life. Measure 2 assesses
percent of patients receiving at least two visits from medical social workers,
chaplains or spiritual counselors, licensed practical nurses and hospice aides
in the last seven days of life.
- Numerator: The numerator of this measure will be the number of
patients in the denominator who receive hospice staff visits in the last week
of life. Members of the hospice staff whose visits are considered for the
measure include: nurses (registered nurse, licensed professional nurse or
nurse practitioner if acting in the role of a nurse), hospice aides,
physicians (or nurse practitioner or physician assistant if acting as the
attending physician), chaplains or spiritual counselors, therapists (physical
therapist, occupational therapist or speech language therapist), medical
social workers, and volunteers.
(New information provided by CMS on
December 2, 2015)Measure 1 - The numerator of this measure will be the
number of patients in the denominator who receive at least one visit from
registered nurses, physicians, nurse practitioners or physician assistants in
the last three days of life. Measure 2 - The numerator of this measure will be
the number of patients in the denominator who receive at least two visits from
medical social workers, chaplains or spiritual counselors, licensed practical
nurses and hospice aides in the last seven days of life.
- Denominator: The denominator is the number of hospice patients who
are discharged as expired within a defined target period.
(New
information provided by CMS on December 2, 2015)Measure 1 - The
denominator is the number of hospice patients who are discharged as expired
within a defined target period and received routine home care in the last
three days of life. Measure 2 - The denominator is the number of hospice
patients who are discharged as expired within a defined target period and
received routine home care in the last seven days of life.
- Exclusions: Patients who received continuous home care or general
inpatient care only in the last week of life.
(New information
provided by CMS on December 2, 2015)Measure 1 - Patients who received any
continuous home care, respite care, or general inpatient care in the last
three days of life. Measure 2 - Patients who received any continuous home
care, respite care, or general inpatient care in the last seven days of life
OR patients with a length of stay of one day.
- HHS NQS Priority: Patients who received continuous home care or
general inpatient care only in the last week of life.
- HHS Data Source: Hospice Item Set (HIS)
- Measure Type: Process
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF annual
update
- Workgroup Rationale: MAP conditionally supported this update to the
name of the measure from “reliability adjusted SIR” to “Adjusted Ranking
Metric (ARM),” pending NQF annual update. The continued use of this measure
will promote SSI prevention activities, which will lead to an improvement in
patient outcomes, reducing avoidable medical costs, patient morbidity and
mortality.
- Public comments received: 6
Rationale for measure provided by HHS
Affects large numbers,
Frequently performed procedures, A leading cause of morbidity/mortality, High
resource use, Severity of illness, Patient/societal consequences of poor
quality. SSIs estimated to account for 20% of all HAIs[1] 290,485 estimated
SSIs/yr[2] Estimated 8,205 deaths associated with SSIs each year[1] Estimated
11% of all deaths occurring in intensive care units are associated with SSIs[1]
$34,670 medical cost/SSI[2] Total >$10 billion attributable to SSI in U.S.
each year[2] Estimated additional 7-10 days of hospitalization for each SSI per
patient[1] [1] Klevens RM, Edwards JR, et al. Estimating healthcare-associated
infection and deaths in U.S. hospitals, 2002. Public Health Reports 2007;
122:160-166. [2] Scott, RD. The Direct Medical Costs of Healthcare-Associated
Infections in U.S. Hospitals and the Benefits of Prevention.
http://www.cdc.gov/ncidod/dhqp/pdf/Scott_CostPaper.pdf accessed April 12, 2010.
Measure Specifications
- NQF Number (if applicable): 753
- Description: Organ/space Surgical Site Infections (SSI) at the
primary incision site among adult patients at least 18 years of age undergoing
inpatient colon procedures and/or abdominal hysterectomies as reported through
the ACS-NSQIP or CDC NHSN. The measure yields separate SIRs for each
procedure. (The endorsed specifications of the measure are: Prototype
measure for the facility adjusted Standardized Infection Ratio (SIR) of deep
incisional and organ/space Surgical Site Infections (SSI) at the primary
incision site among adult patients aged >= 18 years as reported through the
ACS National Surgical Quality Improvement Program (ACS-NSQIP) or CDC National
Health and Safety Network (NHSN). Prototype also includes a systematic,
retrospective sampling of operative procedures in healthcare facilities. This
prototype measure is intended for time-limited use and is proposed as a first
step toward a more comprehensive SSI measure or set of SSI measures that
include additional surgical procedure categories and expanded SSI
risk-adjustment by procedure type. This single prototype measure is applied
to two operative procedures, colon surgeries and abdominal hysterectomies, and
the measure yields separate SIRs for each procedure.)
- Numerator: Deep incisional primary (DIP) and organ/space SSIs
during the 30-day postoperative period among patients at least 18 years of age
undergoing inpatient colon surgeries or abdominal hysterectomies. SSIs will be
identified before discharge from the hospital, upon readmission to the same
hospital, or during outpatient care or admission to another hospital
(post-discharge surveillance). Case accrual will be guided by sampling
algorithms as described below.
- Denominator: Using multivariable logistic regression models for
colon surgeries and abdominal hysterectomies, the expected number of SSIs is
obtained. These expected numbers are summed by facility and surgical procedure
and used as the denominator of this measure
- Exclusions: Persons under the age of 18, those having a procedure
performed on an outpatient basis, those with ASA Class VI (6) are
excluded.(The endorsed specifications of the measure are: Persons under the
age of 18, those having a procedure performed on an outpatient basis, those
with ASA Class VI (6) are excluded. In the NHSN, patients without primary
closure of the surgical incision are not considered eligible cases and are
excluded- the NSQIP will match this practice for this measure, although this
is not standard practice within the NSQIP.)
- HHS NQS Priority: Making Care Safer
- HHS Data Source: National Healthcare Safety Network
- Measure Type: Outcome
- Steward: Centers for Disease Control and Prevention
- Endorsement Status: Endorsed; MUC same as endorsed
version:Yes
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2012
- Project for Most Recent Endorsement Review: Patient Safety
Measures
- Review for Importance: The measure addresses a high impact area.
Each year, approximately 11 percent of all deaths in ICUs are associated with
SSIs, resulting in up to 20,000 deaths and $2 billion in additional costs.2
Moreover, evidence-based interventions have shown significant reductions in
SSI rates and improved health outcomes.
- Review for Scientific Acceptability: See CDP
Recommendation]
- Review for Feasibility: See CDP Recommendation]
- Review for Usability: See CDP Recommendation]
- Review for Related and Competing Measures: See CDP
Recommendation]
- Endorsement Committee Recommendation: The Steering Committee
discussed the newly-harmonized measure in a supplemental conference call,
reviewing the relevant changes, while also receiving clarification from the
developers on several issues. Committee members inquired as to why these two
particular measures had been chosen, and asked for clarification on the plan
for public reporting. The developer explained that the CMS IPPS requirements
released on August 1, 2011, call for abdominal hysterectomies and colon
surgeries to be reported by the CDC to CMS. The NHSN will serve as the single
reporting system for CMS-required reporting. However, facilities may choose
which calculations of performance on the measure can be accomplished using
either the NHSN or NSQIP data system. The measure developer acknowledged that
for hospitals participating in both systems, there could be duplication.The
Steering Committee questioned why both organ space and deep incisional
infections were included in the measure. The developer described the approach
as a long standing precedent and stated that superficial infections are
considered trivial events and therefore not included. However, organ space
infections that drain through the incisions are classified as deep incisional
infections. The combination of organ space and deep incisional infections are
considered a clinically coherent grouping. The Committee expressed their
appreciation for the developers’ efforts at harmonization, and agreed that the
measure continues to meet the four major evaluation criteria. The Steering
Committee recommended this measure for endorsement in a unanimous vote.This
outcome measure replaces NQF-endorsed measure #0299 (Surgical Site Infection
Rate) and addresses the National Priority area of
safety.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because it
would overlap with the current Medicare Spending Per Beneficiary Measure and
MAP has previously advocated keeping a parsimonious set of measures for the
VBP program to avoid rewarding or penalizing a provider mulitple times for the
same case.
- Public comments received: 10
Rationale for measure provided by HHS
Episode-based performance
measurement allows meaningful comparisons between providers based on resource
use for certain clinical conditions or procedures, as noted in the NQF report
for the “Episode Grouper Evaluation Criteria” project (available at
http://www.qualityforum.org/Publications/2014/09/Evaluating_Episode_Groupers__A_Report_from_the_National_Quality_Forum.aspx)
and in various peer-reviewed articles (e.g., Hussey, P. S., Sorbero, M. E.,
Mehrotra, A., Liu, H., & Damberg, S. L. (2009). Episode-Based Performance
Measurement and Payment: Making It a Reality. Health Affairs, 28(5), 1406-1417.
doi:10.1377/hlthaff.28.5.1406). While reliability analyses have been conducted
on similar performance measures, we plan to conduct our own reliability analysis
for this specific measure and propose a minimum number of cases for reporting.
The analysis will likely mirror the 2012 MSPB reliability analysis:
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/hospital-value-based-purchasing/Downloads/MSPBReliabilityAnalysis-Jul-18-12.pdf
Measure Specifications
- NQF Number (if applicable):
- Description: The measure constructs a clinically coherent group of
services to inform providers about resource use and effectiveness. It sums
Parts A and B payments related to a cellulitis IP stay and attributes them to
the hospital where the index IP stay occurred. It includes subtypes for
diabetics, decubitus pressure ulcers, and other cellulitis
patients.
- Numerator: The numerator of the Cellulitis Clinical Episode-Based
Payment Measure is the risk-adjusted sum of a provider’s spending and the
preadmission and post-discharge medical services that are clinically related
to cellulitis across a hospital’s eligible cellulitis episodes during the
period of performance. A clinical episode begins 3 days prior to the initial
(i.e., index) admission and extends 30 days following the index hospital stay
discharge date.
- Denominator: A count of the provider’s condition-specific episodes
during the period of performance.
- Exclusions: Episode Exclusions: 1. Beneficiaries who do not have
continuous enrollment in Medicare Parts A and B from 90 days prior to IP
admission through the end of the episode with Medicare as the primary payer.
2. Beneficiaries who enroll in Medicare Advantage during the period that
starts 90 days prior to IP admission through the end of the
episode.
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: Claims
- Measure Type: Efficiency
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because it
would overlap with the current Medicare Spending Per Beneficiary Measure and
MAP has previously advocated keeping a parsimonious set of measures for the
VBP program to avoid rewarding or penalizing a provider mulitple times for the
same case.
- Public comments received: 10
Rationale for measure provided by HHS
Episode-based performance
measurement allows meaningful comparisons between providers based on resource
use for certain clinical conditions or procedures, as noted in the NQF report
for the “Episode Grouper Evaluation Criteria” project (available at
http://www.qualityforum.org/Publications/2014/09/Evaluating_Episode_Groupers__A_Report_from_the_National_Quality_Forum.aspx)
and in various peer-reviewed articles (e.g., Hussey, P. S., Sorbero, M. E.,
Mehrotra, A., Liu, H., & Damberg, S. L. (2009). Episode-Based Performance
Measurement and Payment: Making It a Reality. Health Affairs, 28(5), 1406-1417.
doi:10.1377/hlthaff.28.5.1406). While reliability analyses have been conducted
on similar performance measures, we plan to conduct our own reliability analysis
for this specific measure and propose a minimum number of cases for reporting.
The analysis will likely mirror the 2012 MSPB reliability analysis:
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/hospital-value-based-purchasing/Downloads/MSPBReliabilityAnalysis-Jul-18-12.pdf
Measure Specifications
- NQF Number (if applicable):
- Description: The measure constructs a clinically coherent group of
services to inform providers about resource use and effectiveness. It sums
Parts A and B payments related to a GI hemorrhage IP stay and attributes them
to the hospital where the index IP stay occurred. It includes subtypes for 1)
upper, 2) lower, 3) upper and lower, and 4) undefined bleeds.
- Numerator: The numerator of the GI Hemorrhage Clinical
Episode-Based Payment Measure is the risk-adjusted sum of a provider’s
spending and the preadmission and post-discharge medical services that are
clinically related to GI hemorrhage across a hospital’s eligible GI Hemorrhage
episodes during the period of performance. A clinical episode begins 3 days
prior to the initial (i.e., index) admission and extends 30 days following the
index hospital stay discharge date.
- Denominator: A count of the provider’s condition-specific episodes
during the period of performance.
- Exclusions: Episode Exclusions: 1. Beneficiaries who do not have
continuous enrollment in Medicare Parts A and B from 90 days prior to IP
admission through the end of the episode with Medicare as the primary payer.
2. Beneficiaries who enroll in Medicare Advantage during the period that
starts 90 days prior to IP admission through the end of the
episode.
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: Claims
- Measure Type: Efficiency
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Support
- Workgroup Rationale: MAP supported this measure because there is a
lot of room for improvement for mortalities following CABG surgeries and
believed this is valuable to the VBP program.
- Public comments received: 9
Rationale for measure provided by HHS
It is envisioned that this
measure will provide hospitals with procedure-specific information to help
improve patient safety and quality of care, thus reducing mortality rates. CABG
is a priority area for outcomes measure development because it is a common
procedure associated with considerable morbidity, mortality, and health care
spending. In 2007, there were 114,028 hospitalizations for CABG surgery and
137,721 hospitalizations for combined surgeries for CABG and valve procedures
(“CABG plus valve” surgeries) among Medicare FFS patients in the U.S. [1] CABG
surgeries are costly procedures that account for the majority of major cardiac
surgeries performed nationally. In fiscal year 2009, isolated CABG surgeries
accounted for almost half (47.6%) of all cardiac surgery hospital admissions in
Massachusetts. [2] In 2008, the average Medicare payment was $30,546 for CABG
without valve and $47,669 for CABG plus valve surgeries. [3] Mortality rates
following CABG surgery vary widely across hospitals. Our mean RSMR is 3.2% with
a range from 1.5%-7.9%. The median risk-standardized rate is 3.0% (25th and 75th
percentiles are 2.6% and 3.6%, respectively). Similarly, published data also
demonstrate variation in mortality rates. 1. Drye E, Krumholz H, Vellanky S,
Wang Y. Probing New Conditions and Procedures for New Measure Development: Yale
New Haven Health Systems Corporation; Center for Outcomes Research and
Evaluation.; 2009:1-7. 2. Massachusetts Data Analysis Center. Adult Coronary
Artery Bypass Graft Surgery in the Commonwealth of Massachusetts: Hospital and
Surgeons Risk-Standardized 30-Day Mortality Rates. In: Health MDoP, ed.
Boston2009:77. 3. Pennsylvania Health Care Cost Containment Council. Cardiac
Surgery in Pennsylvania 2008-2009. Harrisburg2011:60. 4. American New York
State Department of Health. Adult Cardiac Surgery in New York State
2006-20082010:54.
Measure Specifications
- NQF Number (if applicable): 2558
- Description: This measure estimates hospital-level,
risk-standardized mortality rates for Medicare fee-for-service (FFS) patients
who are 65 years of age or older and discharged from the hospital following a
qualifying isolated CABG surgery. (The endorsed specifications of the
measure are: The measure estimates a hospital-level, risk-standardized
mortality rate (RSMR) for patients 18 years and older discharged from the
hospital following a qualifying isolated CABG procedure. Mortality is defined
as death from any cause within 30 days of the procedure date of an index CABG
admission. The measure was developed using Medicare Fee-for-Service (FFS)
patients 65 years and older and was tested in all-payer patients 18 years and
older. An index admission is the hospitalization for a qualifying isolated
CABG procedure considered for the mortality outcome.)
- Numerator: The outcome for this measure is 30-day all-cause
mortality. Mortality is defined as death for any reason within 30 days of the
procedure date from the index admission for patients 65 and older discharged
from the hospital after undergoing isolated CABG . (The endorsed
specifications of the measure are: The outcome for this measure is 30-day
all-cause mortality. Mortality is defined as death for any reason within 30
days of the procedure date from the index admission for patients 18 and older
discharged from the hospital after undergoing isolated CABG
surgery.)
- Denominator: This claims-based measure can be used in either of two
patient cohorts: (1) patients aged 65 years or older or (2) patients aged 18
years or older. We have tested the measure in both age groups. The cohort
includes admissions for patients who receive a qualifying isolated CABG
procedure and with a complete claims history for the 12 months prior to
admission. If a patient has more than one qualifying isolated CABG admission
in a year, one hospitalization is randomly selected for inclusion in the
measure.(The endorsed specifications of the measure are: This claims-based
measure can be used in either of two patient cohorts: (1) patients aged 65
years or older or (2) patients aged 18 years or older. We have tested the
measure in both age groups.The cohort includes admissions for patients who
receive a qualifying isolated CABG procedure (see codes below) and with a
complete claims history for the 12 months prior to admission. For simplicity
of implementation and as testing demonstrated closely correlated patient-level
and hospital-level results using models with or without age interaction terms,
the only recommended modification to the measure for application to all-payer
data sets is replacement of the “Age-65” variable with a fully continuous age
variable.If a patient has more than one qualifying isolated CABG admission in
a year, one hospitalization is randomly selected for inclusion in the
measure.)
- Exclusions: For all cohorts: 1) Patients who leave hospital
against medical advice (AMA) 2) Patients with inconsistent or unknown vital
status or other unreliable data 3) Subsequent qualifying CABG procedures
during the measurement period are identified by the ICD-9 codes defining CABG
listed in denominator details. 4) Non-isolated CABG procedures (CABG
Surgeries that occur concomitantly with excluded procedures and procedure
groups).(The endorsed specifications of the measure are: Hospitalizations
are excluded if they meet any of the following criteria. Hospitalizations
for:1) Patients with inconsistent or unknown vital status or other unreliable
data.Rationale: We exclude these because the outcome cannot be adequately
measured in these patients.2) Patients who leave the hospital against medical
advice (AMA)Rationale: We exclude hospitalizations for patients who are
discharged AMA because providers did not have the opportunity to deliver full
care and prepare the patient for discharge.3) Patients with qualifying CABG
procedures subsequent to another qualifying CABG procedure during the
measurement periodRationale: CABG procedures are expected to last for several
years without the need for revision or repeat revascularization. A repeat CABG
procedure during the measurement period very likely represents a complication
of the original CABG procedure and is a clinically more complex and higher
risk surgery. We, therefore, select the first CABG admission for inclusion in
the measure and exclude subsequent CABG admissions from the
cohort.)
- HHS NQS Priority: Making Care Safer, Communication and Care
Coordination, Effective Prevention and Treatment
- HHS Data Source: Administrative claims. The Medicare data sources
used to create the measure were: 1) Medicare Part A inpatient and Outpatient
and Part B outpatient claims from the Standard Analytic File, including
inpatient and outpatient claims for the 12 months prior to an index admission.
2) Medicare Enrollment Database (EDB): This database contains Medicare
beneficiary demographic, benefit/coverage, and vital status information.. The
all-payer data source used to test the measure in patients 18 years and over
was: 1) 2006 California Patient Discharge Data (PDD), a large, linked database
of approximately 3 million adult discharges from more than 450 non-Federal
acute care hospitals
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Endorsed; MUC same as endorsed
version:Yes
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: NQF-Endorsed Measures
for Surgical Procedures
- Review for Importance: The measure meets the Importance
criteria(1a. Evidence, 1b. Performance Gap, 1c. High Impact)1a. Evidence: Y-
23; N- 0; 1b. Performance Gap: H- 16; M- 6; L- 0; I-0; 1c. Impact: H- 21; M-
1; L- 0; I-0Rationale:• Evidence provided by the developer displays a direct
relationship between the outcome of mortality and processes of care, including
timing of procedure in relation to cardiac events and various peri-operative
strategies.• The developer provided data from 2009-2011 showing that
risk-adjusted mortality rates ranged from 1.5% to 9.3%, demonstrating a gap in
performance.• The Committee agreed that an opportunity for improvement remains
on this measure.• In 2007, there were 114,028 hospitalizations for CABG
surgery and 137,721 hospitalizations for combined surgeries for CABG and valve
procedures (“CABG plus valve” surgeries) among Medicare FFS patients in the
United States, suggesting that this is a high priority.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria(2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity)2a. Reliability: H- 12;
M- 10; L-1; I-0; 2b. Validity: H- 14; M- 9; L- 0; I-0Rationale:• Reliability
testing was conducted at both the performance measure score and data element
level. A test-retest approach was performed with the correlation coefficient
being 0.32 which the Committee stated was sufficient for reliability.•
Validity was conducted at both the data element and measure score level. Face
validity was also assessed by a Technical Expert Panel using a six-point scale
obtained from the mortality measure as specified, provide an accurate
distinction between good and bad quality of care.
- Review for Feasibility: H- 21; M- 2; L- 0; I-0(3a. Clinical data
generated during care delivery; 3b. Electronic sources; 3c.Susceptibility to
inaccuracies/ unintended consequences identified 3d. Data collection strategy
can be implemented)Rationale: The Committee had no concerns regarding measure
logic feasibility based on the feasibility assessment using administrative
claims.
- Review for Usability: H- 8; M- 12; L- 3; I-0 (Meaningful,
understandable, and useful to the intended audiences for 4a. Public
Reporting/Accountability and 4b. Quality Improvement)Rationale: The Committee
discussed no concerns regarding usability and use. Although this measure is
not being currently reported, the developer stated plans for future
use.
- Review for Related and Competing Measures: This measure directly
competes with 0119 Risk-Adjusted Operative Mortality for CABG, Percent of
patients aged 18 years and older undergoing isolated CABG who die, including
both 1) all deaths occurring during the hospitalization in which the CABG was
performed, even if after 30 days, and 2) those deaths occurring after
discharge from the hospital, but within 30 days of the procedure.
- Endorsement Public Comments: Commenters generally expressed support
for the measure and the Committee's recommendation
forendorsement.
- Endorsement Committee Recommendation: Standing Committee
Recommendation for Endorsement: Y- 22;N-1
Consensus Standards Approval Committee (CSAC) Review (October 14,2014):
Y-16; N-0; A-0
Decision: Approved for Endorsement
Board of
Directors Vote: (October 27, 2014)
Decision: Ratified for
Endorsement
Appeals:Three appeals were received on this
measure:
- In summary, the appellants requested reconsideration of theendorsement
of measures #0119 and #2558, both of which measurerisk-adjusted mortality
rates within 30 days of CABG surgery.Many of the appellants questioned
whether 30-day mortality initself reflects quality of care, noting that it
is only oneindicator among many potential outcomes of interest to
patients.Moreover, appellants argued that a 30-day mortality measure mayhave
significant unintended consequences, including discouragingappropriate
palliative care or appropriate withdrawal ofpost-operative life-supporting
treatments despite patient orfamily preferences to limit life-supporting
care. Appellantsalso suggested that surgeons may be more likely to decline
toperform needed surgery on patients who are at high risk ofcomplications or
patients who have placed reasonable limits ontheir post-operative care. In
addition, appellants stated thatthese measures are susceptible to ‘gaming’
(e.g., keepingpatients alive until postoperative day 31 to avoid
penalties,and then transitioning to palliative care). In general,appellants
suggested that these measures are insufficientlysensitive to patient
preferences and that they perpetuatenon-patient-centered
care.
- NQF Response: The Surgery Standing Committee chairsappreciated the
concerns raised by the appellants, and agreedthat consideration of potential
unintended consequences is acritical part of the measure evaluation process.
As the Societyof Thoracic Surgeons (STS) and the Centers for Medicare
&Medicaid Services/Yale-Center for Outcomes Research andEvaluation
(CMS/Yale-CORE) describe in their responses, 30-daymortality measures should
be—and are—part of a balanced approachto measurement that takes into account
various indicators ofhealthcare quality and multiple outcomes that are
important topatients. The Committee co-chairs believe it remains importantto
measure postoperative mortality as one facet of quality, andare satisfied
that the developers have addressed the appellants’concerns in their
responses.
- Developer Response (Centers for Medicare & MedicaidServices): The
developer stated that there are various benefitsachieved by measuring 30-day
mortality following CABG surgery,such as providing hospitals with an
incentive to reducemortality through improved coordination of peri-operative
careand discharge planning. The state of California’s success inreducing
CABG mortality rates when using registry-basedmortality measures was cited
as an example of the benefits thatcan be achieved through use of such
measures.
- The developer agreed with the appellants that a multi-facetedapproach to
measurement is desirable, noting that their CABGmortality measure is
harmonized with a measure of readmissionsafter CABG surgery, which helps to
ensure that the full spectrumof peri-operative care and care coordination
can be assessed.
- However, while some appellants suggest that patient-reportedoutcomes
(PROs) be used to replace or supplement mortalitymeasurement, the developer
noted that there are some significantchallenges associated with PROs,
including the lack of routineor reliable collection of patient-reported
data.
- In response to the appellants’ concerns about surgeonswithholding
comfort care or declining needed surgery forhigh-risk patients, the
developers cited studies suggesting thatthere is little evidence that
provider behavior is influenced bythe public release of performance
data.
- Consensus Standards Approval Committee (CSAC) Review (January2015): On
January 13, 2015 the CSAC convened to discuss theappeals and voted to uphold
endorsement for both measures (with100% approval). CSAC members acknowledged
the appellants’concerns, but remained supportive of endorsement, noting
thatthe measures address an important health outcome and suggestingthat
while the concerns expressed by the appellants may havesome validity, the
benefits of the measure are highly likely tooutweigh potential unintended
consequences. Additionally, CSACmembers expressed satisfaction with the
developers’ responses tothe issues raised, including their approach to
monitoring forunintended consequences.
- Board of Directors Executive Committee (February 2015): TheExecutive
Committee upheld the CSAC decision and votedunanimously to uphold
endorsement of the measure
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because it
should first be placed in IQR and hospital compare for a year and then be in
the VBP program. MAP has previously advocated keeping a parsimonious set of
measures for the VBP program to avoid rewarding or penalizing a provider
mulitple times for the same case.
- Public comments received: 7
Rationale for measure provided by HHS
Medicare spending is
estimated to have been $525.0 billion in 2010 with annual growth rates projected
to be 6.3% for 2013 through 2020 due to both an increase in the Medicare
population as well as Medicare spending on each beneficiary[1]. Further
projections anticipate an exhaustion of Medicare‘s Hospital Insurance Trust Fund
(Part A) by 2024 [2]. The growth in spending is unsustainable and highlights the
need to understand the value of care Medicare buys with every dollar spent.
Given the urgency of the state of the Medicare Hospital Insurance Trust Fund and
the fact that Medicare pays for 40-50% of hospitalizations nationally [3],
hospital costs are a natural venue in which to deconstruct payments for Medicare
patients. Yet payments to hospitals are difficult to interpret in isolation.
Some high payment hospitals may have better clinical outcomes when compared with
low payment hospitals; other high payment hospitals may not. For this reason,
the value of hospital care is more clearly assessed when pairing hospital
payments with hospital quality. A measure of payments for Medicare patients to
hospitals that is aligned with current quality of care measures will facilitate
profiling hospital value (payments and quality). This measure will reflect
differences in the management of care for patients with pneumonia both during
hospitalization and immediately post-discharge. Pneumonia is a condition with
substantial range in costs of care and for which there are well-established
publicly reported quality measures and is therefore an ideal condition for
assessing relative value for an episode-of-care that begins with an acute
hospitalization. By focusing on one specific condition, value assessments may
provide actionable feedback to hospitals and incentivize targeted improvements
in care. 1. Ash AS, Byrne-Logan S. How Well Do Models Work? Predicting Health
Care Costs. Proceedings of the Section on Statistics in Epidemiology. American
Statistical Association. 1998. 2. Medpac. Report to the Congress: Medicare
Payment Policy 9/17/12 2012. 3. National Hospital Discharge Survey.
http://www.cdc.gov/nchs/nhds.htm. Accessed 08/07/2012.
Measure Specifications
- NQF Number (if applicable): 2579
- Description: This measure estimates hospital-level,
risk-standardized payment for a pneumonia episode of care starting with
inpatient admission to a short term acute-care facility and extending 30 days
post-admission for Medicare fee-for-service (FFS) patients who are 65 years of
age or older with a principal discharge diagnosis of pneumonia, aspiration
pneumonia, and sepsis in cases where sepsis is accompanied by secondary
diagnosis of pneumonia present on admission. (The endorsed specifications
of the measure are: This measure estimates hospital-level, risk-standardized
payment for a pneumonia episode of care starting with inpatient admission to a
short term acute-care facility and extending 30 days post-admission for
Medicare fee-for-service (FFS) patients who are 65 years of age or older with
a principal discharge diagnosis of pneumonia.)
- Numerator: This outcome measure does not have a traditional
numerator and denominator. We are using this field to define the outcome. The
outcome for this measure is a hospital-level, risk-standardized payment for
Medicare patients for a pneumonia episode-of-care. The payment timeframe
starts from the admission date of an index hospitalization through 30 days
post-admission. We include payments for the index admission, as well as
payments for subsequent inpatient, outpatient, skilled nursing facility, home
health, hospice, physician/clinical laboratory/ambulance services, supplier
Part B items, and durable medical equipment, prosthetics/orthotics, and
supplies. In order to compare payments for Medicare patients related to
clinical care, we remove geography and policy adjustment from our payment
calculation whenever possible. If the data for a specific care setting do not
allow for the removal of these adjustments, we calculate an average payment
for each item across all geographic areas and replace the claim payment amount
in the data with the average payment amount for that item.
- Denominator: This outcome measure does not have a traditional
numerator and denominator. We use this field to define the measure cohort.
The measure cohort includes admissions to non-federal, short-stay, acute-care
hospitals for Medicare FFS patients age 65 years and older with a principal
discharge diagnosis of pneumonia, or aspiration pneumonia, or sepsis in cases
where sepsis is accompanied by secondary diagnosis of pneumonia present on
admission. Patients must also have continuous enrollment in Medicare Part A
and Part B benefits for the 12 months prior to the index admission and 30 days
post- admission.
- Exclusions: The measure excludes patients with: 1. Incomplete
administrative data in the 30 days following the index admission (if alive)
2. Same or next day discharge and patient did not die or get transferred 3.
Transfers into the hospital 4. Inconsistent or unknown mortality status 5.
Unreliable data 6. Patients who leave hospital against medical advice (AMA)
7. Patients enrolled in hospice in year prior to admission or day of admission
8. Transfers to Federal hospitals 9. Patients without an index admission DRG
or DRG weight 10. Admissions within 30 days of a previous index
admission
- HHS NQS Priority: Communication and Care Coordination, Making Care
Affordable
- HHS Data Source: Administrative claims. Medicare administrative
claims data for certain Part A and Part B services in the 12 months prior to
and during the index admission are used for risk adjustment. The data also
contain price-standardized payments for Medicare patients across multiple care
settings, services, and supplies (i.e., inpatient, outpatient, SNF, home
health, hospice, physician/clinical laboratory/ambulance services, and durable
medical equipment, prosthetics/orthotics, and supplies). The
price-standardized payment data element is harmonized across CMS cost and
resource use measures
- Measure Type: Cost/Resource Use
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Endorsed; MUC same as endorsed
version:Yes
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has not been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Endorsing Cost and
Resource Use Measures: Phase 3
- Review for Importance: The measure meets the Importance criteria1a.
High Priority: H-17; M-5; L-0; I-0; IE-0; 1b. Opportunity for Improvement:
H-19; M-2; L-1; I-0; 1c. Measure Intent: H-18; M-4; L-0; I-0 1. Overall
Importance: H-18; M-4; L-0; I-0Rationale:• The Committee stated that the
measure is high priority given that pneumonia is one of the leading causes of
hospitalization for Medicare patients sixty-five years of age and older, with
Medicare paying roughly ten billion dollars in aggregate costs for
hospitalized beneficiaries with pneumonia. • The developer presented evidence
indicating that there is a threefold variation in cost for the medical
treatment of pneumonia patients, which the Committee agreed signified that
there is a substantial opportunity for improving the overall costs for
pneumonia patients.• The Committee stated that by using this measure in
conjunction with a measure capturing the quality of care for pneumonia
patients, there is an opportunity to begin to understand the value of the care
provided by the hospitals and other providers in treating this
condition.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria(2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity)2a. Reliability: H-10;
M-11; L-1; I-0 2b. Validity: H-3; M-18; L-1; I-0Rationale:• The Committee
stated that the measure specifications were precise and that the measure was
well-constructed. This measure captures risk-standardized payments for a
thirty-day episode of care for Medicare patients diagnosed admitted to the
hospital with a diagnosis of pneumonia through administrative claims data.•
The developer provided reliability testing at the level of the performance
measure score; testing was performed by calculating the Intraclass Correlation
Coefficient (ICC) score by calculating the risk standardized payment using a
split-sample of the combined 2008-2009 data from hospitals. The ICC score was
0.825, indicating significant agreement between the two samples, which the
Committee found sufficient.• The Committee questioned the validity of
specifying the measure for a thirty-day episode triggered by admission for
pneumonia, as the treatment of pneumonia may require care coordination
post-discharge that may extend past thirty days. The Committee stated that
this could affect payments captured during the post-discharge period,
artificially inflating or deflating the costs for some patients simply because
of the construct of the measure.• The Committee raised concerns regarding the
attribution approach and the implications for attribution of costs if a
patient were transferred to another hospital. The developer clarified that
only 0.4 percent of cohorts are transferred for pneumonia, which represents a
small number of beneficiaries. In the case of transfer patients, costs for the
patient will be attributed to the initial admitting hospital, as hospitals are
increasingly responsible for care delivered up to 30 days after discharge. The
Committee found this approach to attribution to be acceptable.• The Committee
stated concern that the low r-squared value (.07) for the risk model may
indicate that case mix is not being appropriately adjusted for through the
risk model. The developer clarified that at lower patient volumes, there is
less certainty when estimating cost. The measure uses a continuous outcome
which results in a more accurate estimate than would result from a binary
outcome. Additionally, the measure uses hierarchical risk modeling that
adjusts hospitals with low patient volume towards the mean. The Committee
found this explanation to be sufficient.• The Committee questioned whether
adjustments for sociodemographic status (SDS) factors should be incorporated
into the risk adjustment model. NQF clarified that it is in the early stages
of reviewing our policy on risk adjusting for SDS factors. The recommendations
for modifying NQF’s current policy on adjusting for SDS factors have not yet
been finalized. As such, we ask that Committees continue to evaluate measures
according to our current guidelines, that SDS factors are not included in the
risk adjustment model, but are used to stratify the measure. If in the future
the recommendations for adjusting for SDS factors become NQF policy, measures
that may be improved from incorporating these adjustments will be updated and
reviewed by the Committee through one of NQF’s measure maintenance
processes.
- Review for Feasibility: H-20; M-2; L-0; I-0(3a. Byproduct of Care
Processes; and 3b. Electronic sources; and 3c. Data Collection
Strategy)Rationale: The Committee stated that this measure is feasible to
implement because the measure is specified using administrative claims data
which is created as a byproduct of care delivery and available
electronically.
- Review for Usability: H-10; M-11; L-1; I-0(4a.
Accountability/transparency (used in accountability w/in 3 yr, public
reporting w/in 6 yr, or if new - credible plan); and 4b. Improvement –
progress demonstrated (if new - credible rationale); and 4c. Unintended
Consequences - benefits outweigh evidence of unintended negative consequences
(to patients/populations); and 4d. Measure Deconstruction – can be
deconstructed to facilitate transparency and understanding)Rationale:• The
Committee found the measure to be useful for providers, giving them access to
detailed data of cost for hospital care for pneumonia.• The Committee
questioned the availability of information on costs for providers other than
the hospital to which the patient has been attributed, stating that for this
measure to be most useful there needs to be documentation of the reimbursement
amounts for each provider treating the patient.
- Review for Related and Competing Measures: No related or competing
measures identified.
- Endorsement Public Comments: August 14, 2014 - September 12,
2014Comments received:• One measure-specific comment was received regarding
the appropriateness of the attribution approach for measure #2579. The
commenter suggested that the current attribution approach is inappropriate and
only reflects an episode-of-care attributed to a hospital as the responsible
entity and does not account for the care of multiple providers across the
health care delivery system. The commenter suggested this approach would be
more appropriate for an integrated health system or an organization accepting
bundled payments.• Two comments regarding risk adjustment for sociodemographic
status for this measure. Some commenters believed that it would be appropriate
to stratify claims by sociodemographic factors and document non-clinical
elements that negatively impact patient outcomes when calculating risk
adjusted costs.• One measure-specific comment was received regarding validity
of exclusions for measure this measure. A commenter proposed the inclusion of
ICD-9 code 507.0 in the denominator for aspiration pneumonia, which was
estimated to account for 15% of Medicare patients discharged with
pneumonia.Developer response:• Yale addressed the concern of integrating the
ICD-9 code 507.0 in the denominator for aspiration pneumonia and based on the
prevalence of the code, developers will plan to reevaluate including
aspiration pneumonia in future versions of the measure.Committee responses:•
The Committee acknowledged and many shared the concerns with the attribution
approach used in this measure; however, they also stated that hospitals are
increasingly responsible for care delivered up to 30 days after discharge.
Consequently, hospitals are in the unique position of being able to push
coordination of care, and this measure may serve as an impetus for this to
occur.• The Committee recognizes the importance of adequately adjusting for
sociodemographic status in the appropriate applications. While NQF continues
to work on their implementation of the guidance from the SDS Expert Panel,
measures currently under review have been recommended with additional guidance
to stratify for SDS, as appropriate.• Based on the NQF criteria for validity,
the Committee has agreed that this measure has met the criteria for validity
and has recommended it for endorsement. A few committee members support the
inclusion of ICD-9 code 507.0 within this measure, which will assist with
documenting the presence of pneumonia aspiration among admission.
- Endorsement Committee Recommendation: Standing Committee
Recommendation for Endorsement: Y-21; N-1.
NQF Member Voting: October
6, 2014- October 20, 2014
Representatives of 18 member organizations voted,
with 50% approval;consensus was not reached.
Consensus Standards
Approval Committee (CSAC) Vote: November 12,2014; Y-13, N-0
Endorsed with
the same conditions the CMS cardiovascular hospitallevel episode-based
measures from phase II.
Board of Directors Executive Committee
Vote: December 22, 2014
Ratified endorsement with the following
conditions:
- One- year Look Back Assessment of Unintended Consequences: NQFstaff will
work with Cost and Resource Standing Committee andCMS to determine a plan
for assessing potential unintendedconsequences of this measure in use. The
evaluation ofunintended consequences will be initiated in approximately
oneyear and possible changes to the measures based on this data.
- Consideration for SDS trial period: The Cost and Resource UseStanding
Committee will consider whether the measure should beincluded in the NQF
trial period for sociodemographic statusadjustments.
- Attribution: NQF will consider opportunities to address theattribution
issue.
Appeals: December 30, 2014 -January 28, 2015
No
appeals submitted.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because it
should first be placed in IQR and hospital compare for a year and then be in
the VBP program. MAP has previously advocated keeping a parsimonious set of
measures for the VBP program to avoid rewarding or penalizing a provider
mulitple times for the same case.
- Public comments received: 7
Rationale for measure provided by HHS
In 2012 total Medicare
expenditures were $574.2 billion, representing 3.6% of gross domestic product
(GDP). Current estimates suggest that Medicare spending will increase to 5.6% of
GDP by 2035 due to both an increase in the Medicare population as well as
Medicare spending on each beneficiary [1]. The growth in Medicare spending is
unsustainable and highlights the need to create incentives for high value care.
A critical first step in moving toward high value care is to define an approach
to calculate costs that is transparent to consumers and fair to providers. AMI
is a condition with a substantial range in costs of care and for which there are
well-established publicly reported quality measures; therefore, it is an ideal
condition for assessing relative value for an episode of care that begins with
an acute hospitalization. A measure of payments for Medicare patients during an
episode of care for AMI aligned with current quality of care measures will
facilitate profiling hospital value (payments and quality). This measure, which
uses standardized payments, reflects differences in the management of care for
patients with AMI both during hospitalization and immediately post-discharge. By
focusing on one specific condition, value assessments may provide actionable
feedback to hospitals and incentivize targeted improvements in care.
References: 1. Boards of Trustees of the Federal Hospital Insurance and Federal
Supplementary Medical Insurance Trust Funds, 2013 Annual Report, May 31, 2013.
2. Andrews RM, Elixhauser, A. The National Hospital Bill: Growth Trends and 2005
Update on the Most Expensive Conditions by Payer. Agency for Healthcare
Research and Quality. 2007.
Measure Specifications
- NQF Number (if applicable): 2431
- Description: This measure estimates hospital-level,
risk-standardized payment for an AMI episode-of-care starting with inpatient
admission to a short term acute-care facility and extending 30 days
post-admission for Medicare fee-for-service (FFS) patients who are 65 years of
age or older with a principal discharge diagnosis of AMI.
- Numerator: This outcome measure does not have a traditional
numerator and denominator. We are using this field to define the outcome. The
outcome for this measure is a hospital-level, risk-standardized payment for
Medicare patients for an AMI episode of care. The payment timeframe starts
from the admission date of an index hospitalization through 30 days
post-admission. We include payments for the index admission, as well as
payments for subsequent inpatient, outpatient, skilled nursing facility, home
health, hospice, physician/clinical laboratory/ambulance services, supplier
Part B items, and durable medical equipment, prosthetics/orthotics, and
supplies. In order to compare payments for Medicare patients related to
clinical care, we remove geography and policy adjustment from our payment
calculation whenever possible. If the data for a specific care setting do not
allow for the removal of these adjustments, we calculate an average payment
for each item across all geographic areas and replace the claim payment amount
in the data with the average payment amount for that item.
- Denominator: This outcome measure does not have a traditional
numerator and denominator. We use this field to define the measure cohort.
The measure cohort includes admissions to non-federal, short-stay, acute-care
hospitals for Medicare FFS patients aged 65 years and older with a principal
discharge diagnosis of AMI. Patients must also have continuous enrollment in
Medicare Part A and Part B benefits for the 12 months prior to the index
admission and 30 days post- admission.
- Exclusions: 1. Incomplete administrative data in the 30 days
following the index admission if discharged alive 2. Discharged alive on the
day of admission or the following day who were not transferred 3.
Inconsistent or unknown patient vital status, or other unreliable demographic
data (age and gender) 4. Admissions where patients are discharged against
medical advice (AMA) 5. Enrolled in the Medicare hospice program any time in
the 12 months prior to the index admission, including the first day of the
index admission 6. Transferred to federal hospitals 7. Transferred into the
hospital 8. Missing index DRG weight and provider received no
payment
- HHS NQS Priority: Making Care Affordable
- HHS Data Source: Administrative claims. The measure uses Medicare
administrative claims data and enrollment information. Medicare administrative
claims data for certain Part A and Part B services in the 12 months prior to
and during the index admission are used for risk adjustment. The data also
contain price-standardized payments for Medicare patients across multiple care
settings, services, and supplies (i.e., inpatient, outpatient, SNF, home
health, hospice, physician/clinical laboratory/ambulance services, and durable
medical equipment, prosthetics/orthotics, and supplies). The
price-standardized payment data element is harmonized across CMS cost and
resource use measures.
- Measure Type: Cost/Resource Use
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Endorsed; MUC same as endorsed
version:Yes
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Endorsing Cost and
Resource Use Measures: Phase 2
- Review for Importance: 1a. High Priority, 1b. Opportunity for
Improvement, 1c. Measure Intent)IM.1. High Priority: H-20; M-1; L-0; I-0 IM.2.
Opportunity for Improvement: H-10; M-10; L-0; I-1 IM.3. Measure Intent: H-16;
M-5; L-0; I-0 Overall Importance: H-16; M-5; L-0; I-0Rationale:• The Committee
agreed that Acute Myocardial Infarction (AMI) is a high-priority area for
measurement because it is a common condition that drives spending in
hospitals.• The Committee questioned the opportunity for improvement because
the inner quartile of performance gets very narrow after risk adjustment. The
developers responded that this measure is intended to be paired with quality
measures and that the opportunity for improvement must be considered with the
opportunity to improve the quality of care when factoring in the cost of the
care provided.• Additionally, the Committee was concerned with the attribution
of post-acute expenses to the admitting hospital. The developers responded
that it is critical to capture those costs because the current system is setup
to incentivize pushing those payments out into the post-discharge time period.
Hospitals can act as catalysts in their communities for improving care and
health decision-making. | The Committee raised a question about the episode
definition as 30 days from the date of admission and the potential need for
alignment with the Medicare Spending per Beneficiary (MSPB) measure that
defines a period of 30 days post-discharge. The developers responded that
these specifications are aligned with a corresponding AMI mortality measure to
be used together to assess value.
- Review for Scientific Acceptability: 2a. Reliability - precise
specifications, testing; 2b. Validity - testing, threats to validity)2a.
Reliability: H-3; M-16; L-2; I-0 2b. Validity: H-0; M-9; L-7; I-4Rationale:•
The Committee raised concern about the ability to assess performance of low
volume hospitals given the hierarchical modeling approach and the potential
implications it could pose for the reliability and validity of the measure.
The developers responded that at lower patient volumes, the less certainty you
have about your estimates for cost. This measure uses a continuous outcome so
the estimate is more accurate than a binary outcome. Additionally, this
measure uses hierarchical risk modeling that adjusts hospitals with low
patient volume towards the mean. Furthermore, reporting is only done for
hospitals that have 25 or more cases.• The Committee further questioned the
decision to attribute the entire cost of an episode to the initial hospital in
the case of a transfer to another facility. The developers responded that the
decision was made not to exclude these cases because transfers account for
approximately 8 percent of AMI episodes. This represented too many cases to
exclude. Furthermore, the initial hospital begins the episode of care and can
have a great influence over the coordination of care.• The Committee raised
concerns about whether the supplied reliability testing was done with the
amount of data required by the specification of the measure. The measure is
specified for a 12-month period and the testing used combined 2008 and 2009
data. The developers responded that the measure will eventually be implemented
with three years of data but when the testing was performed, only two years of
data was available. The decision to include three years of data was made to
include as many hospitals in the measurement as possible. Many hospitals do
not have 25 AMI cases in a year and would therefore not meet the threshold for
reporting.• In addition to the risk adjustment provided in the overarching
issues section, the Committee was concerned that the developer did not do
empiric measure-level validity testing for the measure as specified. The
developers acknowledged that they relied on prior research on risk adjustment
testing for mortality measures and also relied on face validity testing with
their technical expert panel.
- Review for Feasibility: H-18; M-3; L-0; I-0(3a. Byproduct of Care
Processes; and 3b. Electronic sources; and 3c. Data Collection
Strategy)Rationale:• The Committee had no concerns about the feasibility of
the measure.
- Review for Usability: H-12; M-7; L-2; I-0(4a.
Accountability/transparency (used in accountability w/in 3 yr, public
reporting w/in 6 yr, or if new - credible plan); and 4b. Improvement –
progress demonstrated (if new - credible rationale); and 4c. Unintended
Consequences - benefits outweigh evidence of unintended negative consequences
(to patients/populations); and 4d. Measure Deconstruction – can be
deconstructed to facilitate transparency and understanding)Rationale:• The
Committee raised concern about the number of hospitals falling in the
“average” range for the measure – 78 percent. 15 percent were rated “high” and
7 percent “low”.• The Committee did appreciate the data breakdown provided to
hospitals as a result of the measure.
- Review for Related and Competing Measures: No related or competing
measures noted.
- Endorsement Public Comments: April 21, 2014 – May 21, 2014Several
supportive comments for the measure were received, with commenters indicating
that the measure addresses an area of high morbidity, mortality, and
healthcare costs. Commenters stated that information shared by CMS with
hospitals will allow for identification of high/low cost areas and focused
improvement. Additionally, commenters raised several issues with the measure,
which were discussed during the in-person meeting:
- Appropriateness of attribution approach
- Commenters stated that attributing the cost of the entire episode to
the admitting hospital may be inappropriate to attribute the cost of the
episode to the hospital as much of the care happens in an outpatient
setting. Commenters stated that measures should assess processes and
outcomes over which the measured entity (e.g., hospital, physician group)
can exercise a reasonable level of control, and that these measures may be
more appropriate for an organization accepting bundled payments on behalf
of all measured entities.
- The Committee acknowledged this concern; however, the Committee stated
that increasingly hospitals are responsible for care delivered up to 30
days after discharge. Consequently, hospitals are in the unique position
of being able to push coordination of care, and this measure may serve as
an impetus for this to occur.
- Adequacy of risk adjustment model
- Several commenters stated that the low r-squared values for the
measure (0.05) indicated that the risk model did not account for enough of
the variation in measure scores and may not adequately account for patient
case mix and severity. Moreover, commenters believe that the low level of
reliability demonstrated illustrated another fundamental flaw of both
measures—that they fail to adequately account for complicating conditions
that patients have prior to an episode of care.
- The developers explained that at lower patient volumes, there is less
certainty when estimating cost. The measure uses a continuous outcome
which results in a more accurate estimate than would result from a binary
outcome. Additionally, the measure uses hierarchical risk modeling that
adjusts hospitals with low patient volume towards the mean. o Approach to
addressing transfer patients Several commenters stated concern that the
initial admitting hospital would be attributed cost for the episode when
transferring patients to a second hospital, as the initial admitting
hospital may have little control over the care that happens after the
transfer.
- The Committee acknowledged this concern; however, the Committee stated
that increasingly hospitals are responsible for care delivered up to 30
days after discharge.
- Risk adjustment for socio-demographic factors
- Several commenters stated that the risk adjustment models for the
measures should capture socio-demographic factors, as there is robust
evidence that such factors affect health outcomes, including resource
use.
- NQF acknowledged these concerns and clarified that NQF is in the early
stages of reviewing our policy on risk adjusting for socio-demographic
factors. The report referenced is a draft report that has recently been
reviewed during an NQF member and public comment period; the
recommendations have not yet been finalized. As such, we ask that
Committees continue to evaluate measures according to our current
guidelines, that measures not be adjusted for socio-demographic variables.
If in the future the recommendations for adjusting for socio-demographic
variables become NQF policy, measures needing this adjustment will be
updated and reviewed by the Committee through measure maintenance.
- The Committee acknowledged that the timing of the NQF risk adjustment
report is not ideal; however, given the current NQF policy on adjusting
for sociodemographic variables, the Committee requested that a
recommendation be issued with the measure that when reported, the results
should be stratified by sociodemographic
variables.
- Endorsement Committee Recommendation: Standing Committee
Recommendation for Endorsement: Y-12; N-9 [Consensus not reached]• After
considering all comments and thorough discussion, the Committee requested the
opportunity to revote on endorsement for the measure. The results of that vote
are below:o Yes- 14; No-7• The measure is recommended for endorsement and
pursuant with NQF process will be posted for NQF member voting. 7. NQF
Member Voting: June 17, 2014-July 2, 2014• Representatives of 17 member
organizations voted.• With 40% of the councils approving the measure, the
voting results indicated that consensus was not reached among the membership.•
To further understand the rationale for the membership votes, NQF hosted
conference calls with council leaders and NQF members to further discuss the
issues.o 73 participants from 7 councils with broad distribution across the
councils attended the membership call.o Staff compiled the major themes that
arose from these consensus-building calls and shared them with the CSAC.
8. Consensus Standards Approval Committee (CSAC) Vote: August 12, 2014, Y-10;
N-3• The Consensus Standards Approval Committee (CSAC) pulled this measure on
July 10, 2014, to further discuss NQF Member voting results indicating that
consensus was not reached. • NQF hosted a call on July 31, 2014 for
members to discuss their concerns about the measure.• CSAC reviewed the member
voting results and themes from the membership call and endorsed this measure.
9. Board of Directors (BOD) Vote: November 5, 2014• The BOD ratified
endorsement with the following conditions:o One- year Look Back Assessment of
Unintended Consequences: NQF staff will work with Cost and Resource Standing
Committee and CMS to determine a plan for assessing potential unintended
consequences of this measure in use. The evaluation of unintended consequences
will be initiated in approximately one year and possible changes to the
measures based on this data.o Consideration for SDS trial period: The Cost and
Resource Use Standing Committee will consider whether the measure should be
included in the NQF trial period for sociodemographic status adjustments.o
Attribution: NQF will consider opportunities to address the attribution issue.
10. Appeals: November 7, 2014- December 9, 2014• NQF received an appeal
for this measure from the American College of Cardiology (ACC). The
appeallants noted concerns with attribution, the use of stand-alone cost
measures and the adjustment for sociodemographic variables.• CSAC reviewed the
appeal on January 13, 2015, and voted to uphold endorsement (92% approval).•
The BOD Executive Committee reviewed the appeal on February 4, 2015, and voted
to uphold endorsement.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because it
should first be placed in IQR and hospital compare for a year and then be in
the VBP program. MAP has previously advocated keeping a parsimonious set of
measures for the VBP program to avoid rewarding or penalizing a provider
mulitple times for the same case.
- Public comments received: 8
Rationale for measure provided by HHS
Medicare spending is
estimated to have been $525.0 billion in 2010 with annual growth rates projected
to be 6.3% for 2013 through 2020 due to both an increase in the Medicare
population as well as Medicare spending on each beneficiary [1]. Further
projections anticipate an exhaustion of Medicare‘s Hospital Insurance Trust Fund
(Part A) by 2024 [2]. The growth in spending is unsustainable and highlights the
need to understand the value of care Medicare buys with every dollar spent.
Given the urgency of the state of the Medicare Hospital Insurance Trust Fund and
the fact that Medicare pays for 40-50% of hospitalizations nationally [3],
hospital costs are a natural venue in which to deconstruct payments for Medicare
patients. Yet payments to hospitals are difficult to interpret in isolation.
Some high payment hospitals may have better clinical outcomes when compared with
low payment hospitals; other high payment hospitals may not. For this reason,
the value of hospital care is more clearly assessed when pairing hospital
payments with hospital quality. A measure of payments for Medicare patients to
hospitals that is aligned with current quality of care measures will facilitate
profiling hospital value (payments and quality). This measure will reflect
differences in the management of care for patients with heart failure both
during hospitalization and immediately post-discharge. Heart failure is a
condition with substantial range in costs of care and for which there are
well-established publicly reported quality measures and is therefore an ideal
condition for assessing relative value for an episode-of-care that begins with
an acute hospitalization. By focusing on one specific condition, value
assessments may provide actionable feedback to hospitals and incentivize
targeted improvements in care. 1. Ash AS, Byrne-Logan S. How Well Do Models
Work? Predicting Health Care Costs. Proceedings of the Section on Statistics in
Epidemiology. American Statistical Association. 1998. 2. Medpac. Report to the
Congress: Medicare Payment Policy 9/17/12 2012. 3. National Hospital Discharge
Survey. http://www.cdc.gov/nchs/nhds.htm. Accessed 08/07/2012.
Measure Specifications
- NQF Number (if applicable): 2436
- Description: This measure estimates a hospital-level,
risk-standardized payment for a heart failure episode-of-care starting with
inpatient admission to a short term acute-care facility and extending 30 days
post-admission for Medicare fee-for-service (FFS) patients who are 65 years of
age or older with a principal discharge diagnosis of heart
failure.
- Numerator: Note: This outcome measure does not have a traditional
numerator and denominator. We are using this field to define the outcome. The
outcome for this measure is a hospital-level, risk-standardized payment for
Medicare patients for a heart failure episode of care. The payment timeframe
starts from the admission date of an index hospitalization through 30 days
post-admission. We include payments for the index admission, as well as
payments for subsequent inpatient, outpatient, skilled nursing facility, home
health, hospice, physician/clinical laboratory/ambulance services, supplier
Part B items, and durable medical equipment, prosthetics/orthotics, and
supplies. In order to compare payments for Medicare patients related to
clinical care, we remove geography and policy adjustment from our payment
calculation whenever possible. If the data for a specific care setting do not
allow for the removal of these adjustments, we calculate an average payment
for each item across all geographic areas and replace the claim payment amount
in the data with the average payment amount for that item.
- Denominator: This outcome measure does not have a traditional
numerator and denominator. We use this field to define the measure cohort.
The measure cohort includes admissions to non-federal, short-stay, acute-care
hospitals for Medicare FFS patients aged 65 years and older with a principal
discharge diagnosis of HF. Patients must also have continuous enrollment in
Medicare Part A and Part B benefits for the 12 months prior to the index
admission and 30 days post- admission.
- Exclusions: 1. Incomplete administrative data in the 30 days
following the index admission if discharged alive 2. Discharged alive on the
day of admission or the following day who were not transferred 3.
Inconsistent or unknown patient vital status, or other unreliable demographic
data (age and gender) 4. Admissions where patients are discharged against
medical advice (AMA) 5. Enrolled in the Medicare hospice program any time in
the 12 months prior to the index admission, including the first day of the
index admission 6. Transferred to federal hospitals 7. Missing index
diagnosis-related group (DRG) weight and provider received no payment 8.
Hospitalizations for patients who receive a heart transplant during the
episode of care 10. Hospitalizations for patients who receive a Left
Ventricular Assist Device (LVAD) during the episode of care
- HHS NQS Priority: Making Care Affordable
- HHS Data Source: Administrative claims. The measure uses Medicare
administrative claims data and enrollment information. Medicare administrative
claims data for certain Part A and Part B services in the 12 months prior to
and during the index admission are used for risk adjustment. The data also
contain price-standardized payments for Medicare patients across multiple care
settings, services, and supplies (i.e., inpatient, outpatient, SNF, home
health, hospice, physician/clinical laboratory/ambulance services, and durable
medical equipment, prosthetics/orthotics, and supplies). The
price-standardized payment data element is harmonized across CMS cost and
resource use measures.
- Measure Type: Cost/Resource Use
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Endorsed; MUC same as endorsed
version:Yes
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Endorsing Cost and
Resource Use Measures: Phase 2
- Review for Importance: IM.1. High Priority; IM.2. Opportunity for
Improvement; and IM.3. Measure Intent)IM.1. High Priority: H-14; M-4; L-3; I-0
IM.2. Opportunity for Improvement: H-11; M-9; L-1; I-0 IM.3. Measure Intent:
H-11; M-9; L-1; I-0 Overall Importance: H-8; M-13; L-0; I-0Rationale: The
Committee agreed that Heart Failure (HF) is a high-priority area for
measurement because it is a common condition that drives spending in hospitals
and systems.
- Review for Scientific Acceptability: 2. Scientific Acceptability of
Measure Properties(2a. Reliability - precise specifications, testing; 2b.
Validity - testing, threats to validity)2a. Reliability: H-7; M-11; L-2; I-1
2b. Validity: H-0; M-9; L-6; I-5Rationale:• The Committee questioned the
description of a “typical heart failure” patient considering that many
patients have chronic heart failure and a hospitalization occurs for an acute
incidence of the disease. The developer responded that they meant non-LVAD,
non-transplant, non-major surgical procedure heart failure patients. These
conditions dramatically change the payment outcome. They are sicker patients
and were excluded from the measure.• The Committee also questioned the
methodology for choosing the index admission for patients who might have
multiple hospitalizations in the same year for heart failure. The developer
responded that the hospitalization is randomly selected and any
re-hospitalization within 30 days of that index admission would be considered
a re-admission and counted in the total hospitalization cost.• The Committee
expressed concern that attributing costs to hospitals was inappropriate for
heart failure patients and that the real accountability should be with the
ambulatory providers. Furthermore, the 30-day time period for costs does not
align with the typical disease progression for a heart failure patient. A
longer period, perhaps 12 months, would be more appropriate for the chronic
nature of this disease.• The developer defended the attribution to the
hospital by stating that heart failure is a leading cause of hospitalization
for the elderly and it represented a high-leverage opportunity to measure and
evaluate spending. Additionally, the 30-day time period was short enough that
the associated spending would be attributable to the hospital admission.• In
addition to the risk adjustment discussion provided in the overarching issues
section, the Committee was concerned that the developer did not do empiric
measure-level validity testing for the measure as specified. The developers
acknowledged that they relied on prior research on risk adjustment testing for
mortality measures and also relied on face validity testing with their
technical expert panel.
- Review for Feasibility: 3. Feasibility: H-16; M-3; L-0; I-0(3a.
Byproduct of Care Processes; and 3b. Electronic sources; and 3c. Data
Collection Strategy)Rationale:• The Committee had no concerns about the
feasibility of the measure.
- Review for Usability: 4. Use and Usability: H-4; M-10; L-6; I-1(4a.
Accountability/transparency (used in accountability w/in 3 yr, public
reporting w/in 6 yr, or if new - credible plan); and 4b. Improvement –
progress demonstrated (if new - credible rationale); and 4c. Unintended
Consequences - benefits outweigh evidence of unintended negative consequences
(to patients/populations); and 4d. Measure Deconstruction – can be
deconstructed to facilitate transparency and understanding)Rationale:• The
Committee had no concerns about the Use and Usability of the
measure.
- Review for Related and Competing Measures: 5. Related and Competing
Measures• No related or competing measures noted.
- Endorsement Public Comments: 6. Public and Member Comment: April
21, 2014 – May 21, 2014• Several supportive comments for the measure were
received, with commenters indicating that the measure addresses an area of
high morbidity, mortality, and healthcare costs. Commenters stated that
information shared by CMS with hospitals will allow for identification of
high/low cost areas and focused improvement. Additionally, commenters raised
several issues with the measure, which were discussed during the in-person
meeting:o Appropriateness of attribution approach§ Commenters stated that
attributing the cost of the entire episode to the admitting hospital may be
inappropriate to attribute the cost of the episode to the hospital as much of
the care happens in an outpatient setting. Commenters stated that measures
should assess processes and outcomes over which the measured entity (e.g.,
hospital, physician group) can exercise a reasonable level of control, and
that these measures may be more appropriate for an organization accepting
bundled payments on behalf of all measured entities.§ The Committee
acknowledged this concern; however, the Committee stated that increasingly
hospitals are responsible for care delivered up to 30 days after discharge.
Consequently, hospitals are in the unique position of being able to push
coordination of care, and this measure may serve as an impetus for this to
occur.o Adequacy of risk adjustment model§ Several commenters stated that the
low r-squared values for the measure (0.03) indicated that the risk model did
not account for enough of the variation in measure scores and may not
adequately account for patient case mix and severity. Moreover, commenters
believe that the low level of reliability demonstrated illustrated another
fundamental flaw of both measures—that they fail to adequately account for
complicating conditions that patients have prior to an episode of care.§ The
developers explained that at lower patient volumes, there is less certainty
when estimating cost. The measure uses a continuous outcome which results in a
more accurate estimate than would result from a binary outcome. Additionally,
the measure uses hierarchical risk modeling that adjusts hospitals with low
patient volume towards the mean.o Approach to addressing transfer patients§
Several commenters stated concern that the initial admitting hospital would be
attributed cost for the episode when transferring patients to a second
hospital, as the initial admitting hospital may have little control over the
care that happens after the transfer.§ The Committee acknowledged this
concern; however, the Committee stated that increasingly hospitals are
responsible for care delivered up to 30 days after discharge.o Risk adjustment
for socio-demographic factors§ Several commenters stated that the risk
adjustment models for the measures should capture socio-demographic factors,
as there is robust evidence that such factors affect health outcomes,
including resource use.§ NQF acknowledged these concerns and clarified that
NQF is in the early stages of reviewing our policy on risk adjusting for
socio-demographic factors. The report referenced is a draft report that has
recently been reviewed during an NQF member and public comment period; the
recommendations have not yet been finalized. As such, we ask that Committees
continue to evaluate measures according to our current guidelines, that
measures not be adjusted for socio-demographic variables. If in the future the
recommendations for adjusting for socio-demographic variables become NQF
policy, measures needing this adjustment will be updated and reviewed by the
Committee through measure maintenance.§ The Committee acknowledged that the
timing of the NQF risk adjustment report is not ideal; however, given the
current NQF policy on adjusting for sociodemographic variables, the Committee
requested that a recommendation be issued with the measure that when reported,
the results should be stratified by sociodemographic variables.• After
considering all comments and thorough discussion, the Committee requested the
opportunity to revote on endorsement for the measure. The results of that vote
are below:o Yes- 13; No-8• The measure is recommended for endorsement and
pursuant with NQF process will be posted for NQF member voting.
- Endorsement Committee Recommendation: Standing Committee
Recommendation for Endorsement: Y-10; N-11 [Consensus not reached] After
considering all comments and thorough discussion, the Committee requested the
opportunity to revote on endorsement for the measure. The results of that vote
are below:o Yes- 13; No-8• The measure is recommended for endorsement and
pursuant with NQF process will be posted for NQF member voting. 7. NQF
Member Voting: June 17, 2014- July 2, 2014• Representatives of 17 member
organizations voted.• With 40% of the councils approving the measure, the
voting results indicated that consensus was not reached among the membership.•
To further understand the rationale for the membership votes, NQF hosted
conference calls with council leaders and NQF members to further discuss the
issues.o 73 participants from 7 councils with broad distribution across the
councils attended the membership call.o Staff compiled the major themes that
arose from these consensus-building calls and shared them with the CSAC. 8.
Consensus Standards Approval Committee (CSAC) Vote: August 12, 2014, Y-10;
N-3• The Consensus Standards Approval Committee (CSAC) pulled this measure on
July 10, 2014, to further discuss NQF Member voting results indicating that
consensus was not reached.• NQF hosted a call on July 31, 2014 for members to
discuss their concerns about the measure.• CSAC reviewed the member voting
results and themes from the membership call and endorsed this measure. 9.
Board of Directors Vote: November 5, 2014• The EC ratified endorsement with
the following conditions:o One- year Look Back Assessment of Unintended
Consequences: NQF staff will work with Cost and Resource Standing Committee
and CMS to determine a plan for assessing potential unintended consequences of
this measure in use. The evaluation of unintended consequences will be
initiated in approximately one year and possible changes to the measures based
on this data.o Consideration for SDS trial period: The Cost and Resource Use
Standing Committee will consider whether the measure should be included in the
NQF trial period for sociodemographic status adjustments. 10. Appeals:
November 7, 2014- December 9, 2014• NQF received an appeal for this measure
from the American College of Cardiology (ACC). The appeallants noted concerns
with attribution, the use of stand-alone cost measures and the adjustment for
sociodemographic variables.• CSAC reviewed the appeal on January 13, 2015, and
voted to uphold endorsement (92% approval).• The BOD Executive Committee
reviewed the appeal on February 4, 2015, and voted to uphold
endorsement.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because it
should first be placed in IQR and hospital compare for a year and then be in
the VBP program. MAP has previously advocated keeping a parsimonious set of
measures for the VBP program to avoid rewarding or penalizing a provider
mulitple times for the same case.
- Public comments received: 8
Rationale for measure provided by HHS
Due to their frequency and
cost, THA and TKA are priority areas for outcome measure development. More than
one third of the US population 65 years and older suffers from osteoarthritis
[1]. Between 2009 and 2012, there were 337,419 THA procedures and 750,569 TKA
procedures for Medicare fee-for-service patients 65 years and older [2].
Estimates place the annual insurer cost of osteoarthritis in the US at $149
billion, with Medicare direct payments to hospitals for THA/TKA exceeding $15
billion annually [3]. Further, there are conflicting data regarding costs after
total joint arthroplasty, with evidence to support both increased [4] and
decreased costs [5] following arthroplasty, suggesting there is great variation
in the costs of a full episode of care for THA and TKA. The goal of
hospital-level resource use measurement is to capture the full spectrum of care
in order to incentivize collaboration and shared responsibility for improving
patients’ health and reducing the burden of their disease. Variation in the cost
of a THA or TKA episode of care is often related to the quality of care, where
complications and readmissions increase the total payment for post-surgical
care. Given the well-documented variation in readmission and complication rates
following THA and TKA, there is expected variation in total episode of care
costs for the procedures [6]. Birkmeyer et al. found that the average 30-day
cost increased by $2,436 among hospitals with the highest quintile of
complication rates, compared to the lowest quintile following THA [7]. The same
study also found that rehabilitation costs accounted for 50% of “excess”
payments among those undergoing THA. Miller et al. found that a major driver of
differences in episode payments for THA was that hospitals within Accountable
Care Organizations (ACO) had smaller payments for post-discharge care compared
to non-ACO hospitals [8]. Taken together, these studies suggest that much of the
variation in total episode costs arises in the post-acute setting. Health
systems have taken notice of opportunities to improve value by encouraging
collaboration of care between hospitals and post-acute providers. [10].
Transparency regarding the variation of episode of care payments triggered by
THA and TKA helps to guide health systems and providers towards improvement in
the value of care. 1. Centers for Disease Control and Prevention (CDC).
Osteoarthritis. 2011; http://www.cdc.gov/arthritis/basics/osteoarthritis.htm.
Accessed August 13, 2013. 2. Suter LG, Grady JN, Lin Z, et al. 2013 Measure
Updates and Specifications: Elective Primary Total Hip Arthroplasty (THA) And/Or
Total Knee Arthroplasty (TKA) All-Cause Unplanned 30-Day Risk-Standardized
Readmission Measure (Version 2.0). March 2013. 3. Miller DC, Gust C, Dimick JB,
Birkmeyer N, Skinner J, Birkmeyer JD. Large variations in Medicare payments for
surgery highlight savings potential from bundled payment programs. Health
affairs (Project Hope). Nov 2011;30(11):2107-2115. 4. Bozic KJ, Stacey B, Berger
A, Sadosky A, Oster G. Resource utilization and costs before and after total
joint arthroplasty. BMC health services research. 2012;12:73. 5. Hawker GA,
Badley EM, Croxford R, et al. A population-based nested case-control study of
the costs of hip and knee replacement surgery. Med Care. 2009;47(7):732-741. 6.
Suter LG, et al., Medicare Hospital Quality Chartbook 2013: Performance Report
on Outcome Measures, 2013. 7. Birkmeyer JD, Gust C, Dimick JB, Birkmeyer NJ,
Skinner JS. Hospital quality and the cost of inpatient surgery in the United
States. Annals of surgery. 2012;255(1):1-5. 8. Miller DC, Ye Z, Gust C,
Birkmeyer JD. Anticipating the effects of accountable care organizations for
inpatient surgery. JAMA surgery. Jun 2013;148(6):549-554. 9. CMS. Bundled
Payments for Care Improvement (BPCI) Initiative: General Information. http:/ /
innovation.cms.gov/initiatives/bundled?payments/ [accessed Jan 7, 2014] 10.
Miller DC, Ye Z, Gust C, Birkmeyer JD. Anticipating the effects of accountable
care organizations for inpatient surgery. JAMA surgery. Jun 2013;148(6):549-554.
Measure Specifications
- NQF Number (if applicable):
- Description: This measure estimates hospital-level,
risk-standardized payments for a primary elective total THA/TKA episode of
care starting with inpatient admission to a short term acute-care facility for
Medicare fee-for-service (FFS) patients who are 65 years of age or
older.
- Numerator: This outcome measure does not have a traditional
numerator and denominator. We are using this field to define the outcome. The
outcome for this measure is a hospital-level, risk-standardized payment for
Medicare patients for a primary elective total THA/TKA episode of care. The
payment timeframe starts from the admission date of an index hospitalization
through 90 days post-admission. We include payments for the index admission,
as well as payments for subsequent inpatient, outpatient, skilled nursing
facility, home health, hospice, physician/clinical laboratory/ambulance
services, supplier Part B items, and durable medical equipment,
prosthetics/orthotics, and supplies. In order to compare payments for Medicare
patients related to clinical care, we remove geography and policy adjustment
from our payment calculation whenever possible. If the data for a specific
care setting do not allow for the removal of these adjustments, we calculate
an average payment for each item across all geographic areas and replace the
claim payment amount in the data with the average payment amount for that
item
- Denominator: This outcome measure does not have a traditional
numerator and denominator. We use this field to define the measure cohort.
The measure cohort includes admissions to non-federal, short-stay, acute-care
hospitals for Medicare FFS patients aged 65 years and older with a qualifying
THA/TKA procedure, not transferred in from another facility. Patients must
also have continuous enrollment in Medicare Part A and Part B benefits for the
12 months prior to the index admission and 90 days
post-admission.
- Exclusions: 1) Patients without complete administrative data in the
90 days following the index admission, if alive 2) Patients with no payment
information during the index admission 3) Patients discharged against medical
advice (AMA) 4) Patients transferred to federal hospitals 5) Patients with
more than two THA/TKA procedure codes during the admission 6) Patients
transferred into the hospital
- HHS NQS Priority: Making Care Affordable
- HHS Data Source: Administrative claims. The measure was developed
using claims data from seven standard analytic files contained in the Chronic
Condition Warehouse (CCW) data. The CCW data are derived from the Medicare
claims in the Standard Analytic Files. The CCW data contain data from the
Medicare FFS institutional and non-institutional claims, enrollment and
eligibility information, and assessment data for up to 100% of the Medicare
FFS beneficiary population for particular conditions and procedures. The data
are organized by predefined chronic conditions, but can also be used to define
individualized patient cohorts, as described below. The annual CCW datasets
include claims data from all seven standard files (inpatient, skilled nursing
facility, outpatient, home health agency, hospice, carrier, and durable
medical equipment) that can be linked across care settings, services,
supplies, and years using a unique patient identifier. Specific information
available in the CCW data includes diagnosis codes, procedure codes,
quantity/units of services used, and payments made by CMS, patients, and other
insurers to providers.
- Measure Type: Cost/Resource Use
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not support
- Workgroup Rationale: MAP did not support this measure because it
would overlap with the current Medicare Spending Per Beneficiary Measure and
MAP has previously advocated keeping a parsimonious set of measures for the
VBP program to avoid rewarding or penalizing a provider mulitple times for the
same case.
- Public comments received: 9
Rationale for measure provided by HHS
Episode-based performance
measurement allows meaningful comparisons between providers based on resource
use for certain clinical conditions or procedures, as noted in the NQF report
for the “Episode Grouper Evaluation Criteria” project (available at
http://www.qualityforum.org/Publications/2014/09/Evaluating_Episode_Groupers__A_Report_from_the_National_Quality_Forum.aspx)
and in various peer-reviewed articles (e.g., Hussey, P. S., Sorbero, M. E.,
Mehrotra, A., Liu, H., & Damberg, S. L. (2009). Episode-Based Performance
Measurement and Payment: Making It a Reality. Health Affairs, 28(5), 1406-1417.
doi:10.1377/hlthaff.28.5.1406). While reliability analyses have been conducted
on similar performance measures, we plan to conduct our own reliability analysis
for this specific measure and propose a minimum number of cases for reporting.
The analysis will likely mirror the 2012 MSPB reliability analysis:
https://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/hospital-value-based-purchasing/Downloads/MSPBReliabilityAnalysis-Jul-18-12.pdf
Measure Specifications
- NQF Number (if applicable):
- Description: The measure constructs a clinically coherent group of
services to inform providers about resource use and effectiveness. It sums
Parts A and B payments related to a kidney/urinary tract infection IP stay and
attributes them to the hospital where the index IP stay occurred.
- Numerator: The numerator of the Kidney/Urinary Tract Infection
Clinical Episode-Based Payment Measure is the risk-adjusted sum of a
provider’s spending and the preadmission and post-discharge medical services
that are clinically related to kidney/urinary tract infection across a
hospital’s eligible Kidney/Urinary Tract Infection episodes during the period
of performance. A clinical episode begins 3 days prior to the initial (i.e.,
index) admission and extends 30 days following the index hospital stay
discharge date.
- Denominator: A count of the provider’s condition-specific episodes
during the period of performance.
- Exclusions: Episode Exclusions: 1. Beneficiaries who do not have
continuous enrollment in Medicare Parts A and B from 90 days prior to IP
admission through the end of the episode with Medicare as the primary payer.
2. Beneficiaries who enroll in Medicare Advantage during the period that
starts 90 days prior to IP admission through the end of the
episode.
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: Claims
- Measure Type: Efficiency
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Support
- Workgroup Rationale: MAP supported this measure because the PSI
measures were developed to identify harmful healthcare related events that are
potentially preventable. Three additional PSIs have been added to this updated
version of the measure. PSIs were better linked to important changes in
clinical status with “harm weights” that are based on diagnoses that were
assigned after the complication. This is intended to allow the measure to more
accurately reflect the impact of the events.
- Public comments received: 10
Rationale for measure provided by HHS
Each measure used within the
PSI 90 composite is an outcome measure that has been shown to be largely
preventable through improved structures and processes of care. Each measure has
an evidence review form as part of the NQF endorsement process. The literature
to support each measure is updated on a schedule basis.
Measure Specifications
- NQF Number (if applicable): 531
- Description: Patient Safety and Adverse Events Composite (Patient
Safety Indicator, or PSI90) is a composite measure of 10 individual PSIs, each
measuring a different aspect of harm associated with patient safety. Each PSI
is reliability-adjusted (smoothed) and indirectly standardized (risk
adjusted). The composite is the weighted average of the reliability-adjusted,
indirectly standardized, observed-to-expected ratios for component indicators.
The final weight for each component is the product of harm weights and volume
weights (numerator weights). Harm weights are calculated by multiplying
empirical estimates of excess harms associated with the patient safety event
by utility weights linked to each of the harms. Excess harms are estimated
using statistical models comparing patients with a safety-related event to
those without that safety-related event in a CMS Medicare fee-for-service
sample that allowed up to one year of follow-up from the discharge date of the
hospital stay associated with the index event. Volume weights, the second part
of the final weight, are calculated on the basis of the number of
safety-related events for the component indicators in the all-payer reference
population. The observed to expected ratios (indirect standardization) of the
reliability adjusted (smoothed) rates are multiplied by a component weight and
the weighted scores are summed to determine the final PSI 90 score. A score of
1 means that the hospital performs as expected, scores greater than one
indicate worse performance than expected.
- Numerator: Below we list the numerator values for the composite
components. The composite score is calculated as a ratio of the weighted
observed to expected ratios for each of the components. PSI03-Pressure Ulcer
Rate- Discharges, among cases meeting the inclusion and exclusion rules for
the denominator, with any secondary ICD-9-CM diagnosis codes for pressure
ulcer and any secondary ICD-9-CM diagnosis codes for pressure ulcer stage III
or IV (or unstageable). PSI06-Iatrogenic Pneumothorax Rate- Discharges,
among cases meeting the inclusion and exclusion rules for the denominator,
with any secondary ICD-9-CM diagnosis codes for iatrogenic pneumothorax.
PSI08-Postoperative Hip Fracture Rate- Discharges, among cases meeting the
inclusion and exclusion rules for the denominator, with any secondary ICD-9-CM
diagnosis codes for hip fracture. PSI09-Perioperative Hemorrhage and
Hematoma Rate- Discharges, among cases meeting the inclusion and exclusion
rules for the denominator, with either: • any secondary ICD-9-CM diagnosis
codes for perioperative hemorrhage or hematoma and any-listed ICD-9-CM
procedure codes for control of perioperative hemorrhage or evacuation of
hematoma. PSI10-Postoperative Acute Kidney Injury Rate- Discharges, among
cases meeting the inclusion and exclusion rules for the denominator, with
either: • any secondary ICD-9-CM diagnosis codes for acute renal failure and
any-listed ICD-9- CM procedure codes for dialysis. PSI11-Postoperative
Respiratory Failure Rate- Discharges, among cases meeting the inclusion and
exclusion rules for the denominator, with either: • any secondary ICD-9-CM
diagnosis code for acute respiratory failure; or • any-listed ICD-9-CM
procedure codes for a mechanical ventilation for 96 consecutive hours or more
that occurs zero or more days after the first major operating room procedure
code (based on days from admission to procedure); or • any-listed ICD-9-CM
procedure codes for a mechanical ventilation for less than 96 consecutive
hours (or undetermined) that occurs two or more days after the first major
operating room procedure code (based on days from admission to procedure); or
• any-listed ICD-9-CM procedure codes for a reintubation that occurs one or
more days after the first major operating room procedure code (based on days
from admission to procedure). PSI12-Perioperative Pulmonary Embolism and
Deep Vein Thrombosis Rate- Discharges, among cases meeting the inclusion and
exclusion rules for the denominator, with a secondary ICD-9-CM diagnosis code
for deep vein thrombosis or a secondary ICD-9-CM diagnosis code for pulmonary
embolism (omitting cases from the numerator with isolated calf vein DVT).
PSI13-Postoperative Sepsis Rate- Discharges, among cases meeting the inclusion
and exclusion rules for the denominator, with any secondary ICD-9-CM diagnosis
codes for sepsis. PSI14-Postoperative Wound Dehiscence Rate-Discharges,
among cases meeting the inclusion and exclusion rules for the denominator,
with any-listed ICD-9-CM procedure codes for reclosure of postoperative
disruption of the abdominal wall. PSI15-Unrecognized Abdominopelvic
Accidental Puncture or Laceration Rate -Discharges, among cases meeting the
inclusion and exclusion rules for the denominator, with any secondary ICD-9-CM
diagnosis codes for accidental puncture or laceration during a procedure and
second abdominopelvic operation 1 day or more after the index
procedure.
- Denominator: Below we list the denominator values for the composite
components. The composite score is calculated as a ratio of the weighted
observed to expected ratios for each of the components. PSI03-Pressure Ulcer
Rate- Surgical and medical discharges, for patients ages 18 years and older.
Surgical and medical discharges are defined by specific DRG or MS-DRG codes.
PSI06-Iatrogenic Pneumothorax Rate- Surgical and medical discharges, for
patients ages 18 years and older. Surgical and medical discharges are defined
by specific DRG or MS-DRG codes. PSI08-Postoperative Hip Fracture Rate-
Surgical discharges, ages 18 years and older, with any-listed ICD-9-CM
procedure codes for an operating room procedure. Surgical discharges are
defined by specific DRG or MS-DRG codes. PSI09-Perioperative Hemorrhage and
Hematoma Rate- Surgical discharges, for patients ages 18 years and older,
with any-listed ICD-9-CM procedure codes for an operating room procedure.
Surgical discharges are defined by specific DRG or MS-DRG codes.
PSI10-Postoperative Acute Kidney Injury Rate- Elective surgical discharges,
for patients ages 18 years and older, with any-listed ICD-9-CM procedure codes
for an operating room procedure. Elective surgical discharges are defined by
specific DRG or MS-DRG codes with admission type recorded as elective (SID
ATYPE=3). PSI11-Postoperative Respiratory Failure Rate- Elective surgical
discharges, for patients ages 18 years and older, with any-listed ICD-9-CM
procedure codes for an operating room procedure. Elective surgical discharges
are defined by specific DRG or MS-DRG codes with admission type recorded as
elective (SID ATYPE=3). PSI12-Perioperative Pulmonary Embolism and Deep Vein
Thrombosis Rate- Surgical discharges, for patients ages 18 years and older,
with any-listed ICD-9-CM procedure codes for an operating room procedure.
Surgical discharges are defined by specific DRG or MS-DRG codes.
PSI13-Postoperative Sepsis Rate- Elective surgical discharges, for patients
ages 18 years and older, with any-listed ICD-9-CM procedure codes for an
operating room procedure. Elective surgical discharges are defined by specific
DRG or MS-DRG codes with admission type recorded as elective (SID ATYPE=3).
PSI14-Postoperative Wound Dehiscence Rate- Discharges, for patients ages 18
years and older, with any-listed ICD-9-CM procedure codes for abdominopelvic
surgery. PSI15-Unrecognized Abdominopelvic Accidental Puncture or Laceration
Rate- Patients ages 18 years and older with any procedure code for an
abdominopelvic procedure.
- Exclusions: Below we list the exclusions for the composite
components. There are no additional exclusions for the composite measure as a
whole. PSI03 – Pressure Ulcer Rate-Excludes cases with length of stay less
than 5 days, with a principal diagnosis of pressure ulcer or secondary
diagnosis of pressure ulcer present on admission, cases with evidence of
hemiplegia, paraplegia or quadriplegia, spina bifida, anoxic brain damage,
debridement or pedicle graft on the same day as the major operating room
surgery or as the only major operating room procedure, and cases that were
transferred from a different hospital or skilled nursing facility, and cases
with MDC (major diagnostic classification) of 9 (skin, subcutaneous and
breast) or 14 (pregnancy, childbirth and puerperium). PSI06 – Iatrogenic
Pneumothorax Rate - Excludes cases with a principal diagnosis for iatrogenic
pneumothorax or secondary diagnosis of iatrogenic pneumothorax on admission,
cases with evidence of chest trauma, pleural effusion, thoracic surgery, lung
or pleural biopsy, diaphragmatic repair, cardiac procedure, and cases with MDC
(major diagnostic classification) of 14 (pregnancy, childbirth and
puerperium). PSI08 – Postoperative Hip Fracture Rate-Excludes cases with
principal diagnosis of hip fracture or a secondary diagnosis of hip fracture
on admission, cases where the only operating room procedure is hip fracture,
where the procedure for hip fracture occurs before or on the same day as the
first operating room procedure, and cases with a principal diagnosis of
seizure, syncope, stroke and occlusion of arteries, coma, cardiac arrest,
poisoning, trauma, delirium and other psychoses, anoxic brain injury,
metastatic cancer, lymphoid malignancy, bone malignancy, self-inflicted
injury, and cases with MDC (major diagnostic classification) of 8
(musculoskeletal system and connective tissue) or 14 (pregnancy, childbirth
and puerperium). PSI09 – Perioperative Hemorrhage and Hematoma Rate -
Excludes cases with principal diagnosis of perioperative hemorrhage or
postoperative hematoma or secondary diagnosis present of perioperative
hemorrhage on admission, cases where the only operating room procedure is
control of postoperative hemorrhage, drainage of hematoma or miscellaneous
hemorrhage- or hematoma-related procedure, any secondary diagnosis of
perioperative hemorrhage or postoperative hematoma and any-listed procedure
codes for control of perioperative hemorrhage or evacuation of hematoma or
miscellaneous hemorrhage- or hematoma- related procedure occurring before the
first operating room procedure, cases with diagnosis of coagulation disorder
and cases with MDC (major diagnostic classification) of 14 (pregnancy,
childbirth and puerperium). PSI10 – Postoperative Acute Kidney
Injury-Excludes cases with a principal diagnosis or secondary diagnosis on
admission of acute renal failure, acute myocardial infarction, cardiac
arrhythmia, cardiac arrest, shock, hemorrhage, gastrointestinal hemorrhage, or
chronic renal failure, cases with dialysis procedure before on the same day as
the first operating procedure and cases with MDC (major diagnostic
classification) of 14 (pregnancy, childbirth and puerperium). PSI11 –
Postoperative Respiratory Failure Rate - Excludes cases with principal
diagnosis or secondary diagnosis on admission of acute respiratory failure,
cases where the only operating procedure is tracheostomy or a tracheostomy
occurs before the first operating procedure, cases with any listed diagnosis
of neuromuscular disorder, craniofacial anomalies or degenerative neurological
disorder, cases with any listed procedure of laryngeal or pharyngeal, nose,
mouth, or pharynx surgery, procedures involving the face, esophageal
resection, procedures for lung cancer, and cases with MDC (major diagnostic
classification) of 4 (disease of respiratory system), 5 (diseases of the
circulatory system), or 14 (pregnancy, childbirth and puerperium). PSI12 –
Perioperative Pulmonary Embolism and Deep Vein Thrombosis Rate - Excludes
cases with principal diagnosis or secondary diagnosis on admission of DVT,
pulmonary embolism, cases where a procedure for interruption of vena cava
occurs before or on the same day as the first operating room procedure, cases
with any procedure for extracorporeal membrane oxygenation, and cases with MDC
(major diagnostic classification) of 14 (pregnancy, childbirth and
puerperium). PSI13 – Postoperative Sepsis Rate – Excludes cases with
principal diagnosis or secondary diagnosis on admission of sepsis, infection,
cases with evidence of immunocompromised state or cancer, cases with a length
of stay less than 4 days, and cases with MDC (major diagnostic classification)
of 14 (pregnancy, childbirth and puerperium). PSI14 – Postoperative Wound
Dehiscence Rate – Excludes cases with any listed evidence of immunocompromised
state, cases where the procedure for abdominal wall reclosure occurs on or
before the day of the first abdominopelvic surgery procedure, cases with a
length of stay less than 2 days, and cases with MDC(major diagnostic
classification) of 14 (pregnancy, childbirth and puerperium). PSI15 –
Unrecognized Abdominopelvic Accidental Puncture or Laceration Rate-Excludes
cases with a principal diagnosis or secondary diagnosis at admission of
accidental puncture or laceration during a procedure and cases with MDC (major
diagnostic classification) of 14 (pregnancy, childbirth and
puerperium).
- HHS NQS Priority: Making Care Safer
- HHS Data Source: Administrative claims Component measures require:
ICD-9 diagnosis and procedure codes, MDC, MSDRG, procedure day, age in year,
gender, admission type, discharge disposition. All are drawn from
administrative data.
- Measure Type: Composite
- Steward: Agency for Healthcare Research & Quality
- Endorsement Status: Endorsed; MUC same as endorsed
version:Yes
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Patient Safety
2015
- Review for Importance: The measure meets the Importance criteria
(1a. Evidence, 1b. Performance Gap) 1a. Evidence: 16-Y; 8-N I; 1b. Performance
Gap: 9-H; 9-M; 6-L; 0-I; 1c. Composite- Quality Construct and Rationale: 6-H;
7-M; 11-L; 0-I Rationale: · The Committee agreed that the outcomes in this
measure were associated with one or more healthcare actions. However, there
was concern that some of the elements of the composite had variable
preventability. · The developers reported that the items within the composite
are positively correlated. The correlations range in the low 0.08 up to the
30s (not very high). · The developers referenced several processes of care
that are associated with lower rates for each of the components in the
composite.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria (2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity) 2a. Reliability: 4-H;
10-M; 9-L; 1-I 2b. Validity: 2-H; 11-M; 7-L; 2-I 1c. Composite Construction:
4-H; 12-M; 7-L; 1-I Rationale: · The Committee agreed that the updated version
of the measure provided by AHRQ was improved from the 2014 version reviewed by
the Committee, specifically noting that the new weighting focusing on harm
rather than just the frequency of events, was more clinically relevant than
the previous version of the measure. · During reliability testing, the
developers examined the true difference rather than random chance and noise.
Their results show a reliability scores in the 70s, which is comparable to
other endorsed measures · Aggregating a number of individual measures into a
single composite can generate an overall performance score that is more
reliable than if the individual measure scores were taken in isolation. ·
Empirical field validity testing was conducted at the performance measure
score level for the overall composite by correlating the composite scores with
the rates calculated from the 3M Potentially Preventable Readmissions measure.
.The Pearson correlation value, was 0.11 with a p-value of
<0.0001.
- Review for Feasibility: 12-H; 8-M; 3-L; 1-I (3a. Clinical data
generated during care delivery; 3b. Electronic sources; 3c.Susceptibility to
inaccuracies/ unintended consequences identified 3d. Data collection strategy
can be implemented) Rationale: · The Committee had no concerns about the
feasibility of this measure given that it is gathered with administrative
claims data.
- Review for Usability: 12-H; 6-M; 6-L; 0-I (Meaningful,
understandable, and useful to the intended audiences for 4a. Public
Reporting/Accountability and 4b. Quality Improvement) Rationale: · There were
concerns about the use of this measure in value-based purchasing, despite the
improvements the developer has made, because may not accurately reflect that
an actual preventable complication occurred or may focus on preventing
measured events that are less clinically important. · This measure is used to
monitor performance in national and regional reporting. It was also developed
to enable comparative reporting and quality improvement at the provider or the
hospital level.
- Review for Related and Competing Measures: Concerns were raised by
the Committee that some of the elements of this measure, notably the central
line related blood stream infections and post-operative hip fracture, may be
better captured in other NQF approved measures rather than using
administrative claims data. In addition, this measure is related to NQF 532,
which is the pediatric version of the same measure 0347.
- Endorsement Public Comments: Summary pending
- Endorsement Committee Recommendation: 14-Y; 10-N
Since 58% of the Committee voted to recommend this measure, it did not
achieve consensus. It will move forward to the comment period and the
Committee will discuss and revote after the public comment.
This measure was last endorsed in 2009; it is a composite measure of 11
inpatient Patient Safety Indicators. In 2014 the Committee raised concerns
about the weighting of the various components of the composite, specificially
that some of the more heavily weighted components were less clinically
significant (i.e., accidental punctures and lacerations) and/or less
preventable. In addition, there were concerns that the events measured are not
always reflective of an actual patient safety event that resulted in
preventable patient harm. To address the concerns of the 2014 Committee, AHRQ
made several updates to the measure to address the Committee’s concerns.
- Additional PSIs were included (from 8 events to 11 events, which
expanded the type of complications included this measure),
- Two of the component PSIs were redesigned; specifically PSI 12 with the
removal of isolated calf deep vein thromboses (DVT) which have limited
clinical relevance and PSI 15 with a greater focus on accidental punctures
and lacerations that occur during abdominal/pelvic surgery and those that
result in re-operation within one day which reflect events that are more
likely preventable, and
- The measure was modified to more accurately reflect the impact of the
events by better linking the PSIs to important changes in clinical status
with “harm weights” that are based on diagnoses that were assigned after the
complication.
The Committee agreed that the changes to the measure were highly responsive
to the concerns raised during the 2014 Committee discussion. However, new
concerns were raised: some post-operative DVT or other events included in the
composite may not be preventable; the definition of ICD-9 based central line
related blood stream infections may be less precise than other definitions
(i.e., NHSN which reports the information differently); and concerns about
this measure being included in value-based purchasing programs particularly
when it is likely that not all of these events are preventable and that it may
distract from efforts to reduce more impactful safety events. In addition,
there were concerns that some of the indicators of the measure may not reflect
preventable patient safety events because it comes from ICD-9 data of
inpatient complications, which sometimes did not directly reflect that an
actual preventable complication occurred in the validation of the components
of the composite. During the vote, the Committee agreed that the measure meets
the four NQF criteria; however, consensus was not reached on a recommendation
for endorsement (58% yes, 42% no). The Committee will re-consider the
recommendation for endorsement after reviewing the public
comments.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Support
- Workgroup Rationale: MAP recognized the importance of addressing
this critical quality and public health concern. MAP noted that this process
measure is a start to addressing the issue but recommended that outcome
measures be quickly developed and implemented. MAP recommended that the
developer consider expanding this measure to the under 18 population and that
this measure be considered for implementation in the IQR program.
- Public comments received: 8
Rationale for measure provided by HHS
In a study on the provision
of evidence-based care and preventive services provided in hospitals for 30
different medical conditions, quality varied substantially according to
diagnosis. Adherence to recommended practices for treatment of substance use
ranked last, with only 10% of patients receiving proper care (McGlynn 2003,
Gentilello 2005). Currently, less than one in twenty patients with an addiction
is referred for treatment (Gentilello 1999). Unfortunately, many physicians
mistakenly believe that substance use problems are largely confined to the
young. They are significantly less likely to recognize an alcohol problem in an
older patient than in a younger one. (Curtis 1989) As a result, these problems
usually go undetected, resulting in harmful, expensive, and sometimes even
catastrophic consequences. This is demonstrated by the fact that few older
adults who need substance use treatment actually receive it. In 2005, persons 65
years and older made up only 11,344 out of 1.8 million substance use treatment
episodes recorded.(SAMHSA 2007) Citations: • Gentilello LM, Ebel BE, Wickizer
TM, Salkever DS Rivera FP. Alcohol interventions for trauma patients treated in
emergency departments and hospitals: A cost benefit analysis. Ann Surg. 2005
Apr;241(4):541-50. • Gentilello LM, Villaveces A, Ries RR, Nason KS, Daranciang
E, Donovan DM Copass M, Jurkovich GJ Rivara FP. Detection of acute alcohol
intoxication and chronic alcohol dependence by trauma center staff. J Trauma.
1999 Dec;47(6):1131-5; discussion 1135-9. • McGlynn, EA, Asch SM, Adams J,
Keesey J, et al. The New England Journal of Medicine. Boston: Jun 26, 2003. Vol.
348, Iss.26; pg. 2635, 11pgs. • Curtis, J.R.; Geller, G.; Stokes, E.J. ; et al.
Characteristics, diagnosis, and treatment of alcoholism in elderly patients. J
Am Geriatr Soc 37:310-316, 1989. • SAMHSA. Office of Applied Studies. Older
adults in substance abuse treatment: 2005. The DASIS Report. Rockville MD,
November 8, 2007.
Measure Specifications
- NQF Number (if applicable): 1664
- Description: Overall rate which includes all hospitalized patients
18 years of age and older to whom alcohol or drug use disorder treatment was
provided, or offered and refused, at the time of hospital discharge, and a
second rate, a subset of the first, which includes only those patients who
received alcohol or drug use disorder treatment at discharge. (The endorsed
specifications of the measure are: The measure is reported as an overall rate
which includes all hospitalized patients 18 years of age and older to whom
alcohol or drug use disorder treatment was provided, or offered and refused,
at the time of hospital discharge, and a second rate, a subset of the first,
which includes only those patients who received alcohol or drug use disorder
treatment at discharge. The Provided or Offered rate (SUB-3) describes
patients who are identified with alcohol or drug use disorder who receive or
refuse at discharge a prescription for FDA-approved medications for alcohol or
drug use disorder, OR who receive or refuse a referral for addictions
treatment. The Alcohol and Other Drug Disorder Treatment at Discharge (SUB-3a)
rate describes only those who receive a prescription for FDA-approved
medications for alcohol or drug use disorder OR a referral for addictions
treatment. Those who refused are not included.These measures are intended to
be used as part of a set of 4 linked measures addressing Substance Use (SUB-1
Alcohol Use Screening ; SUB-2 Alcohol Use Brief Intervention Provided or
Offered; SUB-3 Alcohol and Other Drug Use Disorder Treatment Provided or
Offered at Discharge; SUB-4 Alcohol and Drug Use: Assessing Status after
Discharge).)
- Numerator: SUB-3: The number of patients who received or refused at
discharge a prescription for medication for treatment of alcohol or drug use
disorder OR received or refused a referral for addictions treatment. SUB-3a:
The number of patients who received a prescription at discharge for medication
for treatment of alcohol or drug use disorder OR a referral for addictions
treatment.
- Denominator: The number of hospitalized inpatients 18 years of age
and older identified with an alcohol or drug use disorder.
- Exclusions: There are 11 exclusions to the denominator as follows:
• Patients less than 18 years of age • Patient drinking at unhealthy levels
who do not meet criteria for an alcohol use disorder • Patients who are
cognitively impaired • Patients who expire • Patients discharged to another
hospital • Patients who left against medical advice • Patients discharged to
another healthcare facility • Patients discharged to home or another
healthcare facility for hospice care • Patients who have a length of stay
less than or equal to three days or greater than 120 days • Patients who do
not reside in the United States • Patients receiving Comfort Measures Only
documented
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Paper medical record
- Measure Type: Process
- Steward: The Joint Commission
- Endorsement Status: Endorsed; MUC same as endorsed
version:Yes
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2014
- Project for Most Recent Endorsement Review: Behavioral Health
Endorsement Maintenance 2014 - Phase II
- Review for Importance: The measure meets the Importance
criteria(1a. High Impact: 1b. Performance Gap, 1c. Evidence)1a. Impact: H-16;
M-2; L-0; I-0; 1b. Performance Gap: H-12; M-6; L-0; I-0; 1c. Evidence: Y-16;
N-1; I-1Rationale:• The Steering Committee initially reviewed and rated the
Importance criteria for this measure on April 18, 2012, during the first phase
of this project; accordingly, Importance to Measure and Report was not
discussed during the phase two meeting. Instead, the votes from Phase 1 were
carried over, and appear above.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria(2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity)2a. Reliability: H-0;
M-19; L-0; I-0; 2b. Validity: H-0; M-16; L-5; I-0Rationale:• The Steering
Committee agreed the measure meets the criteria. Reliability involved the
re-abstraction of 96 medical records at five hospitals and resulted in an
overall agreement rate to 96.2 percent for SUB-3 and 93.8 percent for SUB-3a.•
The face validity of the measure was initially assessed through a public
comment period and issues identified were addressed through measure revisions.
An alpha test was then incorporated into the pilot test of the measure to
reevaluate its validity. Finally, an eleven member Technical Advisory Panel
was asked to review the measure specifications on a five point scale. The
measure score varied from 3.85 to 5.0 based on clarity of specifications,
usefulness, interpretability, data accessibility and ease of collection and
national use.• A Steering Committee member expressed concern that the measure
includes alcohol as well as other drug use disorders, which creates a broad
measure and potentially an additional burden for providers. Members also noted
that incorporating a prescription at discharge may be problematic since use of
medications for substance abuse may not be as efficacious as medications to
treat other addictions, such as tobacco.o The developer referenced a table,
linked to the measure, which indicates medications approved by the FDA that
could be prescribed to patients. They also clarified that the measure only
focuses on the patient’s receipt of a prescription, and does not address
patient compliance.o The Steering Committee expressed concern that medications
for substance abuse may be expensive, which could deter patients from actually
filling a prescription but ultimately agreed with the measure, noting the
measure is constructed to allow patients to receive a prescription OR a
referral for treatment.• The Steering Committee reviewed the measure testing
results regarding the identification of meaningful differences in performance
and noted that the measure had an overall rate of 3.5 percent, a significant
decrease from the baseline of 9.2 percent. This indicates that there was a
reduction of differences in performance for the measure among hospitals
implementing the measure.
- Review for Feasibility: H-0; M-11; L-10; I-0(4a. Clinical data
generated during care delivery; 4b. Electronic sources; 4c.Susceptibility to
inaccuracies/ unintended consequences identified 4d. Data collection strategy
can be implemented)Rationale:• The Steering Committee agreed the measure is
feasible and some data elements are available in electronic sources. In the
future the developer plans to further develop electronic specifications for
the measure.• A Steering Committee member expressed concern that the measure
includes alcohol as well as other drug use disorders, which could create an
additional burden for providers, and that generating the data elements
requires chart review.o The developer clarified that providers would also need
to conduct chart reviews in measures 1661 SUB-1 Alcohol use screening and 1663
SUB-2 Alcohol use brief intervention provided or offered and Sub-2a Alcohol
use brief intervention. The developer also noted that hospitals currently
implementing the substance abuse suite of measures rely on electronic health
records to reduce the burden.
- Review for Usability: H-2; M-11; L-8; I-0(Meaningful,
understandable, and useful to the intended audiences for 3a. Public
Reporting/Accountability and 3b. Quality Improvement)Rationale: The Steering
Committee agreed the measure is usable. CMS has indicated that this measure
will be required for reporting for inpatient psychiatric hospitals and psych
units in general hospitals starting in 2016.
- Review for Related and Competing Measures: This measure is related
to the other measures in the SUB suite of measures in addition to the AMA-PCPI
measure #2152 – Preventive Care and Screening: Unhealthy
Diagnosis.
- Endorsement Public Comments: Please refer to the TOB-1 measure
review on page 37 for discussion of comments related to the suite of tobacco
measures.
- Endorsement Committee Recommendation: Y-11; N-9
The Steering
Committee recommended that the developer expand the measure population to
include adolescents (aged 13 and older) to make the measure more consistent
with Meaningful Use and to incorporate an age group that also struggles with
substance use disorders. The developer noted that they would review the
evidence for extending the age range of the measure in the future.
Consensus Standards Approval Committee (CSAC) Review (January 24, 2014):
Y-12; N-0; A-1Decision: Approved for endorsement.
Board of Directors (February 18, 2014):Decision: Ratified for
endorsement
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF review
and endorsement and examination of SDS factors.
- Workgroup Rationale: MAP noted the importance of reducing
readmissions for mental health conditions but recommended this measure be
submitted for NQF review and endorsement. MAP recommended the Admissions and
Readmissions Standing Committee pay particular attention to the influence of
sociodemographic factors when reviewing this measure as access to community
resources and supports can influence a patient's ability to manage mental and
behavioral health issues on an outpatient basis.
- Public comments received: 8
Rationale for measure provided by HHS
Patient Volume Analysis of
calendar year 2013 IPF claims data showed that 308,915 Medicare beneficiaries
had 471,349 IPF stays. This group of patients is particularly vulnerable.
Sixty-six percent of discharges are for patients under 65 indicating Medicare
eligibility due to disability; 56% of discharges also have dual eligibility with
Medicaid indicating they have limited financial resources. Twenty-nine percent
of Medicare beneficiaries who used IPF services in 2013 had more than one stay.
For CY 2012 and CY 2013, approximately one-third of all admissions for a
principal psychiatric disorder (ICD-9 codes 290-319) were to short-stay acute
care hospitals (including critical access hospitals). However, of the 1669
short-stay acute care hospitals with psychiatric admissions, only 39% had 25 or
more psychiatric admissions. Forty percent of the psychiatric admissions to
short-stay acute care hospitals were to hospitals that also had IPF units. The
HWR measure for short-stay acute care hospitals includes some of these diagnoses
(i.e., dementia, substance use, and screening/history of mental health and
substance use). Consequences of Readmissions Readmission is considered an
adverse event because it indicates deterioration in health status after
discharge from the IPF that requires an acute level of care. In addition to
patient burden, readmissions impacts cost. A MedPAC report indicated that
Medicare payments to IPFs averaged nearly $10,000 per discharge (MedPAC, 2014)
MedPAC analyses also showed that spending for Medicare beneficiaries who use IPF
services is substantially higher than for all fee-for-service beneficiaries, due
in part to the IPF stays (MedPAC, 2010). Performance Variation There is
variation in 30-day all-cause readmission rates across IPFs, which is noted in
Item 44: Evidence of performance gap. Evidence of Effective Interventions to
Reduce Readmissions Some individual studies and systematic reviews have
supported the positive effect of the following interventions in reducing
psychiatric readmissions: • Follow-up within 7 days of discharge (Mark, 2013)
• Stabilizing condition prior to discharge (Durbin, 2007) •
Transition/discharge practices (Vigod, 2013; Steffen, 2009) • Intensive case
management (Dieterich, 2010) Citations: *Dieterich M, Irving CB, Park B,
Marshall M. Intensive case management for severe mental illness. The Cochrane
database of systematic reviews. 2010(10):Cd007906. *Durbin J, Lin E, Layne C,
Teed M. Is readmission a valid indicator of the quality of inpatient psychiatric
care? J. Behav. Health Serv. Res. 2007;34(2):137-150. *Mark T, Tomic KS,
Kowlessar N, Chu BC, Vandivort-Warren R, Smith S. Hospital readmission among
medicaid patients with an index hospitalization for mental and/or substance use
disorder. J. Behav. Health Serv. Res. 2013;40(2):207-221. *MedPAC. Chapter 6:
Inpatient Psychiatric Care in Medicare: Trends and Issues. June 2010 Report to
Congress: Aligning Incentives in Medicare. Washington, DC: MedPAC; 2010:161-187.
* MedPAC. Inpatient Psychiatric Facility Services Payment System. Washington,
DC: MedPAC; October 2014. *Steffen S, Kosters M, Becker T, Puschner B.
Discharge planning in mental health care: a systematic review of the recent
literature. Acta Psychiatr. Scand. 2009;120(1):1-9. *Vigod SN, Kurdyak PA,
Dennis CL, et al. Transitional interventions to reduce early psychiatric
readmissions in adults: systematic review. Br. J. Psychiatry.
2013;202(3):187-194.
Measure Specifications
- NQF Number (if applicable):
- Description: The measure estimates a facility-level
risk-standardized readmission rate for unplanned, all-cause readmission within
30 days of discharge from an Inpatient Psychiatric Facility of adult Medicare
fee-for-service (FFS) patients with a principal diagnosis of a psychiatric
disorder. The performance period for the measure is 24 months.
- Numerator: The outcome for this measure is unplanned, all-cause
30-day readmission. Readmission is defined as a subsequent inpatient admission
to an IPF or short-stay acute care hospital (including critical access
hospitals) for any cause, with the exception of certain planned readmissions,
within 30 days from the date of discharge from an eligible index psychiatric
admission in an Inpatient Psychiatric Facility.
- Denominator: The target population for this measure is Medicare FFS
beneficiaries aged 18 years and older with a principal diagnosis of a
psychiatric disorder discharged from an Inpatient Psychiatric Facility.
Eligible index admissions require enrollment in Medicare Parts A & B for
12 months prior to the index admission, the month of admission, and at least
30 days post discharge; discharged alive; and not transferred to an IPF or
short-stay acute care hospital. A readmission within 30-days will also be
eligible as an index admission, if it meets all other eligibility criteria.
The performance period for the measure is 24 months.
- Exclusions: The measure excludes admissions for patients: -
Subsequent admission on day of discharge and following 2 days
(transfers/interrupted stay period) - Nonpsychiatric principal discharge
diagnosis - Discharged against medical advice - With unreliable data (e.g.
has a death date but also admissions afterwards)
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: Claims
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP noted that available discharge codes and
coding practices could cause confusion about the results of this measure and
could also introduce validity concerns. MAP asked for greater clarity about
the intent of these measures, especially how they may impact patients and
consumers. MAP members raised concerns about the multiple ways that
readmissions are being measured and noted that a provider could potentially be
penalized multiple times for the same occurrence. MAP noted the need for
excluding patients who are admitted to hospice to prevent discouraging
discharges to hospice. MAP also noted that discharge to community can reflect
access to social support and the measure may need to reflect this. MAP
indicated the need for these measures to be submitted for NQF review and
endorsement to address psychometric concerns about the measures.MAP members
noted concerns about the risk adjustment of these measures, particularly for
the home health setting. MAP specifically noted the need to appropriately risk
adjust the measures to avoid unintended consequences.
- Public comments received: 14
Rationale for measure provided by HHS
The ultimate goals of
post-acute care are avoiding institutionalization and returning patients to
their previous level of independence and functioning, with discharge to
community being the primary goal for the majority of post-acute patients. For
many, home is a symbol of independence, privacy, and competence. Discharge to
community is considered a valuable outcome to measure because it is a
multifaceted measure that captures the patient’s functional status, cognitive
capacity, physical ability, and availability of social support at home. There
is considerable variation in discharge to community rates within and across
post-acute settings. Studies show geographic variation, variation across patient
socioeconomic characteristics (for example, race and ethnicity), and variation
by facility characteristics (for profit vs. nonprofit, freestanding vs.
hospital-based, urban vs. rural). In the IRF setting, discharge to community
rates vary across providers, ranging from about 60% to 75%. The 2015 MedPAC
report shows that, in FY 2013, the facility-level, mean risk-adjusted discharge
to community rate for IRFs within 100 days of admission was 75.8%, and the mean
observed rate was 74.7%. Discharge to community rates also vary widely in the
SNF setting, ranging from as low as 31% to as high as 65%. The 2015 MedPAC
report shows a mean risk-adjusted discharge to community rate of 37.5% for SNFs
within 100 days of admission, and mean observed rate of 40.1%. A multicenter
study of 23 LTCHs reported that only 28.8% of 1,061 patients who were
ventilator-dependent on admission were discharged to home or assisted living
facility. A study of 66,510 Medicare beneficiaries during pre- and post-HH
episodes, revealed that 64 percent of beneficiaries discharged from HH did not
use any other Medicare-reimbursed acute or post-acute services in the 30 days
following HH discharge. Significant numbers of patients were admitted to
inpatient facilities (29 percent) and lesser numbers to skilled nursing
facilities (7.6 percent), inpatient rehabilitation (1.5 percent) and home health
(7.2 percent) or hospice (3.3 percent) within 30 days of HH discharge (Wolff et
al., 2008).
Measure Specifications
- NQF Number (if applicable):
- Description: This measure describes the risk-standardized rate of
Medicare fee-for-service (FFS) patients/residents/persons who are discharged
to the community following a post-acute stay/episode, and do not have an
unplanned (re)admission to an acute care hospital or LTCH in the 31 days
following discharge to community, and remain alive during the 31 days
following discharge to community.
- Numerator: This measure does not have a simple form for the
numerator and denominator. The numerator is defined as the risk-adjusted
estimate of the number of patients/residents/persons included in the measure
who are discharged to the community, and do not have an unplanned
(re)admission to an acute care hospital or LTCH on the day of discharge or in
the 31 days following discharge to community, and remain alive during the 31
days following discharge to community. The numerator estimate includes risk
adjustment for patient/resident/person characteristics, and a statistical
estimate of the facility/agency effect beyond case mix.
- Denominator: The denominator is computed with the same model used
for the numerator. It is the model developed using all non-excluded
facility/agency stays/episodes in the national data. The measure includes all
facility/agency stays/episodes in the measurement period that are observed in
national Medicare FFS data and do not fall into an excluded category. For a
particular facility/agency, the model is applied to the
patient/resident/person population, but the facility/agency effect term is 0.
In essence, it is the number of discharges to community that would be expected
for that patient/resident/person population at the average
facility/agency.
- Exclusions: i) Age under 18 years; (ii) No short-term acute care
stay within 30 days prior to IRF admission ; (iii) Discharges to psychiatric
hospital; (iv) Discharges against medical advice; (v) Discharges to federal
hospitals or disaster alternative care sites; (vi) Patients not continuously
enrolled in Part A FFS Medicare for the 12 months prior to IRF admission date,
and at least 31 days after IRF discharge date; (vii) Patients whose prior
short-term acute-care stay was for non-surgical treatment of cancer; (viii)
Discharges to hospice; (ix) IRF stays that end in transfer to another IRF; (x)
IRF stays with claims data that are problematic (e.g., anomalous records for
stays that overlap wholly or in part, or are otherwise erroneous or
contradictory); (xi) Patients who received care from a provider located
outside of the US, Puerto Rico, or a US territory..
- HHS NQS Priority: i) Age under 18 years; (ii) No short-term acute
care stay within 30 days prior to IRF admission ; (iii) Discharges to
psychiatric hospital; (iv) Discharges against medical advice; (v) Discharges
to federal hospitals or disaster alternative care sites; (vi) Patients not
continuously enrolled in Part A FFS Medicare for the 12 months prior to IRF
admission date, and at least 31 days after IRF discharge date; (vii) Patients
whose prior short-term acute-care stay was for non-surgical treatment of
cancer; (viii) Discharges to hospice; (ix) IRF stays that end in transfer to
another IRF; (x) IRF stays with claims data that are problematic (e.g.,
anomalous records for stays that overlap wholly or in part, or are otherwise
erroneous or contradictory); (xi) Patients who received care from a provider
located outside of the US, Puerto Rico, or a US territory..
- HHS Data Source: Claims
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP noted the importance of medication
reconciliation but raised concerns and asked for greater clarity about the
definition of reconciliation versus drug regimen review. Members also noted
the challenge of defining some of the measure components, specifically “a
clinically significant issue” given the large number of medications a patient
may be taking. MAP stressed that medication reconciliation is a step in a drug
regimen review and asked for greater clarity on defining the drug regimen
review process. MAP stressed the importance of conducting a complete
medication review from all sites of care, including the home. MAP members
noted the value of the role of family caregivers in providing this information
and the hope that technology can help to minimize the burden of getting this
information. MAP members asked for greater emphasis of the inclusion of
non-prescription medication (including supplements), noting that this is a
particular concern in the PAC/LTC population.MAP members raised some concerns
about the feasibility of this measure and noted the need to clarify the roles
of the interdisciplinary team. MAP noted the importance of attribution issues
for this measure. Additionally, Workgroup members raised concerns about the
challenges of competing guidelines and need for greater clarity about when a
medication can be withdrawn. MAP stressed that medication reconciliation needs
to be an on-going process. MAP also noted that this is a particular concern
for dual-eligible beneficiaries.
- Public comments received: 8
Rationale for measure provided by HHS
Medication review in
post-acute care is generally considered to include medication reconciliation for
all medications and medication review for what poses as potential clinically
significant medication issues for the patient/resident. As a process measure,
medication reconciliation and medication review for potential clinically
significant medication issues are expected to reduce re-hospitalizations, reduce
adverse events related to medications and improve health outcomes.
(New information provided by CMS on January 19, 2016) Medication
review in post-acute care is generally considered to include medication
reconciliation and drug regimen review for all medications and for what poses as
potential clinically significant medication issues for the patient/resident. As
a process measure, medication reconciliation and drug regimen review for
potential clinically significant medication issues are expected to reduce
re-hospitalizations, reduce adverse events related to medications and improve
health outcomes.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of stays Inpatient Rehabilitation Facility
(IRF), Long Term Care Facility (LTCH), and Skilled Nursing Facility (SNF) or
care episodes Home Health (HH) in which a drug regimen review was conducted at
the Admission (IRF, LTCH or SNF)/ Start of Care (SOC)/ Resumption of Care
(ROC) (HH) and timely follow-up with a physician occurred each time potential
clinically significant medication issues were identified throughout the stay
(IRF, LTCH, or SNF) or care episode (HH).
- Numerator: Number of stays or care episodes where the medical
record contains documentation of a drug regimen review conducted at admission
or start-of-care or resumption-of-care with all potential clinically
significant medication issues identified during the course of care and
followed-up with a physician or physician designee.
- Denominator: Care episodes or stays ending during the reporting
period. Assessment timing is as follows: Beginning of care
episode or stay: • HH – SOC or ROC • SNF – Admission • IRF - Admission • LTCH
– Admission End of care episode or stay: • HH – Transfer, Discharge, or
Death at Home • SNF – Discharge, or expired • IRF – Discharge, or expired •
LTCH – Discharge, or expired
- Exclusions: Denominator Exclusion: NONE Numerator Exclusion:
NONE
- HHS NQS Priority: Denominator Exclusion: NONE Numerator Exclusion:
NONE
(New information provided by CMS on January 19, 2016)
Denominator Exclusion: NONE Numerator Exclusion: NONE
- HHS Data Source: Patient assessment data
- Measure Type: Process
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP noted that socioeconomic status is a
particular concern for IRFs. Patients need social supports to be able to
return to the community with a disability. Additionally, it was suggested that
providers who are teaching facilities and serve low income patients may have
higher costs than others.
- Public comments received: 12
Rationale for measure provided by HHS
Medicare payments to PAC
have grown at a consistently higher rate than other major Medicare sectors.
Between 2001 and 2013, Medicare PAC spending grew at an annual rate of 6.1
percent and doubled to $59.4 billion.
Measure Specifications
- NQF Number (if applicable):
- Description: The MSPB-PAC Measure for IRFs evaluates providers’
efficiency relative to the efficiency of the national median IRF provider.
Specifically, the MSPB-PAC Measure assesses the cost to Medicare for services
during an episode of care, which consists of a treatment period and an
associated services period. The episode is triggered by an admission to an
IRF stay. The treatment period begins at the trigger and ends at discharge.
The associated services period begins at the trigger and ends 30 days after
the end of the treatment period (i.e., discharge). These periods constitute
the episode window during which beneficiaries’ Medicare services are counted
toward the episode. The MSPB-PAC episode includes all services during the
episode window that are attributable to the IRF provider and those rendered by
other providers, except those services during the associated services period
that are clinically unrelated to IRF responsibilities (e.g., planned care and
routine screening).
- Numerator: The numerator is the attributed provider’s average
MSPB-PAC Amount. The MSPB-PAC Amount for each IRF provider depends on two
factors: i) the average of the ratio of standardized episode spending level
and expected episode spending for each IRF provider; and ii) the average
standardized episode spending across all IRF providers. To calculate the
MSPB-PAC Amount for each IRF, one finds the average of the ratio of the
standardized episode spending over the expected episode spending, and then
multiplies this quantity by the average episode spending level across all
IRFs.
- Denominator: The denominator for an IRF’s MSPB-PAC Measure is the
weighted median MSPB-PAC Amount across all episodes for IRFs nationally.
- Exclusions: The measure excludes the following episodes: • Any
episode that is triggered by an IRF stay that happens outside the 50 states or
DC. • Any episode that is triggered by an IRF stay for which we see Part C
crossover claims. • Any episode for which standard allowed amount of the IRF
stay could not be calculated or is equal to 0. • Any episode in which a
beneficiary is not enrolled in Medicare Fee-for-Service for the entirety of
the lookback period plus the episode window or is enrolled in Part C for any
part of the lookback plus episode window. • Any episode in which a beneficiary
has a primary payer other than Medicare for any part of the lookback plus
episode window. • Any episode for which the lookback period extends beyond our
observation period.
- HHS NQS Priority: The measure excludes the following episodes: •
Any episode that is triggered by an IRF stay that happens outside the 50
states or DC. • Any episode that is triggered by an IRF stay for which we see
Part C crossover claims. • Any episode for which standard allowed amount of
the IRF stay could not be calculated or is equal to 0. • Any episode in which
a beneficiary is not enrolled in Medicare Fee-for-Service for the entirety of
the lookback period plus the episode window or is enrolled in Part C for any
part of the lookback plus episode window. • Any episode in which a beneficiary
has a primary payer other than Medicare for any part of the lookback plus
episode window. • Any episode for which the lookback period extends beyond our
observation period.
- HHS Data Source: Claims
- Measure Type: Cost/Resource Use
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Concerns were raised about potential
unintended consequences of these measures and noted the need for appropriate
risk adjustment. Members noted that facilities may decline complex patients if
these measures are not appropriately adjusted. MAP also raised concerns about
potential overlap between readmission measures and this may introduce multiple
penalties for the same readmission episode due to multiple measures. MAP
members asked for greater clarity about the definition of a potentially
preventable readmission. MAP also noted that patients seldom have only one
diagnosis and raised concerns about the challenges of separating out numerator
and denominators related to each diagnosis. MAP members raised particular
concerns about this measure for the home health setting, especially as the
patient may not be under the care of the home health agency immediately
post-discharge.
- Public comments received: 13
Rationale for measure provided by HHS
The peer-reviewed literature
specific to potentially preventable readmissions following IRF discharge is
limited. However, MedPAC has estimated that 76 percent of 30-day readmissions
for Medicare beneficiaries overall were due to five potentially preventable
conditions (heart failure, electrolyte imbalance, respiratory infection, sepsis,
and urinary tract infection (MedPAC 2007).
Measure Specifications
- NQF Number (if applicable):
- Description: All-condition risk-adjusted potentially preventable
hospital readmission rates
- Numerator: This measure does not have a simple form for the
numerator and denominator. The numerator is defined as the risk-adjusted
estimate of the number of unplanned potentially preventable readmissions that
occurred within 30 days from IRF discharge. The numerator, as defined,
includes risk adjustment for patient characteristics and a statistical
estimate of the facility effect beyond patient mix.
- Denominator: The denominator is computed with the same model used
for the numerator. It is the model developed using all non-excluded stays in
the national data. The measure includes all stays in the measurement period
that are observed in national Medicare FFS data and do not fall into an
excluded category. For a particular facility, the model is applied to the
patient population, but the facility effect term is 0. In essence, it is the
number of unplanned potentially preventable readmissions that would be
expected for that patient population at the average facility
(New
information provided by CMS on January 19, 2016) The denominator is
computed with the same model used for the numerator. It is the model developed
using all non-excluded IRF stays in the national data.
- Exclusions: 1. Patients who died during the IRF stay 2. Patients
less than 18 years old. 3. Patients who were transferred to the same level of
care or a hospital at the end of their IRF stay. 4. Patients who were not
continuously enrolled in Part A FFS Medicare for the 12 months prior to the
IRF admissions, and at least 30 days after IRF discharge. 5. Patients who did
not have a short-term acute-care stay within 30 days prior to the IRF
admission date. 6. Patients who leave the IRF against medical advice 7.
Patients for whom the prior short-term acute-care stay was for the nonsurgical
treatment of cancer. 8. Patients who were transferred to a federal hospital
from the IRF. 9. Patients who received care from a provider located outside
of the US, Puerto Rico, or a US territory. 10. IRF stays with data that are
problematic (e.g., anomalous records for hospital stays that overlap wholly or
in part or are otherwise erroneous or contradictory).
- HHS NQS Priority: 1. Patients who died during the IRF stay 2.
Patients less than 18 years old. 3. Patients who were transferred to the same
level of care or a hospital at the end of their IRF stay. 4. Patients who were
not continuously enrolled in Part A FFS Medicare for the 12 months prior to
the IRF admissions, and at least 30 days after IRF discharge. 5. Patients who
did not have a short-term acute-care stay within 30 days prior to the IRF
admission date. 6. Patients who leave the IRF against medical advice 7.
Patients for whom the prior short-term acute-care stay was for the nonsurgical
treatment of cancer. 8. Patients who were transferred to a federal hospital
from the IRF. 9. Patients who received care from a provider located outside
of the US, Puerto Rico, or a US territory. 10. IRF stays with data that are
problematic (e.g., anomalous records for hospital stays that overlap wholly or
in part or are otherwise erroneous or contradictory).
(New
information provided by CMS on January 19, 2016) 1. Patients who died
during the IRF stay. 2. Patients less than 18 years old. 3. Patients who were
transferred to the same level of care or a hospital at the end of their IRF
stay. 4. Patients who were not continuously enrolled in Part A FFS Medicare
for the 12 months prior to the IRF admissions, and at least 30 days after IRF
discharge. 5. Patients who did not have a short-term acute-care stay within
30 days prior to the IRF admission date. 6. Patients who leave the IRF
against medical advice. 7. Patients for whom the prior short-term acute-care
stay was for the nonsurgical treatment of cancer. 8. Patients who were
transferred to a federal hospital from the IRF. 9. Patients who received care
from a provider located outside of the US, Puerto Rico, or a US territory. 10.
IRF stays with data that are problematic (e.g., anomalous records for hospital
stays that overlap wholly or in part or are otherwise erroneous or
contradictory).
- HHS Data Source: Claims: This measure is based on Medicare claims
data for fee-for-service beneficiaries using IRF services. Several variables
from the inpatient claims and SNF claims will be used including
admission/discharge dates and diagnostic/procedure information.
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Members noted concerns that about the first
three days of stay in an IRF when a patient may be transferred back to acute
care. Members also noted concerns about being penalized numerous times for the
same readmission. MAP members noted concerns about the impact of socioeconomic
factors and the potential need for the factors to be addressed in the risk
adjustment model.
- Public comments received: 12
Rationale for measure provided by HHS
The peer-reviewed literature
specific to potentially preventable readmissions during an IRF stay is limited.
However, MedPAC has estimated that 76 percent of 30-day readmissions for
Medicare beneficiaries overall were due to five potentially preventable
conditions (heart failure, electrolyte imbalance, respiratory infection, sepsis,
and urinary tract infection (MedPAC 2007).
Measure Specifications
- NQF Number (if applicable):
- Description: All-condition risk-adjusted potentially preventable
hospital readmission rates occurring during an IRF stay
- Numerator: This measure does not have a simple form for the
numerator and denominator. The numerator is defined as the risk-adjusted
estimate of the number of unplanned potentially preventable readmissions that
occurred during an IRF stay. The numerator, as defined, includes risk
adjustment for patient characteristics and a statistical estimate of the
facility effect beyond patient mix.
- Denominator: The denominator is computed with the same model used
for the numerator. It is the model developed using all non-excluded stays in
the national data. The measure includes all stays in the measurement period
that are observed in national Medicare FFS data and do not fall into an
excluded category. For a particular facility, the model is applied to the
patient population, but the facility effect term is 0. In essence, it is the
number of unplanned potentially preventable readmissions that would be
expected for that patient population at the average facility
(New
information provided by CMS on January 19, 2016) The denominator is
computed with the same model used for the numerator. It is the model developed
using all non-excluded IRF stays in the national data.
- Exclusions: 1. Patients who died during the IRF stay. 2. Patients
less than 18 years old. 3. Patients who were not continuously enrolled in Part
A FFS Medicare for the 12 months prior to the IRF admissions, and at least 30
days after IRF discharge. 4. Patients who did not have a short-term
acute-care stay within 30 days prior to the IRF admission date. 5. Patients
who leave the IRF against medical advice 6. Patients for whom the prior
short-term acute-care stay was for the nonsurgical treatment of cancer. 7.
Patients who were transferred to a federal hospital from the IRF. 8. Patients
who received care from a provider located outside of the US, Puerto Rico, or a
US territory. 9. IRF stays with data that are problematic (e.g., anomalous
records for hospital stays that overlap wholly or in part or are otherwise
erroneous or contradictory).
(New information provided by CMS on
January 19, 2016) 1. Patients who died during the IRF stay. 2. Patients
less than 18 years old. 3. Patients who were not continuously enrolled in Part
A FFS Medicare for the 12 months prior to the IRF admissions, and at least 30
days after IRF discharge. 4. Patients who did not have a short-term
acute-care stay within 1 day prior to the IRF admission date. 5. Patients who
leave the IRF against medical advice. 6. Patients for whom the prior
short-term acute-care stay was for the nonsurgical treatment of cancer. 7.
Patients who were transferred to a federal hospital from the IRF. 8. Patients
who received care from a provider located outside of the US, Puerto Rico, or a
US territory. 9. IRF stays with data that are problematic (e.g., anomalous
records for hospital stays that overlap wholly or in part or are otherwise
erroneous or contradictory).
- HHS NQS Priority: 1. Patients who died during the IRF stay. 2.
Patients less than 18 years old. 3. Patients who were not continuously
enrolled in Part A FFS Medicare for the 12 months prior to the IRF admissions,
and at least 30 days after IRF discharge. 4. Patients who did not have a
short-term acute-care stay within 30 days prior to the IRF admission date. 5.
Patients who leave the IRF against medical advice 6. Patients for whom the
prior short-term acute-care stay was for the nonsurgical treatment of cancer.
7. Patients who were transferred to a federal hospital from the IRF. 8.
Patients who received care from a provider located outside of the US, Puerto
Rico, or a US territory. 9. IRF stays with data that are problematic (e.g.,
anomalous records for hospital stays that overlap wholly or in part or are
otherwise erroneous or contradictory).
(New information provided by
CMS on January 19, 2016) 1. Patients who died during the IRF stay. 2.
Patients less than 18 years old. 3. Patients who were not continuously
enrolled in Part A FFS Medicare for the 12 months prior to the IRF admissions,
and at least 30 days after IRF discharge. 4. Patients who did not have a
short-term acute-care stay within 1 day prior to the IRF admission date. 5.
Patients who leave the IRF against medical advice. 6. Patients for whom the
prior short-term acute-care stay was for the nonsurgical treatment of cancer.
7. Patients who were transferred to a federal hospital from the IRF. 8.
Patients who received care from a provider located outside of the US, Puerto
Rico, or a US territory. 9. IRF stays with data that are problematic (e.g.,
anomalous records for hospital stays that overlap wholly or in part or are
otherwise erroneous or contradictory).
- HHS Data Source: Claims: This measure is based on Medicare claims
data for fee-for-service beneficiaries using IRF services. Several variables
from the inpatient claims will be used including admission/discharge dates and
diagnostic/procedure information.
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP members stressed the variation that exists
in the field and noted the importance of this measure.
- Public comments received: 4
Rationale for measure provided by HHS
Patients on invasive
mechanical ventilation comprise a substantial proportion of LTCH patient
admissions, and thus present a critical focus for assessment of high quality
care. In Fiscal Year 2012, the LTCH MS-DRGs for “Respiratory system diagnosis
with ventilator support 96+ hours” (MS-DRG-LTCH 207) and “Respiratory system
diagnosis with ventilator support < 96 hours” (MS-DRG-LTCH 208) accounted for
over 16,000 discharges, or greater than 13% of discharges. (MedPAC 2014).
Mechanically ventilated patients are at higher risk of mortality,
ventilator-associated pneumonia (Cook et al, 1998; Papazian et al., 1996;
Vincent et al., 1995), delirium (Ely et al., 2001), ventilator associated lung
injury (Meade et al., 1995 and 1997; Slutsky and Trembley, 1998), and other
ventilator-associated events. The cost of invasive mechanical ventilation in
LTCHs is considerable, estimated at $1.3 billion in 2006 (Kahn et al., 2010).
Discontinuation of invasive mechanical ventilation is associated with improved
patient outcomes, including lower post-discharge mortality (Aboussouan et al.
2008; Dermot Frengley et al. 2014; Hassenpflug, Steckart, and Nelson 2011).
Citations: Aboussouan, L. S., Lattin, C. D., and Kline, J. L. (2008).
'Determinants of long-term mortality after prolonged mechanical ventilation'.
Lung 186 (5):299-306, doi 10.1007/s00408-008-9110-x. Cook, D. J., Walter, S.
D., Cook, R. J., Griffith, L. E., Guyatt, G. H., Leasa, D., Jaeschke, R. Z., and
Brun-Buisson, C. (1998). 'Incidence of and risk factors for
ventilator-associated pneumonia in critically ill patients'. Ann Intern Med 129
(6):433-40. Dermot Frengley, J., Sansone, G. R., Shakya, K., and Kaner, R. J.
(2014). 'Prolonged mechanical ventilation in 540 seriously ill older adults:
effects of increasing age on clinical outcomes and survival'. J Am Geriatr Soc
62 (1):1-9, doi 10.1111/jgs.12597. Ely EW, Inouye SK, Bernard GR, et al.
Delirium in mechanically ventilated patients: validity and reliability of the
confusion assessment method for the intensive care unit (CAM-ICU). JAMA. 2001
Dec 5;286(21):2703-10. PMID: 11730446. Hassenpflug, M., Steckart, J., and
Nelson, D. (2011). Post-ICU Mechanical Ventilation: Extended Care Facility
Residents Transferred From Intensive Care To Long-Term Acute Care. In, American
Thoracic Society 2011 International Conference. Denver, Colorado. Kahn, J. M.,
Benson, N. M., Appleby, D., Carson, S. S., and Iwashyna, T. J. (2010).
'Long-term acute care hospital utilization after critical illness'. JAMA 303
(22):2253-9, doi 10.1001/jama.2010.761. Meade, M. O., and Cook, D. J. (1995).
'The aetiology, consequences and prevention of barotrauma: a critical review of
the literature'. Clin Intensive Care 6 (4):166-73. Meade, M. O., Cook, D. J.,
Kernerman, P., and Bernard, G. (1997). 'How to use articles about harm: the
relationship between high tidal volumes, ventilating pressures, and
ventilator-induced lung injury'. Crit Care Med 25 (11):1915-22. MedPAC. (2014).
Chapter 11. Long-term Care Hospital Services. In: Report to the Congress:
Medicare Payment Policy. In. Medicare Payment Advisory Commission, Washington,
DC. Papazian, L., Bregeon, F., Thirion, X., Gregoire, R., Saux, P., Denis, J.
P., Perin, G., Charrel, J., Dumon, J. F., Affray, J. P., and Gouin, F. (1996).
'Effect of ventilator-associated pneumonia on mortality and morbidity'. Am J
Respir Crit Care Med 154 (1):91-7, doi 10.1164/ajrccm.154.1.8680705. Slutsky,
A. S., and Tremblay, L. N. (1998). 'Multiple system organ failure. Is mechanical
ventilation a contributing factor?'. Am J Respir Crit Care Med 157 (6 Pt
1):1721-5, doi 10.1164/ajrccm.157.6.9709092. Vincent, J. L., Bihari, D. J.,
Suter, P. M., Bruining, H. A., White, J., Nicolas-Chanoin, M. H., Wolff, M.,
Spencer, R. C., and Hemmer, M. (1995). 'The prevalence of nosocomial infection
in intensive care units in Europe. Results of the European Prevalence of
Infection in Intensive Care (EPIC) Study. EPIC International Advisory
Committee'. JAMA 274 (8):639-44.
Measure Specifications
- NQF Number (if applicable):
- Description: This measure assesses facility-level compliance with
Spontaneous Breathing Trial (SBT), including Tracheostomy Collar Trial (TCT)
or Continuous Positive Airway Pressure (CPAP) breathing trial, by Day 2 of the
LTCH stay for patients on invasive mechanical ventilation (IMV) support upon
admission, and for whom at admission weaning attempts were expected or
anticipated. Compliance is calculated and reported separately for the
following two components: 1. the percentage of patients who were assessed for
readiness for SBT (including TCT or CPAP breathing trial) by Day 2 of the LTCH
stay, 2. the percentage of patients found ready for SBT (including TCT or CPAP
breathing trial) for whom an SBT (including TCT or CPAP breathing trial) was
performed by Day 2 of LTCH stay.
- Numerator: This measure assesses facility-level compliance with
Spontaneous Breathing Trial (SBT), including Tracheostomy Collar Trial (TCT)
or Continuous Positive Airway Pressure (CPAP) breathing trial, by Day 2 of the
LTCH stay for patients on invasive mechanical ventilation (IMV) support upon
admission, and for whom at admission weaning attempts were expected or
anticipated. The numerators for the two (2) components are: the number of
patients who were assessed for readiness for SBT (including TCT or CPAP
breathing trial) by Day 2 of the LTCH stay, 2. the number of patients found
ready for SBT (including TCT or CPAP breathing trial) for whom an SBT
(including TCT or CPAP breathing trial) was performed by Day 2 of LTCH
stay.
- Denominator: The target population (denominator) for this measure
is the total number of patients admitted to the Long Term Care Hospital (LTCH)
during the reporting period who were on invasive mechanical ventilation
support upon upon admission to the LTCH,for whom weaning attempts were
expected or anticipated at admission.
- Exclusions: This measure excludes patients with missing data and
invasively mechanically ventilated patients identified as non-weaning at the
time of admission to an LTCH. Patients who may be considered non-weaning
include patients who are considered chronically ventilated as defined by
evidence-based guidelines for ventilator liberation or patients with an acute
or chronic condition that negates at admission any expectation or anticipation
of weaning attempts (e.g. progressive neuromuscular disease such amyotrophic
lateral sclerosis, or irreversible neurological injury or disease or
dysfunction such as high (C2) spinal cord injury). Consideration of a patient
as non-weaning must be based on documentation found in the patient’s medical
record by Day 2 of LTCH Stay.
- HHS NQS Priority: This measure excludes patients with missing data
and invasively mechanically ventilated patients identified as non-weaning at
the time of admission to an LTCH. Patients who may be considered non-weaning
include patients who are considered chronically ventilated as defined by
evidence-based guidelines for ventilator liberation or patients with an acute
or chronic condition that negates at admission any expectation or anticipation
of weaning attempts (e.g. progressive neuromuscular disease such amyotrophic
lateral sclerosis, or irreversible neurological injury or disease or
dysfunction such as high (C2) spinal cord injury). Consideration of a patient
as non-weaning must be based on documentation found in the patient’s medical
record by Day 2 of LTCH Stay.
- HHS Data Source: LTCH CARE data set. Assessment items related to
mechanical ventilation support will be added to the current assessment tool
for this setting (LTCH CARE Data Set) to ensure operationalization of this
measure.
- Measure Type: Process
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP noted that available discharge codes and
MAP noted that available discharge codes and coding practices could cause
confusion about the results of this measure and could also introduce validity
concerns. MAP asked for greater clarity about the intent of these measures,
especially how they may impact patients and consumers. MAP members raised
concerns about the multiple ways that readmissions are being measured and
noted that a provider could potentially be penalized multiple times for the
same occurrence. MAP noted the need for excluding patients who are admitted
to hospice to prevent discouraging discharges to hospice. MAP also noted that
discharge to community can reflect access to social support and the measure
may need to reflect this. MAP indicated the need for these measures to be
submitted for NQF review and endorsement to address psychometric concerns
about the measures.MAP members noted concerns about the risk adjustment of
these measures, particularly for the home health setting. MAP specifically
noted the need to appropriately risk adjust the measures to avoid unintended
consequences.
- Public comments received: 12
Rationale for measure provided by HHS
The ultimate goals of
post-acute care are avoiding institutionalization and returning patients to
their previous level of independence and functioning, with discharge to
community being the primary goal for the majority of post-acute patients. For
many, home is a symbol of independence, privacy, and competence. Discharge to
community is considered a valuable outcome to measure because it is a
multifaceted measure that captures the patient’s functional status, cognitive
capacity, physical ability, and availability of social support at home. There
is considerable variation in discharge to community rates within and across
post-acute settings. Studies show geographic variation, variation across patient
socioeconomic characteristics (for example, race and ethnicity), and variation
by facility characteristics (for profit vs. nonprofit, freestanding vs.
hospital-based, urban vs. rural). In the IRF setting, discharge to community
rates vary across providers, ranging from about 60% to 75%. The 2015 MedPAC
report shows that, in FY 2013, the facility-level, mean risk-adjusted discharge
to community rate for IRFs within 100 days of admission was 75.8%, and the mean
observed rate was 74.7%. Discharge to community rates also vary widely in the
SNF setting, ranging from as low as 31% to as high as 65%. The 2015 MedPAC
report shows a mean risk-adjusted discharge to community rate of 37.5% for SNFs
within 100 days of admission, and mean observed rate of 40.1%. A multicenter
study of 23 LTCHs reported that only 28.8% of 1,061 patients who were
ventilator-dependent on admission were discharged to home or assisted living
facility. A study of 66,510 Medicare beneficiaries during pre- and post-HH
episodes, revealed that 64 percent of beneficiaries discharged from HH did not
use any other Medicare-reimbursed acute or post-acute services in the 30 days
following HH discharge. Significant numbers of patients were admitted to
inpatient facilities (29 percent) and lesser numbers to skilled nursing
facilities (7.6 percent), inpatient rehabilitation (1.5 percent) and home health
(7.2 percent) or hospice (3.3 percent) within 30 days of HH discharge (Wolff et
al., 2008).
Measure Specifications
- NQF Number (if applicable):
- Description: This measure describes the risk-standardized rate of
Medicare fee-for-service (FFS) patients/residents/persons who are discharged
to the community following a post-acute stay/episode, and do not have an
unplanned (re)admission to an acute care hospital or LTCH in the 31 days
following discharge to community, and remain alive during the 31 days
following discharge to community.
- Numerator: This measure does not have a simple form for the
numerator and denominator. The numerator is defined as the risk-adjusted
estimate of the number of patients/residents/persons included in the measure
who are discharged to the community, and do not have an unplanned
(re)admission to an acute care hospital or LTCH on the day of discharge or in
the 31 days following discharge to community, and remain alive during the 31
days following discharge to community. The numerator estimate includes risk
adjustment for patient/resident/person characteristics, and a statistical
estimate of the facility/agency effect beyond case mix.
- Denominator: The denominator is computed with the same model used
for the numerator. It is the model developed using all non-excluded
facility/agency stays/episodes in the national data. The measure includes all
facility/agency stays/episodes in the measurement period that are observed in
national Medicare FFS data and do not fall into an excluded category. For a
particular facility/agency, the model is applied to the
patient/resident/person population, but the facility/agency effect term is 0.
In essence, it is the number of discharges to community that would be expected
for that patient/resident/person population at the average
facility/agency.
- Exclusions: i) Age under 18 years; (ii) No short-term acute care
stay within 30 days prior to LTCH admission ; (iii) Discharges to psychiatric
hospital; (iv) Discharges against medical advice; (v) Discharges to federal
hospitals or disaster alternative care sites; (vi) Patients not continuously
enrolled in Part A FFS Medicare for the 12 months prior to the LTCH stay
admission date, and at least 31 days after PAC discharge date; (vii) Patients
whose prior short-term acute-care stay was for non-surgical treatment of
cancer; (viii) Discharges to hospice; (ix) LTCH stays that end in transfer to
another LTCH; (x) LTCH stays with claims data that are problematic (e.g.,
anomalous records for stays that overlap wholly or in part, or are otherwise
erroneous or contradictory); (xi) Patients who received care from a provider
located outside of the US, Puerto Rico, or a US territory.
- HHS NQS Priority: i) Age under 18 years; (ii) No short-term acute
care stay within 30 days prior to LTCH admission ; (iii) Discharges to
psychiatric hospital; (iv) Discharges against medical advice; (v) Discharges
to federal hospitals or disaster alternative care sites; (vi) Patients not
continuously enrolled in Part A FFS Medicare for the 12 months prior to the
LTCH stay admission date, and at least 31 days after PAC discharge date; (vii)
Patients whose prior short-term acute-care stay was for non-surgical treatment
of cancer; (viii) Discharges to hospice; (ix) LTCH stays that end in transfer
to another LTCH; (x) LTCH stays with claims data that are problematic (e.g.,
anomalous records for stays that overlap wholly or in part, or are otherwise
erroneous or contradictory); (xi) Patients who received care from a provider
located outside of the US, Puerto Rico, or a US territory.
- HHS Data Source: Claims
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP noted the importance of medication
reconciliation but raised concerns and asked for greater clarity about the
definition of reconciliation versus drug regimen review. Members also noted
the challenge of defining some of the measure components, specifically “a
clinically significant issue” given the large number of medications a patient
may be taking. MAP stressed that medication reconciliation is a step in a drug
regimen review and asked for greater clarity on defining the drug regimen
review process. MAP stressed the importance of conducting a complete
medication review from all sites of care, including the home. MAP members
noted the value of the role of family caregivers in providing this information
and the hope that technology can help to minimize the burden of getting this
information. MAP members asked for greater emphasis of the inclusion of
non-prescription medication (including supplements), noting that this is a
particular concern in the PAC/LTC population.MAP members raised some concerns
about the feasibility of this measure and noted the need to clarify the roles
of the interdisciplinary team. MAP noted the importance of attribution issues
for this measure. Additionally, Workgroup members raised concerns about the
challenges of competing guidelines and need for greater clarity about when a
medication can be withdrawn. MAP stressed that medication reconciliation needs
to be an on-going process. MAP also noted that this is a particular concern
for dual-eligible beneficiaries.
- Public comments received: 4
Rationale for measure provided by HHS
Medication review in
post-acute care is generally considered to include medication reconciliation for
all medications and medication review for what poses as potential clinically
significant medication issues for the patient/resident. As a process measure,
medication reconciliation and medication review for potential clinically
significant medication issues are expected to reduce re-hospitalizations, reduce
adverse events related to medications and improve health outcomes.
(New information provided by CMS on January 19, 2016) Medication
review in post-acute care is generally considered to include medication
reconciliation and drug regimen review for all medications and for what poses as
potential clinically significant medication issues for the patient/resident. As
a process measure, medication reconciliation and drug regimen review for
potential clinically significant medication issues are expected to reduce
re-hospitalizations, reduce adverse events related to medications and improve
health outcomes.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of stays Inpatient Rehabilitation Facility
(IRF), Long Term Care Facility (LTCH), and Skilled Nursing Facility (SNF) or
care episodes Home Health (HH) in which a drug regimen review was conducted at
the Admission (IRF, LTCH or SNF)/ Start of Care (SOC)/ Resumption of Care
(ROC) (HH) and timely follow-up with a physician occurred each time potential
clinically significant medication issues were identified throughout the stay
(IRF, LTCH, or SNF) or care episode (HH).
- Numerator: Number of stays or care episodes where the medical
record contains documentation of a drug regimen review conducted at admission
or start-of-care or resumption-of-care with all potential clinically
significant medication issues identified during the course of care and
followed-up with a physician or physician designee.
- Denominator: Care episodes or stays ending during the reporting
period. Assessment timing is as follows: Beginning of care
episode or stay: • HH – SOC or ROC • SNF – Admission • IRF - Admission • LTCH
– Admission End of care episode or stay: • HH – Transfer, Discharge, or
Death at Home • SNF – Discharge, or expired • IRF – Discharge, or expired •
LTCH – Discharge, or expired
- Exclusions: Denominator Exclusion: NONE Numerator Exclusion:
NONE
- HHS NQS Priority: Denominator Exclusion: NONE Numerator Exclusion:
NONE
(New information provided by CMS on January 19, 2016)
Denominator Exclusion: NONE Numerator Exclusion: NONE
- HHS Data Source: Patient assessment data
- Measure Type: Process
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Members noted the importance of balancing cost
measures with quality and access. Although the MAP encouraged continued
development, they did note concerns about the potential for unintended
consequences.
- Public comments received: 8
Rationale for measure provided by HHS
Medicare payments to PAC
have grown at a consistently higher rate than other major Medicare sectors.
Between 2001 and 2013, Medicare PAC spending grew at an annual rate of 6.1
percent and doubled to $59.4 billion.
Measure Specifications
- NQF Number (if applicable):
- Description: The MSPB-PAC Measure for LTCHs evaluates providers’
efficiency relative to the efficiency of the national median LTCH provider.
Specifically, the MSPB-PAC Measure assesses the cost to Medicare for services
during an episode of care, which consists of a treatment period and an
associated services period. The episode is triggered by an admission to an
LTCH stay. The treatment period begins at the trigger and ends at discharge.
The Measure is constructed differently for cases in which the LTCH stay is
paid according to the standard MS-LTC-DRG versus cases in which the LTCH stay
is paid a site neutral rate comparable to the IPPS payment rates. The
associated services period for standard payment rate cases begins at the
trigger and ends 30 days after the end of the treatment period (i.e.,
discharge). The associated services period for site neutral payment rate
cases begins at the close of the treatment period and ends 30 days after, to
parallel the MSPB-Hospital measure. For the standard and site neutral cases,
these periods constitute the episode window during which beneficiaries’
Medicare services are counted toward the episode. For the standard cases, the
MSPB-PAC episode includes all services during the episode window that are
attributable to the LTCH provider and those rendered by other providers,
except those services during the associated services period that are
clinically unrelated to LTCH responsibilities (e.g., planned care and routine
screening). For the site neutral cases, the MSPB-PAC episode includes all
services during the episode window that are attributable to the LTCH provider
and those rendered by other providers, except those services during the
associated services period that are clinically unrelated to LTCH
responsibilities (e.g., planned care and routine screening). As discussed
above, there is a difference in the construction of the associated services
period for these cases, in that it only begins at discharge and ends 30 days
after.
- Numerator: The numerator is the attributed provider’s average
MSPB-PAC Amount. The MSPB-PAC Amount for each LTCH provider depends on two
factors: i) the average of the ratio of standardized episode spending level
and expected episode spending for each LTCH provider; and ii) the average
standardized episode spending across all LTCH providers. To calculate the
MSPB-PAC Amount for each LTCH, one finds the average of the ratio of the
standardized episode spending over the expected episode spending, and then
multiplies this quantity by the average episode spending level across all
LTCHs.
- Denominator: The denominator for an LTCH’s MSPB-PAC Measure is the
weighted median MSPB-PAC Amount across all episodes for LTCHs
nationally.
- Exclusions: The measure excludes the following episodes: • Any
episode that is triggered by a LTCH stay that happens outside the 50 states or
DC. • Any episode that is triggered by a LTCH stay for which we see Part C
crossover claims. • Any episode for which standard allowed amount of the LTCH
stay could not be calculated or is equal to 0. • Any episode in which a
beneficiary is not enrolled in Medicare Fee-for-Service for the entirety of
the lookback period plus the episode window or is enrolled in Part C for any
part of the lookback plus episode window. • Any episode in which a beneficiary
has a primary payer other than Medicare for any part of the lookback plus
episode window. • Any episode for which the lookback period extends beyond our
observation period.
- HHS NQS Priority: The measure excludes the following episodes: •
Any episode that is triggered by a LTCH stay that happens outside the 50
states or DC. • Any episode that is triggered by a LTCH stay for which we see
Part C crossover claims. • Any episode for which standard allowed amount of
the LTCH stay could not be calculated or is equal to 0. • Any episode in which
a beneficiary is not enrolled in Medicare Fee-for-Service for the entirety of
the lookback period plus the episode window or is enrolled in Part C for any
part of the lookback plus episode window. • Any episode in which a beneficiary
has a primary payer other than Medicare for any part of the lookback plus
episode window. • Any episode for which the lookback period extends beyond our
observation period.
- HHS Data Source: Claims
- Measure Type: Cost/Resource Use
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Members noted concerns that medications are
often started in the hospital and questioned if the measure could be
structured to reward LTCHs for a reduction in use.
- Public comments received: 4
Rationale for measure provided by HHS
Antipsychotic medication use
is common among older adults in all post acute care settings. Antipsychotic
medications can be potentially dangerous for the elderly, especially for those
whom the medications are clinically indicated. Of particular concern is the
off-label use of these drugs for older adults with dementia or dementia-related
psychoses or agitation (Jeste et al., 2008). The FDA issued a black box warning
against prescribing atypical antipsychotic medications for older adults with
dementia in 2005 (Rosack, 2005). The evidence on which the warning is based on a
meta-analysis of 17 randomized trials with a total of 5,106 patients that
identified an “approximately 1.6- to 1.7-fold increase in mortality in the
combined studies” (Rosack, 2005). Three years later, the FDA (June 2008)
extended the warning to all categories of antipsychotic drugs (conventional
& atypical). In addition to elevated mortality risk, elevated risk for
serious adverse events such as falls, somnolence, and abnormal gait are results
from clinical trials of atypical antipsychotic (AP) medications (Rosack, 2005;
FDA, 2008; Ballard & Margallo-Lana, 2004; Martin et al., 2003; Neil, Curran,
and Wattis, 2003; Doody et al., 2001; Jackson-Siegal, 2004). Also, there is
evidence of increased risk for cerebrovascular adverse events associated with
certain atypical antipsychotic medications (e.g., risperidone, olanzapine, and
aripiprazole) (Jeste et al., 2008). Regardless of the warnings and potential
adverse events, the administration of antipsychotic therapy is common and
frequent among mechanically ventilated patients or among patients with delirium
(Al-Qadheeb et al., 2013).
Measure Specifications
- NQF Number (if applicable):
- Description: This measure reports the percentage of patients in a
Long Term Care Hospital who receive antipsychotic medications during the
target period.
- Numerator: The numerator is the number of Long Term Care Hospital
patients receiving antipsychotic medications.
- Denominator: The denominator is the total of all patients in a Long
Term Care Hospital during the target period except for those who meet
exclusion criteria.
- Exclusions: Patients will be excluded from the denominator if they
are diagnosed with any of the following conditions: schizophrenia, Tourette's
syndrome, and Huntington's Disease.
- HHS NQS Priority: Patients will be excluded from the denominator if
they are diagnosed with any of the following conditions: schizophrenia,
Tourette's syndrome, and Huntington's Disease.
- HHS Data Source: LTCH CARE data set
- Measure Type: Process
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Concerns were raised about potential
unintended consequences of these measures and noted the need for appropriate
risk adjustment. Members noted that facilities may decline complex patients if
these measures are not appropriately adjusted. MAP also raised concerns about
potential overlap between readmission measures and this may introduce multiple
penalties for the same readmission episode due to multiple measures. MAP
members asked for greater clarity about the definition of a potentially
preventable readmission. MAP also noted that patients seldom have only one
diagnosis and raised concerns about the challenges of separating out numerator
and denominators related to each diagnosis. MAP members raised particular
concerns about this measure for the home health setting, especially as the
patient may not be under the care of the home health agency immediately
post-discharge.
- Public comments received: 9
Rationale for measure provided by HHS
The peer-reviewed literature
specific to potentially preventable readmissions following LTCH discharge is
limited. However, MedPAC has estimated that 76 percent of 30-day readmissions
for Medicare beneficiaries overall were due to five potentially preventable
conditions (heart failure, electrolyte imbalance, respiratory infection, sepsis,
and urinary tract infection (MedPAC 2007).
Measure Specifications
- NQF Number (if applicable):
- Description: All-condition risk-adjusted potentially preventable
hospital readmission rates
- Numerator: This measure does not have a simple form for the
numerator and denominator. The numerator is defined as the risk-adjusted
estimate of the number of unplanned, potentially preventable readmissions that
occurred within 30 days from LTCH discharge. The numerator, as defined,
includes risk adjustment for patient characteristics and a statistical
estimate of the facility effect beyond patient mix.
- Denominator: The denominator is computed with the same model used
for the numerator. It is the model developed using all non-excluded stays in
the national data. The measure includes all stays in the measurement period
that are observed in national Medicare FFS data and do not fall into an
excluded category. For a particular facility, the model is applied to the
patient population, but the facility effect term is 0. In essence, it is the
number of unplanned potentially preventable readmissions that would be
expected for that patient population at the average facility
(New
information provided by CMS on January 19, 2016) The denominator is
computed with the same model used for the numerator. It is the model developed
using all non-excluded LTCH stays in the national data.
- Exclusions: 1. Patients who died during the LTCH stay. 2. Patients
less than 18 years old. 3. Patients who were transferred to the same level of
care or a hospital at the end of their LTCH stay 4. Patients who were not
continuously enrolled in Part A FFS Medicare for the 12 months prior to the
LTCH admissions, and at least 30 days after LTCH discharge. 5. Patients who
did not have a short-term acute-care stay within 30 days prior to the LTCH
admission date. 6. Patients who leave the LTCH against medical advice 7.
Patients for whom the prior short-term acute-care stay was for the nonsurgical
treatment of cancer. 8. Patients who were transferred to a federal hospital
from the LTCH. 9. Patients who received care from a provider located outside
of the US, Puerto Rico, or a US territory. 10. LTCH stays with data that are
problematic (e.g., anomalous records for hospital stays that overlap wholly or
in part or are otherwise erroneous or contradictory).
- HHS NQS Priority: 1. Patients who died during the LTCH stay. 2.
Patients less than 18 years old. 3. Patients who were transferred to the same
level of care or a hospital at the end of their LTCH stay 4. Patients who were
not continuously enrolled in Part A FFS Medicare for the 12 months prior to
the LTCH admissions, and at least 30 days after LTCH discharge. 5. Patients
who did not have a short-term acute-care stay within 30 days prior to the LTCH
admission date. 6. Patients who leave the LTCH against medical advice 7.
Patients for whom the prior short-term acute-care stay was for the nonsurgical
treatment of cancer. 8. Patients who were transferred to a federal hospital
from the LTCH. 9. Patients who received care from a provider located outside
of the US, Puerto Rico, or a US territory. 10. LTCH stays with data that are
problematic (e.g., anomalous records for hospital stays that overlap wholly or
in part or are otherwise erroneous or contradictory).
(New
information provided by CMS on January 19, 2016) 1. Patients who died
during the LTCH stay. 2. Patients less than 18 years old. 3. Patients who
were transferred to the same level of care or a hospital at the end of their
LTCH stay. 4. Patients who were not continuously enrolled in Part A FFS
Medicare for the 12 months prior to the LTCH admissions, and at least 30 days
after LTCH discharge. 5. Patients who did not have a short-term acute-care
stay within 30 days prior to the LTCH admission date. 6. Patients who leave
the LTCH against medical advice. 7. Patients for whom the prior short-term
acute-care stay was for the nonsurgical treatment of cancer. 8. Patients who
were transferred to a federal hospital from the LTCH. 9. Patients who
received care from a provider located outside of the US, Puerto Rico, or a US
territory. 10. LTCH stays with data that are problematic (e.g., anomalous
records for hospital stays that overlap wholly or in part or are otherwise
erroneous or contradictory).
- HHS Data Source: Claims: This measure is based on Medicare claims
data for fee-for-service beneficiaries using LTCH services. Several variables
from the inpatient claims will be used including admission/discharge dates and
diagnostic/procedure information.
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: This measure was also reviewed by MAP in the
2014-2015 Pre-rulemaking cycle. This measure has high value potential for the
LTCH QRP because successful weaning is associated with decreased morbidity,
mortality, and resource use.
- Public comments received: 4
Rationale for measure provided by HHS
Patients on invasive
mechanical ventilation comprise a substantial proportion of LTCH patient
admissions, and thus present a critical focus for assessment of high quality
care. In Fiscal Year 2012, the LTCH MS-DRGs for “Respiratory system diagnosis
with ventilator support 96+ hours” (MS-DRG-LTCH 207) and “Respiratory system
diagnosis with ventilator support < 96 hours” (MS-DRG-LTCH 208) accounted for
over 16,000 discharges, or greater than 13% of discharges. (MedPAC 2014).
Mechanically ventilated patients are at higher risk of mortality,
ventilator-associated pneumonia (Cook et al, 1998; Papazian et al., 1996;
Vincent et al., 1995), delirium (Ely et al., 2001), ventilator associated lung
injury (Meade et al., 1995 and 1997; Slutsky and Trembley, 1998), and other
ventilator-associated events. The cost of invasive mechanical ventilation in
LTCHs is considerable, estimated at $1.3 billion in 2006 (Kahn et al., 2010).
Discontinuation of invasive mechanical ventilation is associated with improved
patient outcomes, including lower post-discharge mortality (Aboussouan et al.
2008; Dermot Frengley et al. 2014; Hassenpflug, Steckart, and Nelson 2011).
Citations: Aboussouan, L. S., Lattin, C. D., and Kline, J. L. (2008).
'Determinants of long-term mortality after prolonged mechanical ventilation'.
Lung 186 (5):299-306, doi 10.1007/s00408-008-9110-x. Cook, D. J., Walter, S.
D., Cook, R. J., Griffith, L. E., Guyatt, G. H., Leasa, D., Jaeschke, R. Z., and
Brun-Buisson, C. (1998). 'Incidence of and risk factors for
ventilator-associated pneumonia in critically ill patients'. Ann Intern Med 129
(6):433-40. Dermot Frengley, J., Sansone, G. R., Shakya, K., and Kaner, R. J.
(2014). 'Prolonged mechanical ventilation in 540 seriously ill older adults:
effects of increasing age on clinical outcomes and survival'. J Am Geriatr Soc
62 (1):1-9, doi 10.1111/jgs.12597. Ely EW, Inouye SK, Bernard GR, et al.
Delirium in mechanically ventilated patients: validity and reliability of the
confusion assessment method for the intensive care unit (CAM-ICU). JAMA. 2001
Dec 5;286(21):2703-10. PMID: 11730446. Hassenpflug, M., Steckart, J., and
Nelson, D. (2011). Post-ICU Mechanical Ventilation: Extended Care Facility
Residents Transferred From Intensive Care To Long-Term Acute Care. In, American
Thoracic Society 2011 International Conference. Denver, Colorado. Kahn, J. M.,
Benson, N. M., Appleby, D., Carson, S. S., and Iwashyna, T. J. (2010).
'Long-term acute care hospital utilization after critical illness'. JAMA 303
(22):2253-9, doi 10.1001/jama.2010.761. Meade, M. O., and Cook, D. J. (1995).
'The aetiology, consequences and prevention of barotrauma: a critical review of
the literature'. Clin Intensive Care 6 (4):166-73. Meade, M. O., Cook, D. J.,
Kernerman, P., and Bernard, G. (1997). 'How to use articles about harm: the
relationship between high tidal volumes, ventilating pressures, and
ventilator-induced lung injury'. Crit Care Med 25 (11):1915-22. MedPAC. (2014).
Chapter 11. Long-term Care Hospital Services. In: Report to the Congress:
Medicare Payment Policy. In. Medicare Payment Advisory Commission, Washington,
DC. Papazian, L., Bregeon, F., Thirion, X., Gregoire, R., Saux, P., Denis, J.
P., Perin, G., Charrel, J., Dumon, J. F., Affray, J. P., and Gouin, F. (1996).
'Effect of ventilator-associated pneumonia on mortality and morbidity'. Am J
Respir Crit Care Med 154 (1):91-7, doi 10.1164/ajrccm.154.1.8680705. Slutsky,
A. S., and Tremblay, L. N. (1998). 'Multiple system organ failure. Is mechanical
ventilation a contributing factor?'. Am J Respir Crit Care Med 157 (6 Pt
1):1721-5, doi 10.1164/ajrccm.157.6.9709092. Vincent, J. L., Bihari, D. J.,
Suter, P. M., Bruining, H. A., White, J., Nicolas-Chanoin, M. H., Wolff, M.,
Spencer, R. C., and Hemmer, M. (1995). 'The prevalence of nosocomial infection
in intensive care units in Europe. Results of the European Prevalence of
Infection in Intensive Care (EPIC) Study. EPIC International Advisory
Committee'. JAMA 274 (8):639-44.
Measure Specifications
- NQF Number (if applicable):
- Description: For patients admitted to an LTCH on invasive
mechanical ventilation support and for whom weaning attempts were expected or
anticipated at admission, this measure reports: (1) percentage of patients
fully weaned at discharge (alive) (Ventilator Weaning/Liberation Rate), and
(2) percentage of patients not fully weaned at discharge (alive).
- Numerator: The numerator represents the number of patients within
each category of weaning status at discharge. The numerator will be calculated
separately according to each of the measure component groups below. Each
numerator component is the number of patients in the following categories: (1)
the number of patients reported as fully weaned on planned or unplanned
discharge assessment (2) the number of patients reported as not fully weaned
on planned or unplanned discharge assessment. A patient is considered fully
weaned if s/he does not require any invasive mechanical ventilation support
for at least 2 consecutive calendar days immediately prior to the date of
discharge (alive or dead) from an LTCH.
- Denominator: The target population (denominator) for this measure
is the total number of patients who were discharged (alive or dead) from an
LTCH during the reporting period and who were on invasive mechanical
ventilation support upon admission to the LTCH, for whom weaning attempts were
expected or anticipated at admission.
- Exclusions: This measure excludes patients with missing data and
invasively mechanically ventilated patients identified as non-weaning at the
time of admission to an LTCH. Patients who may be considered non-weaning
include patients who are considered chronically ventilated as defined by
evidence-based guidelines for ventilator liberation or patients with an acute
or chronic condition that negates at admission any expectation or anticipation
of weaning attempts (e.g. progressive neuromuscular disease such amyotrophic
lateral sclerosis, or irreversible neurological injury or disease or
dysfunction such as high (C2) spinal cord injury). Consideration of a patient
as non-weaning must be based on documentation found in the patient’s medical
record by Day 2 of LTCH Stay.
- HHS NQS Priority: This measure excludes patients with missing data
and invasively mechanically ventilated patients identified as non-weaning at
the time of admission to an LTCH. Patients who may be considered non-weaning
include patients who are considered chronically ventilated as defined by
evidence-based guidelines for ventilator liberation or patients with an acute
or chronic condition that negates at admission any expectation or anticipation
of weaning attempts (e.g. progressive neuromuscular disease such amyotrophic
lateral sclerosis, or irreversible neurological injury or disease or
dysfunction such as high (C2) spinal cord injury). Consideration of a patient
as non-weaning must be based on documentation found in the patient’s medical
record by Day 2 of LTCH Stay.
- HHS Data Source: LTCH CARE data set. Assessment items related to
mechanical ventilation support will be added to the current assessment tool
for this setting (LTCH CARE Data Set) to ensure operationalization of this
measure.
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support
- Workgroup Rationale: Minimizing complications from a procedure is
important and comparing complication rates among providers is critical for
patients and families when making decisions about healthcare. The American
Heart Association and American Stroke Association recommend a complication
rate less than 6% for carotid artery stenting. Complication rates higher than
6% negate the potential benefit of stroke risk reduction. This adverse outcome
measure is a “companion” measure to PQRS #345 - Rate of Postoperative Stroke
or Death in Asymptomatic Patients Undergoing Carotid Artery Stenting (CAS) and
captures a different patient population – those with symptoms (but not acute
emergencies.) MAP conditionally supports this measure intended for
interventional radiologists and addresses the quality domain of patient
safety. CONDITION: The measure should be submitted to NQF for
endorsement.
- Public comments received: 2
Rationale for measure provided by HHS
This measure complements the
companion measure in symptomatic patients. The rationale for separating
asymptomatic and symptomatic patients is that the recommended treatment criteria
for each is different (stenosis grade) and a worse outcome score could be
acceptable in symptomatic patients. This measure represents an unmet outcome
measure for patients in multiple CMS programs.
Measure Specifications
- NQF Number (if applicable):
- Description: Percent of patients with prior neurological symptoms
experiencing Stroke or Death within 30 days of Carotid Artery
Stenting
- Numerator: All symptomatic patients with stroke or death within 30
days of Carotid Artery Stenting
- Denominator: All symptomatic patients undergoing Carotid Artery
Stenting
- Exclusions: Patients being treated with emergent Carotid Artery
Stenting (Acute ischemic stroke or Trauma) Exceptions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Multicenter Registry in Hospital/Acute Care
Facility
- Measure Type: Outcome
- Steward: Society of Interventional Radiology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Entropion is an inversion of the eyelid (i.e.,
inward turning of the eyelid margin) toward the globe. Lower lid entropion is
a common condition in elderly individuals; the prevalence increases steadily
with age. Involutional entropion is the most common form of entropion.
Patients seek treatment due to eye irritation, watering of the eye or cosmetic
concerns. MAP encourages development of outcomes measures but data is not
available to understand the opportunity for improvement for this procedure. A
patient-reported outcome measure on symptom or cosmetic improvement may be
more informative for public reporting
- Public comments received: 9
Rationale for measure provided by HHS
Normalized lid position is
the desired goal of surgery to improve clinical and functional outcomes for the
patient
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of surgical entropion patients with a
postoperative normalized lid position
- Numerator: Patients who achieved normalized lid position
postoperatively within 90 days of surgery
- Denominator: Patients aged 18 years or older with a diagnosis of
involutional entropion who underwent a surgical procedure for the
condition
- Exclusions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Outcome
- Steward: American Academy of Ophthalmology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: The presence of Grade 0 anterior chamber cells
indicates reduced inflammation in response to therapy. Though signs of
improvement are welcome, the important outcomes are reduction in patient
symptoms and good vision. MAP encourages further development though it is
unclear what this intermediate outcome measure adds to the functional outcome
measure - Acute Anterior Uveitis: Post-treatment visual acuity which is more
meaningful for public reporting.
- Public comments received: 7
Rationale for measure provided by HHS
Reduction of inflammation is
a desired treatment goal for improved clinical and functional outcome
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with acute anterior uveitis who
post-treatment had Grade 0 anterior chamber cells.
- Numerator: Patients achieved Grade 0 anterior chamber cells at 30
days after onset of treatment
- Denominator: Patients aged 18 years of older who underwent
treatment for acute anterior uveitis
- Exclusions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Outcome
- Steward: American Academy of Ophthalmology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP encourages further development of this
outcome measure evaluating the effectiveness of treatment for an eye condition
not yet represented in the clinician measure set. Measures of treatment
effectiveness for maintaining vision are informative for public
reporting.
- Public comments received: 7
Rationale for measure provided by HHS
Improvement of visual acuity
is a desired treatment goal to continue the level of the patient's daily
activities of daily living and quality of life
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of acute anterior uveitis patients with a
post-treatment best corrected visual acuity of 20/40 or greater OR patients
whose visual acuity had returned to their baseline value prior to onset of
uveitis
- Numerator: Best corrected visual acuity of 20/40 or better achieved
within 90 days following treatment initiation OR Patient's visual acuity
returned to baseline value within 90 days of treatment initiation
- Denominator: Patients aged 18 years of older who underwent
treatment for acute anterior uveitis
- Exclusions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Outcome
- Steward: American Academy of Ophthalmology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not encourage further
consideration
- Workgroup Rationale: MAP does not encourage continued consideration
of this assessment measure because two other measures for iliio-femoral
stenting that capture a patient reported outcome (MUC15-411) and the objective
clinical assessment (MUC-413) provide more robust information about the
procedure and includes the assessment aspect. This measure would be redundant
with the other two measures.
- Public comments received: 2
Rationale for measure provided by HHS
The Villalta score is a
well-recognized composite score that integrates patient reported symptoms with
signs of the severity of post-thrombotic syndrome in patients with ilio-femoral
venous disease (hence represents both PRO and an intermediate outcome measures).
It is simple to administer clinically and is a reliable measure to ascertain
both the clinical severity as well as morbidity associated with post-thrombotic
syndrome. There is a measure gap in the area of venous disease and this measure
will help to address this. The Villalta score can be integrated into structured
reporting that is being piloted by the SIR, potentially enabling QCDR level
reporting of the measure. An advantage over surveys is that this scoring system
can be use uniformly by many sites. A disadvantage over surveys is that patients
must be seen to have the follow-up score documented.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients who demonstrate improvement
signs and symptoms of post-thrombotic syndrome as assessed using the Villalta
Score following ilio-femoral venous stenting
- Numerator: The number of patients who demonstrate an improvement in
the Villalta score following ilio-femoral venous stenting as assessed between
3-6 months post procedure
- Denominator: The total number of patients who underwent
ilio-femoral venous stenting with clinical assessment using the Villalta score
at baseline and between 3-6 months post-procedure
- Exclusions: Patients with a history of lower extremity or pelvic
vein surgery. Exceptions: Patients with a history of pelvic or lower
extremity orthopedic surgery. Patients with debilitating osteoarthritis
involving the hips, knees, or ankles.
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Composite
- Steward: Society of Interventional Radiology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: The presence of Grade 0 anterior chamber cells
indicates reduced inflammation in response to therapy. Though signs of
improvement are welcome, the important outcomes are reduction in patient
symptoms and good vision. MAP encourages further development though it is
unclear what this intermediate outcome measure adds to the functional outcome
measure - Chronic Anterior Uveitis: Post-treatment visual acuity which is more
meaningful for public reporting.
- Public comments received: 7
Rationale for measure provided by HHS
Reduction of inflammation is
a desired treatment goal for improved clinical and functional outcome
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with chronic anterior uveitis
who post-treatment had Grade 0 anterior chamber cells.
- Numerator: Patients achieved Grade 0 anterior chamber cells at 30
days after onset of treatment AND Patients managed at 60 days with dose of
topical corticosteroids or prednisolone acetate (or equivalent) 1% 3X/days or
less
- Denominator: Patients aged 18 years of older who underwent
treatment for chronic anterior uveitis
- Exclusions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Outcome
- Steward: American Academy of Ophthalmology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Chronic uveitis is active uveitis that
persists longer than three months. Chronic anterior uveitis is an insidious in
onset, persistent, associated with a high incidence of visually threatening
complications, and has a variable long term visual prognosis. It may be
associated with systemic diseases such as juvenile chronic arthritis, Behçet's
disease, and sarcoidosis. The aims of treatment are to control inflammation,
prevent visual loss, and minimize long term complications of the disease and
its treatment. MAP agrees that measures assessing maintaining vision are
critically important in treating this condition. It is not clear whether
patients that fail treatment for acute uveitis in MUCFIFTEEN-394 Acute
Anterior Uveitis: Post-treatment visual acuity are the patients in this
measure or when the 90 days specified begins. No data on current performance
is available to determine the opportunity for improvement.
- Public comments received: 7
Rationale for measure provided by HHS
Improvement of visual acuity
is a desired treatment goal to continue the level of the patient's daily
activities of daily living and quality of life
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of chronic anterior uveitis patients with a
post-treatment best corrected visual acuity of 20/40 or greater OR patients
whose visual acuity had returned to their baseline value prior to onset of
uveitis
- Numerator: Best corrected visual acuity of 20/40 or better achieved
within 90 days following treatment initiation OR Patient's visual acuity
returned to baseline value within 90 days of treatment initiation
- Denominator: Patients aged 18 years of older who underwent
treatment for chronic anterior uveitis
- Exclusions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Outcome
- Steward: American Academy of Ophthalmology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Arterial access is performed for a wide range
of interventional radiology, interventional cardiology, and vascular surgery
procedures. Clinical guidelines have noted that “modest hematomas from femoral
arterial access occur in up to 10% of patients, where as major hematomas are
rare (0.5%). The frequency of other arterial access site complications is more
variable.” Measurement of adverse outcomes provides meaningful information for
patients. It is unclear whether the distinction between “modest hematoma”
(which does not count in the measure) and “major hematoma” will result in
reliable results without better definitions. MAP encourages continued
development of this adverse outcome measure for vascular access performed
commonly across a wide range of interventional radiology, interventional
cardiology, and vascular surgery procedures.
- Public comments received: 2
Rationale for measure provided by HHS
Arterial access is a
critical step for any arterial vascular intervention and is performed commonly
across a wide range of interventional radiology, interventional cardiology, and
vascular surgery procedures. Arterial access site complications are a
significant contributor to patient discomfort and morbidity in the perioperative
period, and are a fortunately rare cause for mortality. Common femoral arterial
access is by far the most common site of access for a variety of endovascular
procedures. The size of the arterial access and the presence of underlying
vascular disease are predisposing factors to arterial access site complications.
This measure is intended to focus on access site complications using 8Fr or
small sheath sizes, and can be reported in any center performing arterial
procedures as a measure of quality patient care. The rationale to limit the
upper size of the access to 8Fr is to limit the measure to procedures with
exclusively percutaneous access. Physicians using this measure are free to
utilize Ultrasound for arterial access and can report the measure regardless if
they use closure devices or rely on manual pressure as a strategy for achieving
hemostasis. There is significant morbidity that may result from procedures
performed downstream on patients with access site complications, including open
repair of the injured artery site. The SIR Clinical Practice Guidelines (JVIR
2003, Vol 14, Issue 9, Part 2, S283-288) have noted that modest hematomas from
femoral arterial access occur in up to 10% of patients, whereas major hematomas
are rare (0.5%). The frequency of other arterial access site complications is
more variable. As proposed this measure compliments a measure being considered
for the 2016 PQRS program entitled ""Rate of surgical conversion from lower
extremity endovascular revascularization procedure"" by detailing access site
complications specifically. Access site complications are a modifiable risk
factor for surgical conversion in lower extremity arterial procedures
specifically."
Measure Specifications
- NQF Number (if applicable):
- Description: The percentage of groin arterial access procedures
with a vascular complication other than a modest hematoma with an access
system of 8Fr or less. Access site complications tracked with this measure
include pseudoaneurysms, arteriovenous fistulae, large hematomas, arterial
dissection requiring intervention, arterial thromboembolism, and
infectious
- Numerator: Number of percutaneous arterial access procedures with a
vascular complication from common femoral arterial access using a system of
8Fr or less in size including pseudoaneurysms, arteriovenous fistulae, large
hematomas, arterial dissection requiring intervention, arterial
thromboembolism, and infectious arteritis.
- Denominator: All percutaneous groin arterial access procedures
using access sheath sizes of 8Fr or less. For patients undergoing bilateral
arterial access each access site should be considered a separate
event.
- Exclusions: Exclusions: Patients with a history of surgical lower
extremity bypass. Exceptions: Patients with recent groin arterial access with
uncertain vascular access status (i.e. outside arterial procedure, uncertain
if complication occurred); Recent arterial vascular access procedure with
complication referred for subsequent treatment
- HHS NQS Priority: Making Care Safer
- HHS Data Source: Claims, Registry
- Measure Type: Outcome
- Steward: Society of Interventional Radiology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: This measure is closely related to patient
survival. Data on current performance would provide a better understanding of
the opportunity for improvement. The measures are being collected in the
Society of Gynecologic Oncology Clinical Outcomes Registry.
- Public comments received: 3
Rationale for measure provided by HHS
The primary treatment for
locally advanced cervical cancer consists of external beam radiation to the
pelvis +/-para-aortic region with concurrent chemotherapy. In this patient
population, total radiation therapy treatment time beyond 7 to 9 weeks has been
shown to result in increased pelvic failure rates and decreased cancer specific
and overall survival. Pelvic failure rates were reported at 26% for women who
required greater than 56 days compared to 9% (hazard ratio 3.8; p=0.02). In an
ancillary analysis of a Gynecologic Oncology Group study (protocol 165), women
who had prolongation of radiation for any cause had a poorer progression free
survival (HR 1.98; CI 1.16-3.38) and overall survival (HR 1.88; CI 1.08-3.26)
compared to those who completed therapy within 8 weeks. Further studies have
shown that prolongation of radiation is associated with a decreased survival of
0.6% and pelvic control rates of 0.7% for each additional day beyond 55 days for
all stages of disease. More recent studies have shown that this effect remains
even in the setting of chemoradiation. References: 1. Song S, Rudra S, Hasselle
MD, et al. The effect of treatment time in locally advanced cervical cancer in
the era of concurrent chemoradiotherapy. Cancer 2013;119(2):325-331. 2. Fyles
A, Keane TJ, Barton M, Simm J. The effect of treatment duration in the local
control of cervix cancer. Radiother Oncol 1992;25(4): 273-9. 3. Nugent EK, Case
AS, Hoff JT, et al. Chemoradiation in locally advanced cervical carcinoma: an
analysis of cisplatin dosing and other clinical prognostic factors. Gynecol
Oncol 2010;116(3):438-41. 4. Monk BJ, Tian C, Rose PG, Lanciano R. Which
clinical/pathologic factors matter in the era of chemoradiation as treatment for
locally advanced cervical carcinoma? Analysis of two Gynecologic Oncology Group
(GOG) trials. Gynecol Oncol 2007;427-433. 5. Petereit DG, Sarkaria JN, Chappell
R, Fowler JF, Harmann TJ, Kinsella TJ et al . The adverse effect of treatment
prolongation in cervical carcinoma. Int J Radiation Oncology Biol Phys
1995;32(5):1301-1307. 6. Perez CA, Grigsby PW, Castro-Vita H, Lockett MA.
Carcinoma of the uterine cervix. Impact of prolongation of overall treatment
time and timing of brachytherapy on outcome of radiation therapy. Int J
Radiation Oncology Biol Phys 1995;32(5): 1275-1288.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with locally advanced cervical
cancer who complete their chemoradiation in 60 days or less
- Numerator: Numerator is the number of patients who completed
external beam radiation within 60 days from initiation for locally advanced
cervical cancer with curative intent
- Denominator: Denominator is the number of women being treated with
chemoradiation for locally advanced cervical cancer (ICD-9 180.9; ICD-10
C53.9) Radiation therapy CPT codes 77301, 77338, 77300, 77386, 77295, 77300,
77334, 77412
- Exclusions: Women who not being treated with curative intent
Exceptions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry, Survey
- Measure Type: Process
- Steward: Society of Gynecologic Oncology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: More than 40,000 corneal transplants or grafts
are performed each year in the US. MAP encourages development of outcome
measures for vision -good vision after any eye procedure is the goal for
patients and providers. Data on current performance would provide better
understanding on the opportunity for improvement.
- Public comments received: 7
Rationale for measure provided by HHS
Improved visual acuity is a
desired surgical goal to improve patient's daily activities of daily living and
quality of life
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of corneal graft surgery patients with a
visual acuity of 20/40 or better within 90 days following surgery
- Numerator: Visual acuity of 20/40 of better achieved within 90 days
following corneal graft surgery
- Denominator: Patients aged 18 years or older who underwent a
corneal graft procedure with one of the following indications for surgery:
endothelial dystrophy, post cataract surgery edema, failed corneal graft,
ectatic disease, anterior/stromal dystrophy, or corneal opacity
- Exclusions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Outcome
- Steward: American Academy of Ophthalmology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Macular edema in common in diabetes. The
lifetime risk for diabetics to develop macular edema is about 10%. The
condition is closely associated with the degree of diabetic retinopathy
(retinal disease). The standard of treatment for diabetic macular edema is
glycemic control, optimal blood pressure control, and macular focal/grid laser
photocoagulation. New treatments with steroids and anti-VEGF agents are
available. Optimal treatment can reduce the risk of vision loss and associated
functional limitations in patients with diabetes. MAP encourages continued
developed of this outcome measure for a large population at risk of vision
loss. Vision loss associated with diabetes can be reduced with good diabetes
care. Care coordination among primary and eye care providers is essential to
maintain vision.
- Public comments received: 7
Rationale for measure provided by HHS
Maintenance of visual acuity
is a desired treatment goal to continue the level of the patient's daily
activities of daily living and quality of life
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with a diagnosis of diabetic
macular edema with a loss of less than 0.3 logMar of visual acuity within the
past 12 months
- Numerator: Patients who achieved a loss a loss in visual acuity of
= 0.3 logMar
- Denominator: Patients aged 18 years or older with a diagnosis of
diabetic macular edema who received anti-VEGF injections, intravitreal
injections, or laser photocoagulation therapy
- Exclusions: Denominator Exclusions: Patients with ophthalmic
complications of diabetic retinopathy including neovascular glaucoma, traction
retinal detachment, vitreous hemorrhage, history of vitreous surgery, history
of retinal surgery, development of retinopathy in the fellow eye Exceptions:
None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Outcome
- Steward: American Academy of Ophthalmology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: This measure uses chart review or entry into
the PFD Registry. Encourage further specification to require documentation of
the duration and results of attempted conservative therapy. Strongly consider
developing a patient-reported outcome for fecal incontinence surgery. MAP
encourages the developers to do some work on a functional status assessment or
on a patient reported outcome with some shared decision making based on the
evidence along with the documentation of conservative therapy as appropriate
--that would be very valuable for patients.
- Public comments received: 5
Rationale for measure provided by HHS
This measure is intended to
ensure that patients are offered the opportunity to pursue conservative
management prior to surgery. The pathophysiological mechanisms responsible for
FI include diarrhea, anal and pelvic floor weakness, reduced rectal compliance,
and reduced or increased rectal sensation. Conservative medical management
consisting of patient education, fiber supplements or antidiarrheals, behavioral
techniques such as scheduled toileting, and pelvic floor exercises restores
continence in up to 25% of patients. Biofeedback is associated with satisfaction
rates of up to 76%, and continence in 55%. Patient education on all the
treatment options can help with patient satisfaction and better outcomes as they
still can be used as adjunct therapies to surgery. Treatment of fecal
incontinence: state of the science summary for the National Institute of
Diabetes and Digestive and Kidney Diseases workshop. Whitehead WE, Rao SS,
Lowry A, Nagle D, Varma M, Bitar KN, Bharucha AE, Hamilton FA. Am J
Gastroenterol. 2015 Jan;110(1):138-46; quiz 147. doi: 10.1038/ajg.2014.303. Epub
2014 Oct 21. Epidemiology, pathophysiology, and classification of fecal
incontinence: state of the science summary for the National Institute of
Diabetes and Digestive and Kidney Diseases (NIDDK) workshop. Bharucha AE,
Dunivan G, Goode PS, Lukacz ES, Markland AD, Matthews CA, Mott L, Rogers RG,
Zinsmeister AR, Whitehead WE, Rao SS, Hamilton FA. Am J Gastroenterol. 2015
Jan;110(1):127-36. doi: 10.1038/ajg.2014.396. Epub 2014 Dec 23.
Measure Specifications
- NQF Number (if applicable):
- Description: The percentage of patients who have been offered
non-surgical treatment of fecal incontinence prior to surgical
intervention
- Numerator: Number of patients who have been offered conservative
management for fecal incontinence prior to surgical intervention. These would
be identified by chart review or entry into the PFD Registry. Therapies
meeting the criteria for conservative management would include high fiber
diet, bulking agents, anti-diarrheal medications for patients with diarrhea,
scheduled toileting, Kegel exercises, biofeedback, pelvic floor physical
therapy, and fecal disimpaction in patients who are constipated.
- Denominator: The number of patients undergoing surgery for the
indication of fecal incontinence will be included. Fecal incontinence
surgeries will include the following CPT codes: ICD9 0377T anal bulking
injection; 46750 for overlapping anal sphincteroplasty, 46761 (anal
sphincteroplasty with levator plication), 46762 (ICD10 0DHQ0LZ-0DHQ4LZ) for
implantation of artificial anal sphincter, and 64561, 64581, 64590, 77002 for
sacral neuromodulation and fecal incontinence will be defined by the following
ICD-9/ICD-10 codes: ICD9: 787.60 (full incontinence of feces), 787.62 (fecal
smearing), 787.63 (fecal urgency); ICD10: R15.9 (anal sphincter, fecal
incontinence); R15.1 (fecal smearing); R15.2 (fecal urgency)
- Exclusions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: American Urogynecologic Society
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: This measure uses chart review or entry into
the PFD Registry. Encourage further specification to require documentation of
the duration and results of attempted conservative therapy. Strongly consider
developing a patient-reported outcome for urgency incontinence surgery. MAP
encourages the developers to do some work on a functional status assessment or
on a patient reported outcome with some shared decision making based on the
evidence along with the documentation of conservative therapy as appropriate
--that would be very valuable for patients.
- Public comments received: 6
Rationale for measure provided by HHS
Urge urinary incontinence
negatively impacts patients' quality of life, as patients may limit activities
outside the home, socializing, and sexual activity due to the fear of leaking.
Current guidelines issued by the American Urologic Association state that
behavioral therapies (e.g., bladder training, bladder control strategies, pelvic
floor muscle training, fluid management) should be first line therapy.
Clinicians should offer oral anti-muscarinics or oral beta 3-adrenoceptor
agonists as second-line therapy. Third line therapies include intradetrusor
Botox injections, peripheral tibial nerve stimulation, or sacral
neuromodulation. Website reference:
https://www.auanet.org/education/guidelines/overactive-bladder.cfm
Measure Specifications
- NQF Number (if applicable):
- Description: The percentage of patients who have been offered
non-surgical treatment of urgency urinary incontinence prior to surgical
intervention
- Numerator: Number of patients that who have been offered
conservative management for urgency urinary incontinence prior to surgical
intervention. These would be identified by chart review or entry into the PFD
Registry. Therapies meeting the criteria for conservative management include
would include: behavioral modifications (avoiding bladder irritants, excessive
fluid intake), Kegel exercises, pelvic floor physical therapy; pharmacologic
management.
- Denominator: The number of patients undergoing surgery for the
indication of urgency urinary incontinence will be included. Urgency
incontinence surgeries will include the following CPT codes: ICD9 64566 for
posterior tibial nerve stimulation; 64561, 64581, 64590, 77002 for sacral
neuromodulation; 52287 chemodenervation-intradetrusor botulinum injections.
Urgency incontinence will be defined by the following ICD-9/ICD-10 codes:
ICD9: 788.31 (urge incontinence), 788.63 (urinary urgency), 788.41 (urinary
frequency), 788.43 (nocturia), 788.33 (mixed urinary incontinence) 788.34
(incontinence without sensory awareness), 788.36 (nocturnal enuresis), 788.37
(continuous leakage), 788.38 (overflow incontinence), 788.39 (other
incontinence), 596.59 (detrusor overactivity), 596.54 (neurogenic bladder),
596.51 (overactive bladder). ICD10: N32.81 (overactive bladder), N32.89 (other
specified disorders of bladder), N32.9 (other unspecified disorder of
bladder), N39.41 (urge incontinence), N39.42 (incontinence w/o sensory
awareness), N39.45 (continuous leakage), N39.44 (nocturnal enuresis), N39.46
(mixed incontinence), N39.490(other specified urinary incontinence - reflex or
total), N39.498 (total incontinence), R32 (enuresis NOS), R39.81 (urinary
incontinence associated with cognitive impairment), R39.81 (functional urinary
incontinence)
- Exclusions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: American Urogynecologic Society
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Uterine artery embolization (UAE) is an
alternative treatment for women with symptomatic fibroids of the uterus. Since
the purpose of the procedure is to reduce symptoms, the patient is in the best
position to know whether the treatment improved her symptoms or not. Aggregate
data from the literature reports that 80-85% of women report improvement in
their symptoms. UAE avoids the risks of major surgery (hysterectomy) though
the costs are similar. 20% of patients require additional treatment after UAE.
If UAE is promoted as a less invasive, safer treatment than traditional
surgery, it is important to know that the results for patients are good. MAP
encourages continued development of this patient-reported outcome measure that
provides the patient perspective on the outcome of this procedure for a common
condition -- uterine fibroids. This measure is also valuable for public
reporting to patients and consumers. It is unclear how the results of the
would be submitted to MIPS. The developer reported that individuals who would
want to use the survey for the purposes of quality reporting would have access
to it free of charge.
- Public comments received: 2
Rationale for measure provided by HHS
Uterine artery embolization
is a well-established procedure for the treatment of symptomatic uterine
fibroids, with reported success rates of 85% in patients with isolated uterine
fibroids as the etiology of their symptoms. Although there are a variety of
techniques that are used clinically, such variance has little impact on the
overall patient outcome. The development of uterine fibroid disease specific
surveys, such as the Uterine Fibroid Symptom Health-related Quality of Life
Questionnaire (UFS-QOL) has enabled robust reporting of patient-reported
outcomes for this disease (http://www.sirfoundation.org/registries/).
Importantly, this survey enables assessment both of the patient's subjective
symptoms as well as their experience. The routine use of this survey instrument
would objectively assess the procedural efficacy at the patient level.
Measure Specifications
- NQF Number (if applicable):
- Description: The percentage of patients who demonstrate an
improvement in their symptoms following uterine fibroids embolization as
assessed using a disease-specific survey administered before and 6 months
after the procedure
- Numerator: Number of patients who report symptomatic improvement
following uterine artery embolization performed for treatment of fibroids
using a disease-specific survey instrument
- Denominator: All patients referred for uterine artery embolization
who completed a disease specific survey instrument at baseline and 6 months
following the procedure.
- Exclusions: Exclusions: Patients with incomplete survey data
Exceptions: Patients with suspected adenomyosis
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Survey
- Measure Type: Patient Reported Outcome
- Steward: Society of Interventional Radiology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: There is an estimated 1.75 million cases of
advanced AMD in the US. AMD is the leading cause of irreversible visual loss
in the United States, with variable degrees of age-related macular changes
occurring in more than 10% of the population aged 65-74 years and 25% of the
population older than 74 years. MAP encourages continued development of this
outcome measure for a topic with only process measures currently. Since AMD is
a slowly progressive condition, it is unclear whether this outcome measure is
a function of the natural progression of the disease and to what extent
clinical management will influence the outcome.
- Public comments received: 7
Rationale for measure provided by HHS
Maintenance of visual acuity
is a desired treatment goal to continue the level of the patient's daily
activities of daily living and quality of life
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with a diagnosis of exudative
age-related macular degeneration, being treated with anti-VEGF agents, with a
loss of less than 0.3 logMar of visual acuity within the past 12
months
- Numerator: Patients who achieved a lost in visual acuity of = 0.3
logMar
- Denominator: Patients aged 18 years or older with a diagnosis of
exudative age-related macular degeneration being treated with anti-vegf
agents
- Exclusions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Outcome
- Steward: American Academy of Ophthalmology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: There are approximately 4 million Americans
with glaucoma – 200,000 are severely visually impaired. Reduction of
intraocular pressure (IOP) has been shown to effectively reduce the risk of
glaucoma progression. American Association of Ophthalmology guidelines
recommend “The goal of glaucoma treatment is to maintain the IOP in a range at
which a patient is likely to remain stable or at which worsening of glaucoma
will be slow enough that the risk of additional intervention is not justified.
The target pressure should be individualized and may need adjustment during
the course of the disease.” MAP encourages continued development of this
intermediate outcome measure that is very similar to PQRS # 141 Primary
Open-Angle Glaucoma (POAG): Reduction of Intraocular Pressure (IOP) by 15% OR
Documentation of a Plan of Care. This new measure might be an improvement on
PQRS #141 because it differentiates the outcome threshold based on severity of
disease and does not have the plan of care component. No information regarding
the targets specified in this measure could be identified nor evidence that
these targets are related to specific outcomes.
- Public comments received: 7
Rationale for measure provided by HHS
Intraocular pressure is the
only modifiable risk factor so control of IOP is relevant to clinical outcome
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of glaucoma patients where their
intraocular pressure (IOP) was below a threshold level based on the severity
of their condition
- Numerator: Patient visits where the eye(s) intraocular pressure
(IOP) was below a specified threshold based on the severity of their glaucoma.
- Mild stage glaucoma: IOP <= 22mm HG - Moderate stage glaucoma: IOP
<= 18 mm HG - Severe stage: IOP <= 15 mm HG
- Denominator: Patients aged between 40 and 85 years, with a minimum
of 4 office visits during the prior 24 months, with a diagnosis of glaucoma
and with documentation of the severity of their condition.
- Exclusions: Denominator Exclusions: Patients with a diagnosis of
low tension glaucoma OR Eyes with a documented severity of indeterminate
stage OR Eyes with absolute glaucoma blindness OR Patients who had glaucoma
incisional surgery performed within the last 90 days OR Patients with visual
acuity findings of count fingers, hand motion, light perception or no light
perception Exclusions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Outcome
- Steward: American Academy of Ophthalmology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Surgery is used when medications fail to
control vision loss caused by glaucoma. MAP encourages continued development
of this additional outcome measure for patients undergoing laser surgery for
glaucoma. The most common complication from laser surgery for glaucoma is
increased pressure within the eye that may rise sharply 1-4 months after
surgery. The measure does not specify a timeframe for measuring the IOP after
surgery– if performed too soon the measure may not capture increased pressures
that occur several months after surgery and would over estimate good
outcomes.
- Public comments received: 7
Rationale for measure provided by HHS
Intraocular pressure is the
only modifiable risk factor so control of IOP is relevant to clinical outcome
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of who underwent laser trabeculoplasty who
had IOP reduced by 20% from their pretreatment level.
- Numerator: Patients eyes with a reduction in intraocular pressure =
20% from their pretreatment level
- Denominator: Patients aged between 40 and 85 years who underwent
laser trabeculoplasty
- Exclusions: Denominator Exclusions: Eyes with absolute glaucoma
blindness OR Patients with visual acuity findings of count fingers, hand
motion, light perception or no light perception Exceptions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Outcome
- Steward: American Academy of Ophthalmology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: The ACIP recommends Hepatitis A vaccination:
"Although not at increased risk for Hep A infection, persons with chronic
liver disease are at increased risk for fulminant hepatitis A. Death
certificate data indicate a higher prevalence of chronic liver disease among
persons who died of fulminant hepatitis A compared with persons who died of
other causes. Vaccination against viral hepatitis for patients with cirrhosis
can improve long term clinical outcomes. (ACIP 2014)MAP encouraged continued
development of this measure but strongly recommends this measure be fully
harmonized with PQRS#183/NQF#0399 Hepatitis C: Hepatitis vaccination or better
yet, consolidate both into a single vaccination measure for patients with
chronic liver disease as recommended by ACIP. The measure is duals sensitive.
The registry is not specified. Data on current performance would provide a
better understanding of the gap in care. Public comments on this measure were
mixed with some strongly supporting and other not.
- Public comments received: 9
Rationale for measure provided by HHS
Vaccination against viral
hepatitis for patients with cirrhosis can improve long term clinical outcomes.
(Advisory Committee on Immunization Practices 2014)
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with diagnosis of cirrhosis
that have documented hepatitis A vaccination
- Numerator: Patients with diagnosis of cirrhosis who have had a
hepatitis A vaccination during or prior to the measurement period
- Denominator: All patients with diagnosis of cirrhosis
- Exclusions: Exclusions: none Exceptions: Patient declined
Hepatitis A vaccine or contraindicated
- HHS NQS Priority: Best Practice of Healthy Living
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Eugene Gastroenterology Consultants, PC Oregon Endoscopy
Center, LLC
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: CDC recommends that all patients with chronic
liver disease are vaccinated for hepatitis B. MAP encourages continued
development with strong consideration to consolidating this measure as
Hepatitis B vaccination for all patients with chronic liver disease, including
hepatitis C as recommended by CDC, i.e., combine this measure with the MUC for
Hepatitis B vaccination for patients with cirrhosis. Importantly, the
specifications should specify that all doses of the vaccine should be given to
get credit for this measure. This measure is duals sensitive. Data on current
performance would provide better understanding of the gap in care. The
registry is not specified. Public comments on this measure were mixed with
some strongly supporting and other not.
- Public comments received: 7
Rationale for measure provided by HHS
Vaccination against viral
hepatitis for patients with chronic hepatitis C can improve long term clinical
outcomes
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with diagnosis of chronic
Hepatitis C that have documented hepatitis B vaccination
- Numerator: Patients with diagnosis of chronic Hepatitis C who have
had a hepatitis B vaccination during or prior to the measurement
period
- Denominator: All patients with diagnosis of chronic Hepatitis
C
- Exclusions: Exclusions: none Exceptions: Patient declined
Hepatitis B vaccine or contraindicated
- HHS NQS Priority: Best Practice of Healthy Living
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Eugene Gastroenterology Consultants, PC Oregon Endoscopy
Center, LLC
- Endorsement Status: A similar measure was not endorsed by NQF
because it specified only receipt of the first dose of vaccine which is not
thought to be adequate for protection.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: The CDC recommendation for Hepatitis B
vaccination includes persons with chronic liver disease as a preventive health
measure. MAP encourages continued development of this measures with strong
consideration to focusing this measure on patients with chronic liver
disease, including Hepatitis C, rather than multiple measures. The measure is
duals sensitive. The registry is not specified. Data on current performance
would provide a better understanding of the gap in care. Public comments on
this measure were mixed with some strongly supporting and other
not.
- Public comments received: 8
Rationale for measure provided by HHS
Vaccination against viral
hepatitis for patients with cirrhosis can improve long term clinical outcomes.
(Advisory Committee on Immunization Practices 2014)
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with diagnosis of cirrhosis
that have documented hepatitis B vaccination
- Numerator: Patients with diagnosis of cirrhosis who have had a
hepatitis B vaccination during or prior to the measurement period
- Denominator: All patients with diagnosis of cirrhosis
- Exclusions: Exclusions: none Exceptions: Patient declined
Hepatitis B vaccine or contraindicated
- HHS NQS Priority: Best Practice of Healthy Living
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Eugene Gastroenterology Consultants, PC Oregon Endoscopy
Center, LLC
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: This is an intermediate outcome that reflects
the treatment for Hepatitis C. Recent studies report that combining several
oral antivirals—drugs taken in pill form, not as injections—clear the virus
from the liver in more than 95% of people in just 12 weeks. The new
medications are very expensive though cost-effectiveness studies conclude that
treatment is cost-effective in most patients. This measure only captures
patients that begin treatment – patient that cannot afford the medications are
not included. This is an intermediate outcome measure related to process
measure PQRS#087/NQF #0398 Hepatitis C: Hepatitis C Virus (HCV) Ribonucleic
Acid (RNA) Testing Between 4-12 Weeks After Initiation of Treatment. MAP
encourages continued development but noted that data on current performance
would provide a better understanding of gap in care. Public comments on this
measure were mixed with some strongly supporting and other not.
- Public comments received: 8
Rationale for measure provided by HHS
Achieving SVR is the first
step toward reducing future HCV morbidity and mortality. Once achieved, an SVR
is associated with long-term clearance of HCV infection, which is regarded as a
virologic ‘‘cure,’’ as well as with improved morbidity and mortality. Patients
who achieve an SVR usually have improvement in liver histology and clinical
outcomes. Nineteen cohort studies (n=105 to 16,864) evaluated the association
between SVR after antiviral therapy and mortality or complications of chronic
HCV infection. Duration of follow-up ranged from 3 to 9 years. Ten studies were
conducted in Asia (60, 67-72, 75, 77, 78). Eight (64-66, 72, 75-78) were rated
as poor-quality and the remainder as fair quality. Although all studies reported
adjusted risk estimates, only 8 (60, 61, 63, 67-70, 73) evaluated 5 key
confounders (age, sex, genotype, viral load, and fibrosis stage). No study
clearly described assessment of outcomes blinded to SVR status. The largest
study (n=16,864) had the fewest methodological shortcomings (61). It adjusted
for multiple potential confounders, including age, sex viral load, presence of
cirrhosis, multiple comorbid conditions, aminotransferase levels, and others. It
also stratified results by genotype. In a predominantly male, Veterans Affairs
population, SVR after antiviral therapy was associated with lower risk for
all-cause mortality than was SVR , after median of 3.8 years (adjusted hazard
ration, 0.71 [CI, 0.60 to 0.861], 0.62[CI, 0.44 to 0.87], and 0.51 [CI, 0.35 to
0.75] for genotypes 1, 2, and 3 respectively). Mortality curves began to
separate as soon as 3 to 6 months after SVR assessment. Eighteen other cohort
studies also found SVR to be associated with decreased risk for all-cause
mortality (adjusted hazard rations, 0.07 to 0.39)(60, 69, 72, 73, 75-78),
liver-related mortality (adjusted hazard rations, 0.12 to 0.46)(60, 62, 63, 67,
68, 71, 73-76, 78), and other complications of end-stage liver disease versus no
SVR, with effects larger than in the Veterans Affairs study. The subgroup of
studies that focused on patients with advanced fibrosis or cirrhosis at baseline
(60, 67-72, 75, 77, 78) reported similar risk estimates. (Chou et. al., 2015)
Chou R, Hartung D, Rahman B, Wasson N, Cottrell EB, Fu R. Comparative
effectiveness of antiviral treatment for hepatitis C virus infection in adults:
a systematic review. Ann Intern Med. 2013 Jan 15;158(2):114-23. Review. PubMed
PMID: 23437439
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of Patients aged 18 years and older with a
diagnosis of hepatitis C who have completed a full course of antiviral
treatment with undetectable hepatitis C virus (HCV) ribonucleic acid (RNA) 11
weeks after cessation of treatment.
- Numerator: Patients with undetectable HCV RNA 11 weeks after
cessation of treatment
- Denominator: All patients aged 18 years and older with a diagnosis
of hepatitis C who are initiating or receiving antiviral treatment during the
measurement period
- Exclusions: Measure only needs to be reported if initiation of
antiviral treatment took place before October of the measurement year (11
weeks before the end of the measurement period)
- HHS NQS Priority: Best Practice of Healthy Living
- HHS Data Source: Registry
- Measure Type: Outcome
- Steward: American Gastroenterological Association
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: CDC emphasizes the need for HIV testing for
people with STIs as they are considered at higher risk for acquiring HIV. The
USPSTF includes persons with STIs among those high risk persons who require
more frequent testing than the one time testing recommended for the general
population This measure addresses public health and prevention and is an
eMeasure. In 2015 MAP encouraged further development of this measure that is
currently in field testing. MAP reiterates its encouragement for continued
development of this measure. Patient confidentiality must be considered as a
spouse, adult child or adolescent on the family insurance may not want to have
HIV testing on the insurance billing and may opt to have the HIV test
elsewhere.
- Public comments received: 5
Rationale for measure provided by HHS
Persons with STIs are a
subgroup of the population at increased risk for HIV. CDC recommends HIV testing
of persons seeking evaluation for STI during each visit for a new STI complaint.
The U.S. Preventive Services Task Force (USPSTF) includes persons with STIs
among those high risk persons who require more frequent testing than the one
time testing recommended for the general population (rated “A”). The evidence
underlying the USPSTF recommendation is summarized in: Virginia A. Moyer, MD,
MPH, on behalf of the U.S. Preventive Services Task Force* Screening for HIV:
U.S. Preventive Services Task Force Recommendation Statement. Annals Internal
Medicine 2013. Published at www.annals.org (accessed July 1, 2013) Notably, the
current USPSTF recommendation extends the earlier recommendation for testing of
persons at increased risk for HIV, including persons being treated for STDs
(U.S. Preventive Services Task Force. Screening for HIV: Recommendation
Statement. American Family Physician 2005; 72:2287-2292.), and reiterates the
need for more frequent testing of persons at increased risk, including persons
who have acquired STIs or request testing for STI. CDC's newly published 2015
STD Treatment Guidelines also underscore the need for HIV testing in the context
of certain STD diagnoses, noting that: “Persons at high risk for HIV infection
with early syphilis, gonorrhea, or chlamydia should be screened at the time of
the STD diagnosis, even if an HIV test was recently performed. Some STDs,
especially rectal gonorrhea and syphilis, are a risk marker for HIV
acquisition." Relevant references supporting the 2015 STD Treatment Guidelines
include: • Zetola NM, Bernstein KT, Wong E, et al. Exploring the relationship
between sexually transmitted diseases and HIV acquisition by using different
study designs. J Acquir Immune Defic Syndr 2009;50:546–51. • Pathela P,
Braunstein SL, Blank S, et al. HIV incidence among men with and those without
sexually transmitted rectal infections: estimates from matching against an HIV
case registry. Clin Infect Dis 2013;57:1203–9. • Peterman TA, Newman DR, Maddox
L, Schmitt K, Shiver S. Risk for HIV following a diagnosis of syphilis,
gonorrhoea or chlamydia: 328,456 women in Florida, 2000-2011. Int J STD AIDS.
2015 Feb;26(2):113-9. doi: 10.1177/0956462414531243. Epub 2014 Apr 8. • Taylor
MM, Newman DR, Gonzalez J, Skinner J, Khurana R, Mickey T. HIV status and viral
loads among men testing positive for rectal gonorrhoea and chlamydia, Maricopa
County, Arizona, USA, 2011-2013. HIV Med. 2015 Apr;16(4):249-54. doi:
10.1111/hiv.12192. Epub 2014 Sep 17
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients diagnosed with an acute STD
indicative of elevated risk for HIV exposure who were tested for
HIV
- Numerator: Patients with an HIV test during period extending from
30 days before STD diagnosis to 30 days after STD diagnosis
- Denominator: Patients diagnosed with an acute STD during the one
year period ending 30 days prior to the end of the measurement year. STDs
include: syphilis and gonorrhea
- Exclusions: Denominator Exclusions: Patients who have HIV
infection.
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Measure designed so that all relevant data should
be available/abstractable from EHR
- Measure Type: Process
- Steward: Centers for Disease Control and Prevention
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
Yes
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: The post-thrombotic syndrome (PTS) is a
frequent and important complication of deep venous thrombosis (DVT) with as
many as two-thirds of patients developing symptoms of pain, edema,
hyperpigmentation, or ulceration. Venous stenting has become the treatment of
choice with significant reduction in swelling, pain, ulcer healing and quality
of life. At least two instruments are available to assess PTS (Villalta and
Venous Clinical Severity Score). MAP encourages continued development of this
measure as a clinical, objective assessment of the outcome of the procedure.
MAP encourages combining this measure with MUC15-411 the patient reported
outcome measure for a robust composite outcome.
- Public comments received: 2
Rationale for measure provided by HHS
The venous clinical severity
score replace the older CEAP (clinical grade, etiology, anatomy,
pathophysiology) grading system to assess the severity of chronic venous
disease. Unlike the CEAP system, the venous clinical severity score is more
useful in the assessment of changes in venous disease and thus is most
appropriate to apply to patients undergoing treatment to assess outcomes from
therapy, such as ilio-femoral venous stenting. This measure addresses a
measurement gap across multiple programs. By encouraging the routine use of the
venous clinical severity score centers will be able to objectively assess the
intermediate outcome of venous stenting on the symptoms and signs of chronic
venous disease. This score focuses more on the clinical signs, rather than
patient symptoms, which was demonstrated to be a more useful marker for subtle
changes in the severity of venous disease.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients who demonstrate improvement in
the Venous Clinical Severity Score after ilio-femoral venous
stenting
- Numerator: The number of patients who demonstrate improvement in
the venous clinical severity score following ilio-femoral venous stenting as
assessed 3-6 months post-procedure
- Denominator: The total number of patients who underwent
ilio-femoral venous stenting with application of the venous clinical severity
both at baseline and at 3-6 months post-procedure.
- Exclusions: Patients with history of lower extremity or pelvic vein
surgery. Exceptions: Patients with a history of pelvic or lower extremity
orthopedic surgery. Patients with debilitating osteoarthritis involving the
hips, knees, or ankles.
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Intermediate Outcome
- Steward: Society of Interventional Radiology
- Endorsement Status: Endorsed
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP questioned whether the specific time frame
is appropriate for measurement - does it really make a different if it is 42
versus 43 or 44 days? There is no information that there is an opportunity for
improvement. MAP also asked whether this is standard pf care and little
opportunity for improvement. The measures are being collected in the Society
of Gynecologic Oncology Clinical Outcomes Registry. No data on current
performance is available. MAP encouraged continued development of the measure
pending data from testing that confirms a gap in care exists. The impact of
the measure is limited if current performance is very high.
- Public comments received: 3
Rationale for measure provided by HHS
Starting the chemotherapy
within 42 days (6 weeks) from surgery is consistent with the previous GOG
(Gynecologic Oncology Group) randomized trials that utilized this timeline as a
standard. The most important of those trials is GOG-158 (Ozols RF, Bundy BN,
Greer BE, Fowler JM, Clarke-Pearson D, Burger RA, et al. Phase III trial of
carboplatin and paclitaxel compared with cisplatin and paclitaxel in patients
with optimally resected stage III ovarian cancer: a Gynecologic Oncology Group
study. Journal of clinical oncology : official journal of the American Society
of Clinical Oncology. 2003;21:3194-200. PMID= 12860964) Although there is no
randomized trial to accurately quantify the importance of initiating
chemotherapy within 42 days from the debulking surgery, but analysis of patient
data from the prospective OVCAR study suggested that delaying chemotherapy is
associated with poorer survival, albeit it is only for overall survival in a
subooptimally debulked ovarian cancer (Hofstetter G, Concin N, Braicu I,
Chekerov R, Sehouli J, Cadron I, et al. The time interval from surgery to start
of chemotherapy significantly impacts prognosis in patients with advanced serous
ovarian carcinoma - analysis of patient data in the prospective OVCAD study.
Gynecologic oncology. 2013;131:15-20. PMID= 23877013). A second study presented
at the SGO 2013 by Eskander, R et al was a Gynecologic Oncology Group ancillary
data study. This study showed a negative survival impact associated with >25
day interval from surgical cytoreduction to initiation of systemic therapy in
advanced ovarian carcinoma. The largest study come some from Colorectal
literature when a metaanalysis of more than 15,000 patients, showed that a delay
of initiation of chemotherapy past 4 weeks after surgery is positively
correlated to a worse survival (Biagi JJ, Raphael MJ, Mackillop WJ, Kong W, King
WD, Booth CM. Association between time to initiation of adjuvant chemotherapy
and survival in colorectal cancer: a systematic review and meta-analysis. JAMA.
2011;305:2335-42. PMID=21642686). IP chemotherapy provides a superior OS in
patients after optimal cytoreductive surgery (Walker JL, Armstrong DK, Huang HQ,
Fowler J, Webster K, Burger RA, et al. Intraperitoneal catheter outcomes in a
phase III trial of intravenous versus intraperitoneal chemotherapy in optimal
stage III ovarian and primary peritoneal cancer: a Gynecologic Oncology Group
Study. Gynecologic oncology. 2006;100:27-32. PMID=16368440)
Measure Specifications
- NQF Number (if applicable):
- Description: Measuring the percentage of patient who received Intra
Peritoneal (IP) chemotherapy after the debulking of advanced epithelial
ovarian cancer
- Numerator: Patients who have Ovarian cancer / fallopian tube cancer
( ICD-9= 183.0 (Ovarian cancer) 183.2 (Fallopian tube cancer) AND received IP
chemo within 42 days from surgery
- Denominator: All patients who underwent debulking surgery for
ovarian cancer. CPT coding may vary but possibilities are: 58950 – Resection
(initial) of ovarian, tubal or primary peritoneal malignancy with bilateral
salpingo-oophorectomy and omentectomy 58951 - Resection (initial) of ovarian,
tubal or primary peritoneal malignancy with bilateral salpingo-oophorectomy
and omentectomy; with total abdominal hysterectomy, pelvic and limited
para-aortic lymphandenectomy 58952 - Resection (initial) of ovarian, tubal or
primary peritoneal malignancy with bilateral salpingo-oophorectomy and
omentectomy; with radical dissection for debulking (i.e., radical excision or
destruction, intra-abdominal or retroperitoneal tumors) 58953 – Bilateral
salpingo-oophorectomy with omentectomy, total abdominal hysterectomy and
radical dissection for debulking 58954 - Bilateral salpingo-oophorectomy with
omentectomy, total abdominal hysterectomy and radical dissection for
debulking; with pelvic lymphandenectomy and limited para-aortic
lymphadenectomy 58956 – Bilateral salpingo-oophorectomy with total
omentectomy, total abdominal hysterectomy for malignancy 58957 – Resection
(tumor debulking) of recurrent ovarian, tubal, primary peritoneal, uterine
malignancy (intra-abdominal, retroperitoneal tumors, with omentectomy, if
performed 58958 - Resection (tumor debulking) of recurrent ovarian, tubal,
primary peritoneal, uterine malignancy (intra-abdominal, retroperitoneal
tumors, with omentectomy, if performed; with pelvic lymphadenectomy and
limited para-aortic lymphadenectomy
- Exclusions: Patients who received Neoadjuvant Chemotherapy
Patients with non-epithelial cancer Patients who had the IP chemotherapy not
offered (and or to be offered IP chemotherapy after the first cycle of IV
chemotherapy) by the surgeons for any of the listed reasons: a- Those who had
bowel resection as part of their debulking surgery. b- Had multiple abdominal
surgeries that impede the futility of IP chemotherapy. c- Patients’ who have
had a sub optimal debulking d- Any other medical reason(s) that
contraindicated IP chemotherapy (e.g.: peritonitis, inflammatory bowel
disease, liver failure, renal failure. etc.) Exceptions: Patients who are
pregnant at the time of diagnosis ( ICD-9= 640.0 – 669.9 and V22.0 –
V23.9)
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Society of Gynecologic Oncology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support
- Workgroup Rationale: Composite measures of evidence-based processes
and intermediate clinical outcomes combine multiple factors important to care
and address whether a patients is receiving all the evidence-based care they
receive. Most of the atherosclerotic disease measures enjoy high performance
individually, but the composite reveals that the results are not uniformly
high for individual patients. Opportunity for improvement exists which can
further reduce the risks of poor outcomes for patients and represents a
measure that promotes high performance. CMS recently removed PQRS #349
(NQF#0076) Optimal Vascular Care - an all-or-none-composite measure - because
it is duplicative of the Millions Hearts measures. MAP supports use of both a
composite measure as well as the individual measures for the Millions Hearts
campaign. This measure, MUC15-275 is a competing measure with PQRS #349
(NQF#0076) – both are all-or-none composite measures for ischemic vascular
disease. NQF will be evaluating both measures side-by-side in the upcoming
Cardiovascular - Phase 4 project. CONDITION: MAP conditionally supports this
measure pending the outcome of the NQF evaluation of both composite measures.
MAP supports inclusion of the composite measure that is considered
best-in-class by the NQF review.
- Public comments received: 5
Rationale for measure provided by HHS
There has been important
evidence from clinical trials that further supports and broadens the merits of
risk-reduction therapies for patients with established coronary and other
atherosclerotic vascular disease, including peripheral arterial disease,
atherosclerotic aortic disease, and carotid artery disease. References: Smith SC
Jr, Benjamin EJ, Bonow RO, Braun LT, Creager MA, Franklin BA, Gibbons RJ, Grundy
SM, Hiratzka LF, Jones DW, Lloyd-Jones DM, Minissian M, Mosca L, Peterson ED,
Sacco RL, Spertus J, Stein JH, Taubert KA. AHA/ACCF secondary prevention and
risk reduction therapy for patients with coronary and other atherosclerotic
vascular disease: 2013 ACC/AHA Guideline on the Treatment of Blood Cholesterol
to Reduce : Atherosclerotic Cardiovascular Risk in Adults: A Report of the
American College of Cardiology/American Heart Association Task Force on Practice
Guidelines-
http://circ.ahajournals.org/search?tocsectionid=ACC/AHA+Prevention+Guideline&sortspec=date&submit=Submit
AHA/ACC Guidelines for Preventing Heart Attack and Death in Patients With
Atherosclerotic Cardiovascular Disease: 2001 Update
http://content.onlinejacc.org/article.aspx?articleid=1127560 The All or None
(Composite) method was chosen because of the benefits it provides to both the
patient and the practitioner. First, this methodology more closely reflects the
interests and likely desires of the patient. With the data collected in one
score patients can easily look and see how their provider group is performing on
these criteria rather than trying to make sense of multiple scores on individual
measures. Second, this method represents a systems perspective emphasizing the
importance of optimal care through a patient's entire healthcare experience.
Third, this method gives a more sensitive scale for improvement. For those
organizations scoring high marks on individual measures, the All-or-None measure
will give room for benchmarks and additional improvements to be made.
Measure Specifications
- NQF Number (if applicable):
- Description: The IVD All-or-None Measure is one outcome measure
(optimal control). The measure contains four goals. All four goals within a
measure must be reached in order to meet that measure. The numerator for the
all-or-none measure should be collected from the organization's total IVD
denominator. All-or-None Outcome Measure (Optimal Control) - Using the IVD
denominator optimal results include: Most recent blood pressure measurement is
less than 140/90 mm Hg -- And Most recent tobacco status is Tobacco Free --
And Daily Aspirin or Other Antiplatelet Unless Contraindicated -- And Statin
Use
- Numerator: Most recent BP is less than 140/90 mm Hg And Most recent
tobacco status is Tobacco Free (NOTE: If there is No Documentation of Tobacco
Status the patient is not compliant for this measure) And Daily Aspirin or
Other Antiplatelet Unless Contraindicated And Statin Use
- Denominator: Patients with CAD or a CAD Risk-Equivalent Condition
18-75 years of age and alive as of the last day of the Measurement Period. A
minimum of two CAD or CAD Risk-Equivalent Condition coded office visits OR one
Acute Coronary Event (AMI, PCI, CABG) from a hospital visit and must be seen
by a PCP / Cardiologist for two office visits in 24 months and one office
visit in 12 months.
- Exclusions: History of Gastrointestinal Bleed or Intra-cranial
Bleed or documentation of active anticoagulant use during the MP for the
Aspirin/Other Anticoagulant component (numerator) of the measure. Inpatient
Stays, Emergency Room Visits, Urgent Care Visits, and Patient Self-Reported
BP’s (Home and Health Fair BP results) for the Blood Pressure Control
component (numerator) of the composite measure.
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Composite
- Steward: Wisconsin Collaborative for Healthcare Quality
(WCHQ)
- Endorsement Status: The NQF Cardiovascular Standing Committee has
deferred endorsement recommendation on this measure until they can evaluate it
side-by-side with NQF#0076 Optinal Vascular Care.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Studies show that minimally invasive surgery
(laparoscopic or robotic-assisted hysterectomy) has no difference in survival
compared to open surgery, but patients undergoing minimally invasive surgery
had reduced length of hospital stay, lower blood loss, and improved quality of
life at 6 weeks. Measure submitter reports that data indicates variation in
performance of 50-90%. Improvement in this measure would improve the quality
of care for patients with endometrial cancer and reduce costs. This is an
surgical appropriateness measure for uterine cancer care for GYN and GYN ONC.
There are no other measures for endometrial cancer – an important condition in
the Medicare population. The measures are being collected in the Society of
Gynecologic Oncology Clinical Outcomes Registry. MAP encourages continued
development of the measure. This measures is likely to be meaningful to
patients for public reporting.
- Public comments received: 8
Rationale for measure provided by HHS
A total of 8 randomized
clinical trials investigating minimally invasive surgery compared to laparotomy
in over 3500 patients showed no difference in overall or disease free survival
(Cochrane Database Syst Rev. 2012 Sep 12;9; J Clin Oncol. 2012 Mar
1;30(7):695-700; J Clin Oncol. 2009 Nov 10;27(32):5331-6). However, patients
undergoing minimally invasive surgery (laparoscopic or robotic-assisted
hysterectomy) had reduced length of hospital stay, lower blood loss, and
improved quality of life at 6 weeks (Lancet Oncol. 2010 Aug;11(8):772-80.; J
Clin Oncol. 2009 Nov 10;27(32):5337-42). Furthermore, the rate of severe
postoperative adverse events was lower in patients undergoing minimally invasive
surgery (Cochrane Database Syst Rev. 2012 Sep 12;9). Despite these known
benefits, utilization rates of minimally invasive surgery vary from 50-90%
between surgeons and institutions (unpublished data from Nationwide inpatient
sample - delete this sentence if reference required). References: 1: Galaal K,
Bryant A, Fisher AD, Al-Khaduri M, Kew F, Lopes AD. Laparoscopy versus
laparotomy for the management of early stage endometrial cancer. Cochrane
Database Syst Rev. 2012 Sep 12;9:CD006655. doi: 10.1002/14651858.CD006655.pub2.
Review. PubMed PMID: 22972096. 2: Walker JL, Piedmonte MR, Spirtos NM, Eisenkop
SM, Schlaerth JB, Mannel RS, Barakat R, Pearl ML, Sharma SK. Recurrence and
survival after random assignment to laparoscopy versus laparotomy for
comprehensive surgical staging of uterine cancer: Gynecologic Oncology Group
LAP2 Study. J Clin Oncol. 2012 Mar 1;30(7):695-700. doi:
10.1200/JCO.2011.38.8645. Epub 2012 Jan 30. Erratum in: J Clin Oncol. 2012 May
1;30(13):1570. PubMed PMID: 22291074; PubMed Central PMCID: PMC3295548. 3:
Janda M, Gebski V, Brand A, Hogg R, Jobling TW, Land R, Manolitsas T, McCartney
A, Nascimento M, Neesham D, Nicklin JL, Oehler MK, Otton G, Perrin L, Salfinger
S, Hammond I, Leung Y, Walsh T, Sykes P, Ngan H, Garrett A, Laney M, Ng TY, Tam
K, Chan K, Wrede CD, Pather S, Simcock B, Farrell R, Obermair A. Quality of
life after total laparoscopic hysterectomy versus total abdominal hysterectomy
for stage I endometrial cancer (LACE): a randomised trial. Lancet Oncol. 2010
Aug;11(8):772-80. doi: 10.1016/S1470-2045(10)70145-5. Epub 2010 Jul 16. PubMed
PMID: 20638899. 4: Walker JL, Piedmonte MR, Spirtos NM, Eisenkop SM, Schlaerth
JB, Mannel RS, Spiegel G, Barakat R, Pearl ML, Sharma SK. Laparoscopy compared
with laparotomy for comprehensive surgical staging of uterine cancer:
Gynecologic Oncology Group Study LAP2. J Clin Oncol. 2009 Nov 10;27(32):5331-6.
doi: 10.1200/JCO.2009.22.3248. Epub 2009 Oct 5. PubMed PMID: 19805679; PubMed
Central PMCID: PMC2773219. 5: Kornblith AB, Huang HQ, Walker JL, Spirtos NM,
Rotmensch J, Cella D. Quality of life of patients with endometrial cancer
undergoing laparoscopic international federation of gynecology and obstetrics
staging compared with laparotomy: a Gynecologic Oncology Group study. J Clin
Oncol. 2009 Nov 10;27(32):5337-42. doi: 10.1200/JCO.2009.22.3529. Epub 2009 Oct
5. Erratum in: J Clin Oncol. 2010 Jun 1;28(16):2805. PubMed PMID: 19805678;
PubMed Central PMCID: PMC2773220.
Measure Specifications
- NQF Number (if applicable):
- Description: Proportion of patients who underwent minimally
invasive hysterectomy for endometrial cancer
- Numerator: Number of patients with endometrial cancer (ICD-9 codes:
182 malignant neoplasm of body of uterus; 182.0 Corpus uteri, except isthmus;
182.1 Isthmus; 182.8 Other specified sites of body of uterus) who underwent
minimally invasive hysterectomy. Minimally invasive is defined as laparoscopic
or robotic approaches (CPT codes: 58541-44, 58550, 58552-54, 58570-73) with or
without vaginal assistance (58260, 58262, 58263, 58267, 58270, 58275, 58280,
58285, 58290-94).
- Denominator: Number of patients with endometrial cancer (ICD-9
codes: 182 malignant neoplasm of body of uterus; 182.0 Corpus uteri, except
isthmus; 182.1 Isthmus; 182.8 Other specified sites of body of uterus) who
underwent hysterectomy. This includes hysterectomy via laparotomy (58150,
58152, 58180, 58200, 58210), laparoscopy, robotic, or vaginal (see CPT codes
in numerator).
- Exclusions: Patients with endometrial cancer who did not undergo
hysterectomy Exceptions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Society of Gynecologic Oncology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Corneal abrasion/injury is a common
complication of surgery involving general anesthesia. These injuries are
painful for the patient and may lead to other adverse effects, and can also
result in increased costs and length of stay. MAP encourages continued
development of this patient safety-focused outcome measure is relevant for
anesthesia providers and is not duplicative of other measures in the clinician
measure set.
- Public comments received: 5
Rationale for measure provided by HHS
Corneal abrasion/injury is
the most common ophthalmologic complication that occurs during general
anesthesia for non-ocular surgery. These injuries are painful for the patient,
and can lead to significant microbial keratitis with possibility of permanent
scarring. There is no standardized method for protecting the eyes during an
anesthetic for non-ocular surgery. Adhesive tape, individual single, sterile
packaged eye covers, small bio-occlusive dressings, used with or without eye
ointment are some of the options used. Some practitioners may simply observe
closed, non-taped eyes. The specific type of eye ointment also varies
significantly. Some ointment is made with petrolatum, some is water soluble,
with or without preservatives. If ointment is used, preservative-free eye
ointment is preferred, because preservative can cause corneal epithelial
sloughing and conjunctiva hyperemia. None of the methods described in the
literature are entirely effective at preventing corneal injury and some are
associated with unwanted side effects. It is important to know that petrolatum
is flammable and should be avoided when cautery will be used near the face.
Several large studies have demonstrated that applying these techniques while
measuring performance can lead to significant improvements in patient care.
Measuring the incidence of corneal injury will give practices the data they need
to assess performance, compare to national benchmarks, and if gaps are
identified, undertake measures to improve eye protection for patients. The net
result will be reduced corneal injuries and patient discomfort. All eye trauma
cases and all eye surgery cases will be excluded from the measure. Reporting
separately those procedures done on the face, including the ear, nose, and
mandible, will serve as stratification allowing comparison of procedures which
most anesthesiologists believe have a higher risk of corneal injury and which
also remove the eyes from the direct control of the anesthesiologist.
Measure Specifications
- NQF Number (if applicable):
- Description: The percentage of patients aged 18 years and older who
undergo anesthesia care and who did not have a new diagnosis of corneal injury
in the post-anesthesia care unit/recovery area. Anesthesia care for surgery of
the face will be reported separately from anesthesia care for other
procedures.
- Numerator: All patients who undergo anesthesia care and who do not
have a new diagnosis of corneal injury in the post-anesthesia care
unit/recovery area Definition: Corneal Injury: Includes both exposure
keratitis and corneal abrasion. For the purposes of this measure, the
distinction does not need to be made with fluorescein examination of the
cornea under ultraviolet light; however, it can be diagnosed in this manner.
Corneal injury also includes any new symptom of eye pain treated with topical
antibiotic (e.g., erythromycin) while in the post-anesthesia care
unit/recovery area. Other causes of eye pain (e.g. acute angle-closure
glaucoma) can be excluded by instilling one drop of local anesthetic (e.g.,
proparacaine) into the eye. If the pain is immediately and completely
relieved, corneal injury is confirmed and acute angle-closure glaucoma is
excluded.
- Denominator: All patients who undergo anesthesia care, except those
with pre-existing eye trauma or those patients undergoing ophthalmologic
surgery.
- Exclusions: Exclusions: none Exceptions: Patients who undergo
ophthalmologic surgery or patients with a diagnosis of either eye trauma or
corneal injury before anesthesia care.
- HHS NQS Priority: Making Care Safer
- HHS Data Source: Claims, Registry
- Measure Type: Outcome
- Steward: American Society of Anesthesiologists
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not encourage further
consideration
- Workgroup Rationale: MAP does not encourage further consideration
of this measure for accountability programs. This "behind the scenes" measure
is appropriate for quality improvement and systems improvement.
- Public comments received: 7
Rationale for measure provided by HHS
The communication between
pathologists and physicians about patient outcomes is fragmented. Effective and
timely communication through the biopsy report between the two practitioners is
essential; as delay may directly affect patient care. Furthermore, lack of
timely delivery can increase the cost of medical care and error. This measure
seeks to standardize the amount of time it takes for the pathologist to send the
final biopsy report to the biopsying physician to ensure timely communication
and effective treatment for the patient.
Measure Specifications
- NQF Number (if applicable):
- Description: Length of time taken from when the pathologist
completes the final biopsy report to when s/he sends the final report to the
biopsying physician. This measure evaluates the reporting time between
pathologist and biopsying clinician.
- Numerator: Number of final pathology reports diagnosing cutaneous
basal cell carcinoma or squamous cell carcinoma (to include in situ disease)
sent from the Pathologist/Dermatopathologist to the biopsying clinician for
review within 5 business days from the time when the tissue specimen was
received by the pathologist.
- Denominator: All pathology reports generated by the
Pathologist/Dermatopathologist consistent with cutaneous basal cell carcinoma
or squamous cell carcinoma (to include in situ disease).
- Exclusions: Pathologists/Dermatopathologists providing a second
opinion on a biopsy.
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: American Academy of Dermatology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Non-exudative AMD comprises more than 90% of
patients with AMD and generally has a much slower (over decades), progressive
visual loss relative to exudative (wet) AMD). There is currently no cure for
AMD, but treatments may prevent severe vision loss or slow the progression of
the disease considerably. Not all patients with AMD are candidates for use of
the AREDS vitamin formulation. Taking the AREDS vitamins was shown to reduce
the risk of advanced AMD by 25%. MAP encourages continued development of this
outcome measure for a condition that only has process measures. It is unclear
whether the degree of vision change quantified in this measure will reflect
the natural slow progression of the disease or the impact of optimal treatment
to slow down disease progression.
- Public comments received: 7
Rationale for measure provided by HHS
Maintenance of visual acuity
is a desired treatment goal to continue the level of the patient's daily
activities of daily living and quality of life
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with a diagnosis of
nonexudative age-related macular degeneration and taking AREDS supplements
with a visual acuity loss of less than 0.3 logMar within the past 12
months
- Numerator: Patients who achieved a loss a loss in visual acuity of
= 0.3 logMar
- Denominator: Patients aged 18 years or older with a diagnosis of
nonexudative AMD and taking AREDS supplements
- Exclusions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Outcome
- Steward: American Academy of Ophthalmology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Patients should expect a timely report on the
results of any biopsy - fear of the unknown takes a tremendous toll on
patients waiting for results. According to cancer.org pathology reports are
currently received by the biopsying clinician within 10 days after the biopsy
is performed and even longer for the clinician to share the results with the
patient. Effective and timely communication between the clinician and patient
is essential to ensuring safe and effective patient care along with reducing
cost. MAP encourages continued development of this measure and testing should
provide data on current performance for a better understanding of the gap in
care. The registry is the AAD’s clinical data registry called DataDerm that
will be launched January 2016. The measure specifications indicate the modes
of communication that count in the measure. MAP supports publishing this
communication measure on the clinician web page.
MAP recommends that
this patient-centered communication measure should not be limited to skin
cancer biopsies - timely reporting of results to patients is important for all
critical tests, imaging, pathology, etc. MAP acknowledged that there are some
biopsies or other tests that require more time for additional tests or
analyses such the time frame may be longer. MAP also suggests that measuring
accuracy of the reports is also important to avoid encouraging dissemination
of the wrong information quickly. MAP would like to see a patient-centered
measure that asks the patient "Did you receive all your relevant results in a
timely manner?" One measure could incentivize the system to
- Public comments received: 4
Rationale for measure provided by HHS
Effective and timely
communication between the physician and patient about biopsy results is
essential; as delay may directly affect patient care. Furthermore, lack of
timely delivery can negatively affect patient experience and satisfaction by
increasing the anxiety the patient experiences while waiting for results. This
measure seeks to standardize the amount of time it takes for the clinician to
notify patients of the final biopsy results, to ensure timely communication and
effective treatment for the patient.
Measure Specifications
- NQF Number (if applicable):
- Description: Length of time taken from when a biopsy is performed
to when a patient is notified by the biopsying physician that he or she has
cutaneous basal or squamous cell carcinoma (including in situ disease). This
measure evaluates the reporting time between the biopsying clinician and
patient.
- Numerator: Number of cutaneous biopsies by the clinician consistent
with basal cell carcinoma or squamous cell carcinoma (to include in situ
disease) for which the patient was notified of their final biopsy pathology
findings within 15 business days from the time when the biopsy was performed.
Distinct dates of service resulting in an eligible patient procedure should be
reported separately.
- Denominator: All cutaneous biopsies by the clinician consistent
with cutaneous basal or squamous cell carcinoma (including in situ
disease).
- Exclusions: Pathology reports for tissue specimens produced from
excision.
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: American Academy of Dermatology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not encourage further
consideration
- Workgroup Rationale: MAP held extensive discussion on this measure
which is intended to reduce the use of prostate-specific antigen (PSA)-based
screening for prostate cancer. A 2012 recommendation from the United States
Preventive Services Task Force (USPSTF) discouraged the use of PSA screening
due to a lack of evidence supporting its benefits, giving the service a grade
D recommendation. The USPSTF recommendation has been heavily criticized by the
urology community, and more than 33 public comments to MAP on this measure
strongly opposed its adoption as part of the MIPS program, citing concern
about the measure’s potential to inhibit shared decision-making by dissuading
providers from informing patients of PSA screening as an option. MAP supports
grounding measures in solid evidence and realizes that the USPSTF
recommendation represents a change in practice. MAP noted that this is an
important topic and overtreatment is a legitimate concern. Because of the
ongoing controversy and lack of consensus around PSA screening MAP does not
encourage further consideration of the measure as currently specified for
average risk individuals of all ages but suggests looking at more narrow
aspects of screening, use of risk-assessment tools or appropriate treatment.
- Public comments received: 46
Rationale for measure provided by HHS
The USPSTF recommends
against PSA-based screening for prostate cancer (grade D recommendation). This
recommendation applies to men in the general U.S. population, regardless of
age.” The Agency for Healthcare Research and Quality (AHRQ) looked at five
randomized controlled trials (RCTs) and two meta-analyses and found
inconsistency regarding the efficacy of PSA-based screening, although the
high-quality surveyed studies are limited to interim results and do not consider
potential psychological harms.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of men who were screened unnecessarily for
prostate cancer using a prostate-specific antigen (PSA)-based
screening.
- Numerator: Patients who receive a PSA-based screening test during
the measurement period.
- Denominator: Men of any age with an encounter during the
measurement period.
- Exclusions: Denominator exclusions: Men who had an active
diagnosis or history of prostate cancer diagnosis, an active diagnosis of
dysplasia of the prostate, or an elevated PSA test result in the year prior to
the measurement period (>4.0 nanograms/milliliter [ng/mL]).
- HHS NQS Priority: Making Care Safer
- HHS Data Source: This measure is intended to be an electronic
Clinical Quality Measure (eCQM) and will use EHR data
exclusively.
- Measure Type: Process
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
Yes
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not encourage further
consideration
- Workgroup Rationale: 2014 AASLD guidelines recommend use of
nonselective beta-blockers to prevent hemorrhage in patients with esophageal
varices but the level of evidence varies depending on the size of the varices:
consensus opinion only for small varices but high level evidence for
medium/large varices. As side-effects are significant with these medications
patients with small varices might suffer from use of medication for which
there is no clear evidence of benefit. Although this measure addresses a new
topic area and provides an additional measure for gastroenterologists MAP
notes the comments from the GI societies that do not support the measure.
Comments from the American Gastroenterological Association do not support
this measure and American Society for Gastrointestinal Endoscopy commented
"ASGE does not support advancement of this measure concept as other equally
effective treatments are available for patients with esophageal varices. AASLD
guidelines leave the treatment option to the discretion of the provider.
Further, 25% of patients taking beta blockers have side effects precluding
many patients from taking them."
- Public comments received: 5
Rationale for measure provided by HHS
Use on non-selective beta
blockers in the setting of esophageal varices can reduce portal pressure and
improve long term clinical outcomes. American Association for the Study of Liver
Diseases Guidelines 2009
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with diagnosis of esophageal
varices that have documented use of non-selective beta blocker in the
measurement period
- Numerator: Patients with diagnosis of esophageal varices on
non-selective beta blocker in the measurement period
- Denominator: All patients with diagnosis of esophageal
varices
- Exclusions: Exclusions: none Exceptions: Intolerance to
non-selective beta blocker, pulse < 60, systolic BP < 90, diastolic BP
< 50
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Eugene Gastroenterology Consultants, PC Oregon Endoscopy
Center, LLC
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Posterior repair with and without mesh have
been compared with similar outcomes. Mesh has been shown to have significant
complications including expulsion of the mesh in 17%. MAP encourages continued
development of this measure that will promote reduced use of mesh and the
associated costs (mesh and complications) without affecting patient outcomes.
The measure adds an appropriate use measure to the group of measures for
pelvic prolapse – a common condition in older women.
- Public comments received: 6
Rationale for measure provided by HHS
Pelvic organ prolapse is a
common condition with >50% of women presenting for routine gynecologic
affected (Obstet and Gynecol 2004; 104: 489-96), with the lifetime risk for
undergoing surgery for pelvic organ prolapse recently estimated to have doubled
to 20% (Obstet and Gynecol 2014;123:1201-6). Repairs of the posterior
compartment can include a midline fascial plication, site-specific repair, or a
graft-augmented repair. Studies have failed to demonstrate any significant
benefit to the utilization of synthetic mesh augments in the posterior
compartment (Am J Obstet Gynecol 2006;195:1762-71) and recent concerns have come
to light regarding the use of synthetic mesh augments (FDA Urogynecologic
Surgical Mesh : Update on the Safety and Effectiveness of Transvaginal Placement
for Pelvic Organ Prolapse; July 2011). Implementation of this measure will
determine if best care practices are being followed when treating women with
disorder.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients undergoing vaginal surgery for
pelvic organ prolapse involving the posterior compartment where a synthetic
mesh augment is utilized.
- Numerator: Number of patients undergoing surgery for pelvic organ
prolapse in the posterior compartment with a synthetic mesh augment is placed
in the posterior compartment.
- Denominator: Number of patients undergoing surgery for pelvic organ
prolapse which includes the posterior compartment. The prolapse codes for ICD9
-> ICD-10 include: 618.04 -> N81.6, Rectocele
- Exclusions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Outcome
- Steward: American Urogynecologic Society
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional Support
- Workgroup Rationale: In 2006 and 2008, an estimated 9.1% of U.S.
adults reported symptoms for current depression.1 Persons with a current
diagnosis of depression and a lifetime diagnosis of depression or anxiety were
significantly more likely than persons without these conditions to have
cardiovascular disease, diabetes, asthma and obesity and to be a current
smoker, to be physically inactive and to drink heavily. There is an
opportunity for improvement for the population captured by this paired
measure, which includes two PROs. MAP noted that the clinician set contains
measure NQF#710/PQRS#370 Depression Remission at Twelve months and NQF#712 and
PQRS#371Depressison Utilization of the PHQ-9. CMS advised that the
public-private collaboration ongoing to development core sets of measures to
foster better alignment will include measures NQF#710/PQRS#370 and NQF#1895
Assessment of mental status for community-acquired bacterial pneumonia. This
NQF-endorsed measure is a patient-reported outcome. This updated three-part
measure consolidates two current measures in the PQRS and Meaningful Use
programs. MAP was advised that the data collected for the current measures can
be used for this measures without additional burden. MAP also notes that this
new measure is more aggressive that the current measures and supports this
measure with the following CONDITIONS: look at the response rates; consider
risk-stratification to minimize adverse selection; consider target rates for
different types of providers and consider alignment with the core
measures.
- Public comments received: 8
Rationale for measure provided by HHS
Depression is a common and
treatable mental disorder. The Centers for Disease Control and Prevention states
that an estimated 6.6% of the U.S. adult population (14.8 million people)
experiences a major depressive disorder during any given 12-month period.
Additionally, dysthymia accounts for an additional 3.3 million Americans. In
2006 and 2008, an estimated 9.1% of U.S. adults reported symptoms for current
depression.[1] Persons with a current diagnosis of depression and a lifetime
diagnosis of depression or anxiety were significantly more likely than persons
without these conditions to have cardiovascular disease, diabetes, asthma and
obesity and to be a current smoker, to be physically inactive and to drink
heavily.[2] Depression is associated with higher mortality rates in all age
groups. People who are depressed are 30 times more likely to take their own
lives than people who are not depressed and five times more likely to abuse
drugs.[3] Depression is the leading cause of medical disability for people aged
14 – 44.[4] Depressed people lose 5.6 hours of productive work every week when
they are depressed, fifty percent of which is due to absenteeism and short-term
disability. People who suffer from depression have lower incomes, lower
educational attainment and fewer days working days each year, leading to seven
fewer weeks of work per year, a loss of 20% in potential income and a lifetime
loss for each family who has a depressed family member of $300,000.[5] The cost
of depression (lost productivity and increased medical expense) in the United
States is $83 billion each year.[6] 1. CDC. Current Depression Among Adults ---
United States, 2006 and 2008. MMWR 2010;59(38);1229-1235. 2. Strine TW, Mokdad
AH, Balluz LS, et al. Depression and anxiety in the United States: findings from
the 2006 Behavioral Risk Factor Surveillance System. Psychiatr Serv
2008;59:1383--90. 3. Joiner, Thomas Myths about suicide. Cambridge, MA, US:
Harvard University Press. (2010). 288 pp. 4. Stewart, W. F., Ricci, J. A.,
Chee, E., Hahn, S. R., & Morganstein, D. (2003). Cost of lost productive
work time among US workers with depression. Journal of the American Medical
Association, 289, 3135-3144. 5. Smith, J. P., & Smith, G. C. (2010).
Long-term economic costs of psychological problems during childhood. Social
Science & Medicine, 71, 110-115. 6. Greenberg, P. E., Kessler, R. C.,
Birnbaum, H. G., Leong, S. A., Lowe, S. W., Berglund, P. A., et al. (2003). The
economic burden of depression in the United States: How did it change between
1990 and 2000? Journal of Clinical Psychiatry, 64, 1465-1475. More detailed
information about the rationale and history of this measure and its components
are available in the MNCM measure submission forms for the most recent NQF
Behavioral Health measure endorsement project. Links are in the final committee
report available here:
http://www.qualityforum.org/Publications/2015/05/Behavioral_Health_Endorsement_Maintenance_2014_Final_Report_-_Phase_3.aspx.
Measure Specifications
- NQF Number (if applicable): 2103
- Description: This three-component paired measure assesses whether
the PHQ-9 screening tool was used among patients with a diagnosis of major
depression or dysthymia, and using patient reports, whether patients with an
initial PHQ score >9 demonstrate remission (i.e., PHQ score >5) at six
or 12 months.
- Numerator: 712: Adult patients age 18 and older with the diagnosis
of major depression or dysthymia who have a PHQ-9 tool administered at least
once during the four month measurement period. #711: Adults age 18 and older
with a diagnosis of major depression or dysthymia and an initial PHQ-9 score
greater than nine who achieve remission at six months as demonstrated by a six
month (+/- 30 days) PHQ-9 score of less than five. #710: Adults age 18 and
older with a diagnosis of major depression or dysthymia and an initial PHQ-9
score greater than nine who achieve remission at twelve months as demonstrated
by a twelve month (+/- 30 days) PHQ-9 score of less than five.
- Denominator: 712: Adult patients age 18 and older with the
diagnosis of major depression or dysthymia. #711: Adults age 18 and older
with a diagnosis of major depression or dysthymia and an initial (index) PHQ-9
score greater than nine. #710: Adults age 18 and older with a diagnosis of
major depression or dysthymia and an initial (index) PHQ-9 score greater than
nine.
- Exclusions: Patients who die, are a permanent resident of a nursing
home or are enrolled in hospice are excluded from this measure. Additionally,
patients who have a diagnosis (in any position) of bipolar or personality
disorder are excluded.
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: EHR, Paper medical record
- Measure Type: Outcome
- Steward: MN Community Measurement
- Endorsement Status: Never Submitted
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
Yes
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Ilio-femoral vein stenting has become a safe
and effective alternative to traditional open surgery to correct iliac vein
obstruction. A RAND evidence review in 2013 reported relief of pain (86-94%),
relief from swelling (66%-89%) and healing of venous ulcers (55-89%) in
published studies. The RAND summary concluded the benefits outweigh the risks
(1B). MAP encouraged continued development of this PRO that adds important
information for public reporting and quality of care that is meaningful to
patients and their families. The measure is intended for interventional
radiologists. No information is provided on cost of the survey and it is
unclear how the survey results will be transmitted to MIPS. MAP encourages
combining this measure with MUC15-413 the clinical outcome measure for a
robust composite outcome.
- Public comments received: 2
Rationale for measure provided by HHS
Ilio-venous stenting is a
commonly performed procedure in patients with deep venous disease including
acute, acute-on-chronic, and chronic venous thrombosis. Such interventions are
also performed in patients with venous stenosis, such as patient with May-Turner
syndrome. The procedural outcome of such procedures does not necessarily reflect
resolution of patient symptoms, however. Standardizing the use of
disease-specific surveys in this patient population is necessary to objectively
assess the success of ilio-femoral venous stenting. Each survey is different; an
objective outcome of any improvement would be the most appropriate assessment to
encourage use of this measure by a wide variety of providers. This measure
compliments a measure being considered for the 2016 PQRS program, focused on the
PRO in patients undergoing saphenous vein ablation.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients who demonstrate improvement in
a disease specific patient reported quality of life score after ilio-femoral
venous stenting
- Numerator: The number of patients who demonstrate improvement on a
disease-specific patient reported quality of life score at 3-6 months
following ilio-femoral venous stenting
- Denominator: The total number of patients undergoing ilio-femoral
venous stenting who received a baseline and follow-up disease specific patient
reported quality of life score at 3-6 months
- Exclusions: Patients with a history of lower extremity or pelvic
vein surgery. Exceptions: Patients with a history of pelvic or lower
extremity orthopedic surgery. Patients with debilitating osteoarthritis
involving the hips, knees, or ankles.
- HHS NQS Priority: Patient and Family Engagement
- HHS Data Source: Survey
- Measure Type: Patient Reported Outcome
- Steward: Society of Interventional Radiology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not encourage further
consideration
- Workgroup Rationale: MAP commends the developer for developing
measures but recommends developing more ambitious measures rather than these
documentation measures. The measure seems to be standard of care for
audiologists and no data on current performance is provided to establish a
quality problem. MAP recommends using the results of the patient assessment
in the measure for a true patient-reported outcome.
- Public comments received: 2
Rationale for measure provided by HHS
Patient engagement and their
perceptions of their hearing abilities is necessary to determine
patient-centered goals and treatment. There are several standardized, validated
patient questionnaires available to capture the patient's perception of their
communication abilities in their activities of daily living that can be used
with objective measures of communication and hearing to offer a complete picture
of the patient's functional ability. Using these tools assists the audiologist
with rehabilitation goals and care planning, and engages the patient in the
development of their own functional goals. The AQC proposes this measure will
assist audiologists adapt their practices to patient-centered, functional care
and actively engage patients in the diagnosis and treatment of their hearing
loss.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients 18 years and older with
documentation of a standardized patient-reported functional communication
assessment
- Numerator: A standardized, patient-reported functional
communication assessment is documented in the record
- Denominator: Patients age 18 years and older on the date of the
encounter with a diagnosis of a permanent, bilateral sensorineural hearing
loss (ICD-10 H90.3, H91.03, H91.3) and are seen for audiologic testing (CPT
92552, 92553, 92557, 92591, 92626)
- Exclusions: 1) Patient has a hearing loss that requires medical or
surgical intervention 2) Patient refuses to participate/complete
patient-reported functional hearing assessment 3) Patient is unable to perform
functional hearing assessment due to other complicated health factors,
language delay, or developmental delay Exceptions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: AQC/ASHA
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not encourage further
consideration
- Workgroup Rationale: MAP commends the developer for developing
measures but recommends developing more ambitious measures rather than these
documentation measures. The measure seems to be standard of care for
audiologists and no data on current performance is provided to establish a
quality problem. MAP suggests a measure that includes counseling the patient,
family and caregiver on the results and recommendations of the auditory
assessment and report to physician on the need for treatment or further
testing.
- Public comments received: 2
Rationale for measure provided by HHS
Functional hearing
measurements are necessary to supplement the findings of the hearing thresholds
and capture the patient's ability to communicate, and should be incorporated
into the diagnosis and treatment of bilateral, permanent hearing loss. The data
captured in objective measurement of open-set speech recognition, introduced
with the presence of noise, can help audiologists objectively measure
improvement and outcomes with amplification and rehabilitation and be used as a
tool to educate patients on their hearing perception abilities. Additionally,
functional hearing is a necessary measurement to determine cochlear implant
candidacy. The AQC proposes this measure will assist audiologists adapt their
practices to patient-centered, functional care.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients 5 years and older with
documentation of a standardized, objective measure of functional hearing
status using open-set speech recognition
- Numerator: An objective measure of functional hearing status using
a standardized open-set speech recognition test (words, short phrases, or
sentences) is documented.
- Denominator: Patients age 5 years and older on the date of the
encounter diagnosed with a permanent, bilateral sensorineural hearing loss
(ICD-10: H90.3, H91.03, H91.3) and seen for audiologic testing (CPT 92552,
92553, 92557, 92579, 92582, 92591, 92626)
- Exclusions: 1) Patient has a hearing loss that requires medical or
surgical intervention 2) Patient refuses to participate 3) Patient is unable
to perform functional hearing assessment due to other complicated health
factors, language delay or developmental delay. Exceptions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Audiology Quality Consortium/American Speech Language
Hearing Association
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Radical hysterectomy is the standard procedure
for women who undergo surgical treatment for cervical cancer. This is a more
extensive surgery aimed at curing the cancer. If most women are receiving this
standard of care, there will be little improvement from use of this measure.
MAP asked how often this standard of care is not being performed - data on
current performance is needed to assess whether there is an opportunity for
improvement. The measures are being collected in the Society of Gynecologic
Oncology Clinical Outcomes Registry. MAP encourages further development and
testing data to determine the gap in care.
- Public comments received: 4
Rationale for measure provided by HHS
The primary treatment of
stage IB1-IIA is radical hysterectomy. Unlike simple hysterectomy, radical
hysterectomy includes removal of the paracervical tissue including the
parametrium, uterosacral ligament, and uper vagina. Radical hysterectomy has
long been considered the most appropriate type of hysterectomy for invasive
cervical cancer. The procedure requires expertise and technical skill to
perform. Radical hysterectomy can be performed via laparotomy, through minimally
invasive technology (robotic or laparoscopic) or vaginally.
Measure Specifications
- NQF Number (if applicable):
- Description: Performance of appropriate type of hysterectomy in
women with early stage cervical cancer undergoing hysterectomy.
- Numerator: Women whose hysterectomy is classified as a radical
hysterectomy and includes removal of parametrial tissue, vaginal tissue and a
portion of the uterosacral ligaments. CPT 58210, 58285, or ICD9 codes 68.6,
68.61, 68.69, 68.7, 68.71, 68.79
- Denominator: Women with histologically confirmed stage IB1-IIA
cervical cancer who undergo hysterectomy. CPT codes 58210, 58285, 58150,
58152, 58180, 58200, 58956, 58541, 58542, 58543, 58544, 58548, 58550, 58552,
58553, 58554, 58570, 58572, 58571, 58573, 58260, 58262, 58263, 58267, 58270,
58275, 58280, 58290, 58291, 58292, 58293, 58294 or ICD9 codes 68.6, 68.61,
68.69, 68.7, 68.71, 68.79, 68.3, 68.31, 68.39, 68.4, 68.41, 68.49, 68.5,
68.51, 68.59, 68.6, 68.61, 68.69, 68.9
- Exclusions: Women who undergo primary surgery that is not a
hysterectomy. Women who undergo secondary surgery after primary radiotherapy
or chemoradiation. Exceptions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Society of Gynecologic Oncology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: The time interval from surgery to start of
chemotherapy significantly impacts prognosis in patients with advanced serous
ovarian carcinoma according to analysis of patient data in the prospective
OVCAD study. (Gynecologic oncology. 2013;131:15-20. PMID= 23877013). MAP
questioned whether the specific time frame is appropriate for measurement -
does it really make a different if it is 42 versus 43 or 44 days? Currently
there are few measures for ovarian cancer and GYN ONC specialists, however,
there is no evidence that patients are not receiving this standard of care –
the opportunity for improvement may be limited. The measures are being
collected in the Society of Gynecologic Oncology Clinical Outcomes Registry.
MAP encourages continued development of this measure pending further data on
current performance that demonstrates a gap in care.
- Public comments received: 4
Rationale for measure provided by HHS
Starting the chemotherapy
within 42 days (6 weeks) from surgery is consistent with the previous GOG
(Gynecologic Oncology Group) randomized trials that utilized this timeline as a
standard. The most important of those trials is GOG-158 (Ozols RF, Bundy BN,
Greer BE, Fowler JM, Clarke-Pearson D, Burger RA, et al. Phase III trial of
carboplatin and paclitaxel compared with cisplatin and paclitaxel in patients
with optimally resected stage III ovarian cancer: a Gynecologic Oncology Group
study. Journal of clinical oncology : official journal of the American Society
of Clinical Oncology. 2003;21:3194-200. PMID= 12860964) Although there is no
randomized trial to accurately quantify the importance of initiating
chemotherapy within 42 days from the debulking surgery, but analysis of patient
data from the prospective OVCAR study suggested that delaying chemotherapy is
associated with poorer survival, albeit it is only for overall survival in a
suboptimally debulked ovarian cancer (Hofstetter G, Concin N, Braicu I, Chekerov
R, Sehouli J, Cadron I, et al. The time interval from surgery to start of
chemotherapy significantly impacts prognosis in patients with advanced serous
ovarian carcinoma - analysis of patient data in the prospective OVCAD study.
Gynecologic oncology. 2013;131:15-20. PMID= 23877013). A second study presented
at the SGO 2013 by Eskander, R et al was a Gynecologic Oncology Group ancillary
data study. This study showed a negative survival impact associated with >25
day interval from surgical cytoreduction to initiation of systemic therapy in
advanced ovarian carcinoma. The largest study come some from Colorectal
literature when a metaanalysis of more than 15,000 patients, showed that a delay
of initiation of chemotherapy past 4 weeks after surgery is positively
correlated to a worse survival (Biagi JJ, Raphael MJ, Mackillop WJ, Kong W, King
WD, Booth CM. Association between time to initiation of adjuvant chemotherapy
and survival in colorectal cancer: a systematic review and meta-analysis. JAMA.
2011;305:2335-42. PMID=21642686). Starting the chemotherapy within 42 days (6
weeks) from surgery is consistent with the previous GOG (Gynecologic Oncology
Group) randomized trials that utilized this timeline as a standard. The most
important of those trials is GOG-158 (Ozols RF, Bundy BN, Greer BE, Fowler JM,
Clarke-Pearson D, Burger RA, et al. Phase III trial of carboplatin and
paclitaxel compared with cisplatin and paclitaxel in patients with optimally
resected stage III ovarian cancer: a Gynecologic Oncology Group study. Journal
of clinical oncology : official journal of the American Society of Clinical
Oncology. 2003;21:3194-200. PMID= 12860964) Although there is no randomized
trial to accurately quantify the importance of initiating chemotherapy within 42
days from the debulking surgery, but analysis of patient data from the
prospective OVCAR study suggested that delaying chemotherapy is associated with
poorer survival, albeit it is only for overall survival in a subooptimally
debulked ovarian cancer (Hofstetter G, Concin N, Braicu I, Chekerov R, Sehouli
J, Cadron I, et al. The time interval from surgery to start of chemotherapy
significantly impacts prognosis in patients with advanced serous ovarian
carcinoma - analysis of patient data in the prospective OVCAD study. Gynecologic
oncology. 2013;131:15-20. PMID= 23877013). A second study presented at the SGO
2013 by Eskander, R et al was a Gynecologic Oncology Group ancillary data study.
This study showed a negative survival impact associated with >25 day interval
from surgical cytoreduction to initiation of systemic therapy in advanced
ovarian carcinoma. The largest study come some from Colorectal literature when
a metaanalysis of more than 15,000 patients, showed that a delay of initiation
of chemotherapy past 4 weeks after surgery is positively correlated to a worse
survival (Biagi JJ, Raphael MJ, Mackillop WJ, Kong W, King WD, Booth CM.
Association between time to initiation of adjuvant chemotherapy and survival in
colorectal cancer: a systematic review and meta-analysis. JAMA.
2011;305:2335-42. PMID=21642686).
Measure Specifications
- NQF Number (if applicable):
- Description: Measuring the percentage of patient who received Intra
Venous (IV) chemotherapy after the debulking of advanced epithelial ovarian
cancer
- Numerator: Patients who have Ovarian cancer / fallopian tube cancer
( ICD-9= 183.0 (Ovarian cancer) 183.2 (Fallopian tube cancer) AND received IV
chemo within 42 days from surgery
- Denominator: All patient who underwent debulking surgery for
ovarian cancer. CPT coding may varies but those are the possibilites.58950 –
Resection (initial) of ovarian, tubal or primary peritoneal malignancy with
bilateral salpingo-oophorectomy and omentectomy 58951 - Resection (initial)
of ovarian, tubal or primary peritoneal malignancy with bilateral
salpingo-oophorectomy and omentectomy; with total abdominal hysterectomy,
pelvic and limited para-aortic lymphandenectomy 58952 - Resection (initial)
of ovarian, tubal or primary peritoneal malignancy with bilateral
salpingo-oophorectomy and omentectomy; with radical dissection for debulking
(i.e., radical excision or destruction, intra-abdominal or retroperitoneal
tumors) 58953 – Bilateral salpingo-oophorectomy with omentectomy, total
abdominal hysterectomy and radical dissection for debulking 58954 - Bilateral
salpingo-oophorectomy with omentectomy, total abdominal hysterectomy and
radical dissection for debulking; with pelvic lymphandenectomy and limited
para-aortic lymphadenectomy 58956 – Bilateral salpingo-oophorectomy with
total omentectomy, total abdominal hysterectomy for malignancy 58957 –
Resection (tumor debulking) of recurrent ovarian, tubal, primary peritoneal,
uterine malignancy (intra-abdominal, retroperitoneal tumors, with omentectomy,
if performed 58958 - Resection (tumor debulking) of recurrent ovarian, tubal,
primary peritoneal, uterine malignancy (intra-abdominal, retroperitoneal
tumors, with omentectomy, if performed; with pelvic lymphadenectomy and
limited para-aortic lymphadenectomy
- Exclusions: Patients who received Neoadjuvant Chemotherapy
Patients with non-epithelial cancer Exceptions: Patients who are pregnant at
the time of diagnosis ( ICD-9= 640.0 – 669.9 and V22.0 – V23.9)
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Society of Gynecologic Oncology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: As combination therapy is the standard of care
for patients with spread of cervical cancer beyond surgical margins, it is
unclear whether there is an opportunity for improvement. MAP encourages
further development pending review of data from testing. Unless data can
demonstrate there is a gap in care, this measure will add little to the
current set. The measures are being collected in the Society of Gynecologic
Oncology Clinical Outcomes Registry.
- Public comments received: 3
Rationale for measure provided by HHS
There have been multiple
prospective randomized trials demonstrating the disease free and overall
survival for cervical cancer patients with post-operative involvement of
surgical margins, and/or regional lymph nodes. These collective studies have
resulted in the recommendation by the National Cancer Institute that platinum
containing chemotherapy be added to post-operative radiation therapy for
patients with positive surgical margins including the parametrium and vagina, as
well as positive lymph nodes. The following articles are referenced in the NCI
alert: Morris et al NEJM 1999;340:1137-1143, Peters et al JCO 2000;18:1606-1613,
Rose, P. et al NEJM 1999;340:1144-1153
Measure Specifications
- NQF Number (if applicable):
- Description: Proportion of patients with pelvic lymph node
metastases, positive surgical margins, or positive parametrium who received
postoperative pelvic radiation with concurrent cisplatin-containing
chemotherapy (with or without brachytherapy)
- Numerator: Cervical cancer: 180.0, 180.1, 180.9, parametrium 183.4,
vagina 184.0, Positive lymph nodes draining the cervical basin secondary :
ICD9 codes 196.2, 196.6, 197.6, radiation therapy CPT codes: IMRT 77418,
0073T, HDR brachy 77785-77787,
- Denominator: Cervical cancer: 180.0, 180.1, 180.9 , parametrium
183.4, vagina 184.0, Positive lymph nodes draining the cervical basin
secondary : ICD9 codes 196.2, 196.6, 197.6
- Exclusions: Small cell, melanoma and other cervical histologies
that might be treated with primary chemotherapy. Secondary cervical cancers
Exceptions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Society of Gynecologic Oncology
- Endorsement Status: Endorsed; MUC same as endorsed version: Yes;
NQF endorsement review - 2015
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: The CDC reports that drug overdoses are the
leading cause of injury-related death in the United States and that the death
rate from drug overdose has risen dramatically over the last decade. This
increase is thought to be attributable primarily to the misuse and abuse of
prescription drugs, especially opioid analgesics, sedatives/tranquilizers, and
stimulants. There is substantial variation in opioid prescribing patterns
across regions and providers, indicating a need for improvement in practices.
MAP encourages continued development of this is an appropriate use/overuse and
patient safety measure that is not duplicative of other measures in the
clinician measure set. This MUC directly measures opioid over-prescribing. The
timeframe is important to remove any acute need such as post-operative pain
management from the measure. Data to determine the performance gap is needed.
MAP recommends that the specification on doses align with the best evidence,
and consider a smaller set of exclusions, i.e., cancer and palliative are
understandable, but other are more open for further consideration though there
is concern of going too far in the direction of avoiding opioids in
appropriate situations. MAP also notes that with greater surveillance of
opioid use, patients may be referred to pain management specialists that may
be more costly and less convenient for patients. MAP cautions that publishing
this information on Physician Compare may invite doctor shopping for drug
seekers.
- Public comments received: 12
Rationale for measure provided by HHS
Considerable evidence
indicates that opioid overuse is an important issue. The 2014 U.S. Department of
Health and Human Services (HHS) National Action Plan for Adverse Drug Event
Prevention highlighted the need for safer prescribing and monitoring of opioids.
Patients prescribed high-dose opioids have an approximately 10-fold increase in
risk of overdose compared with those prescribed low-dose opioids (Edlund et al.
2014). Patients on high-dose opioids are less likely to receive care consistent
with guidelines and appropriate monitoring (Morasco et al. 2010). High daily
dose is the most common indicator of potential opioid misuse or inappropriate
prescribing practices for opioids (Liu et al. 2013). The Secretary’s Opioid
Initiative (2015) includes improved prescribing practices as one of the
Departments top three priorities on opioids:
http://aspe.hhs.gov/basic-report/opioid-abuse-us-and-hhs-actions-address-opioid-drug-related-overdoses-and-deaths
.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients aged 18 years or older who
receive opioid therapy for 90 days or longer and are prescribed at least 90
milligrams morphine equivalent daily dosage.
- Numerator: Patients of the Medicare prescribing provider whose
daily morphine equivalent dose (MED) is greater than 90 mg for at least 90
consecutive days.
- Denominator: Patients of the Medicare prescribing provider that are
enrolled in a Part D Plan and who had two or more prescription claims totaling
> 15 days supply for an opioid, on two separate occasions during the
measurement year.
- Exclusions: Denominator exclusions: • Patients receiving palliative
or hospice treatment during the measurement period • Patients with cancer
during the measurement period • Patients with critical limb ischemic pain
during the measurement period • Patients with idiopathic pulmonary fibrosis
during the measurement period • Patients with refractory angina during the
measurement period • Patients with sickle cell disease during the measurement
period
- HHS NQS Priority: Making Care Safer
- HHS Data Source: Claims
- Measure Type: Process
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: This composite measure combines AHRQ's PQIs
individual measures for three acute conditions. MAP encourages continued
development of this composite with testing at the clinician level with the new
risk-adjustment model that includes co-morbidities. This composite measure for
population health encourages care coordination and efficient use of healthcare
services and is sensitive to dual eligible patients. This measure encourages
appropriate care of acute conditions in the ambulatory setting to avoid
hospitalization which is highly desirable for patients and families. However,
MAP raised concerns about the potential for promoting antibiotic overuse such
as overtreatment for aspiration pneumonia particularly in patients residing in
nursing homes and unnecessary treatment for asymptomatic bactiuria. MAP
questioned whether there could be interaction of this measure with the
hospital acquired condition(HACs)measures - the developer responded that the
present on admission codes used for these measures are excluded for the HACs.
CMS advised MAP that this composite is already used in the Physician Value
Modifier Program. CMS advised that they are considering attribution and
geographical comparisons.
- Public comments received: 8
Rationale for measure provided by HHS
The Prevention Quality
Indicators (PQIs) are a set of measures that can be used with hospital inpatient
discharge data to identify quality of care for "ambulatory care sensitive
conditions." These are conditions for which good outpatient care can potentially
prevent the need for hospitalization or for which early intervention can prevent
complications or more severe disease. The PQIs are population based.
Measure Specifications
- NQF Number (if applicable):
- Description: PQI composite of acute conditions per 100,000
population, ages 18 years and older. Includes admissions with a principal
diagnosis of one of the following conditions: dehydration, bacterial
pneumonia, or urinary tract infection. (Includes PQIs 10, 11, and
12)
- Numerator: Discharges, for patients ages 18 years and older, that
meet the inclusion and exclusion rules for the numerator in any of the
following PQIs: • PQI #10 Dehydration Admission Rate • PQI #11 Bacterial
Pneumonia Admission Rate • PQI #12 Urinary Tract Infection Admission Rate
Discharges that meet the inclusion and exclusion rules for the numerator in
more than one of the above PQIs are counted only once in the composite
numerator.
- Denominator: Population ages 18 years and older in metropolitan
area or county. Discharges in the numerator are assigned to the denominator
based on the metropolitan area or county of the patient residence, not the
metropolitan area or county of the hospital where the discharge
occurred.
- Exclusions: See each component measure for exclusions.
http://www.qualityindicators.ahrq.gov/modules/PQI_TechSpec.aspx
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims
- Measure Type: Composite
- Steward: Agency for Healthcare Research & Quality
- Endorsement Status:
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: This composite measure combines AHRQ's PQI
individual measures for admissions for several chronic conditions. This
composite measure for population health encourages care coordination and
efficient use of healthcare services and is sensitive to dual eligible
patients. MAP encourages continued development and testing of this measure
with attention to applicability at the clinician level of analysis and the
risk-adjustment model under development. MAP suggests considering
sociaodemographic factors also. CMS advised MAP that this composite is already
used in the Physician Value Modifier Program.
- Public comments received: 8
Rationale for measure provided by HHS
2 component measures already
in the program.
Measure Specifications
- NQF Number (if applicable):
- Description: PQI composite of chronic conditions per 100,000
population, ages 18 years and older. Includes admissions for one of the
following conditions: diabetes with short-term complications, diabetes with
long-term complications, uncontrolled diabetes without complications, diabetes
with lower-extremity amputation, chronic obstructive pulmonary disease,
asthma, hypertension, heart failure, or angina without a cardiac procedure.
(Includes PQIs 1, 3, 5, 7, 8, 13, 14, 15, and 16)
- Numerator: Discharges, for patients ages 18 years and older, that
meet the inclusion and exclusion rules for the numerator in any of the
following PQIs: • PQI #1 Diabetes Short-Term Complications Admission Rate •
PQI #3 Diabetes Long-Term Complications Admission Rate • PQI #5 Chronic
Obstructive Pulmonary Disease (COPD) or Asthma in Older Adults Admission Rate
• PQI #7 Hypertension Admission Rate • PQI #8 Heart Failure Admission Rate •
PQI #13 Angina Without Procedure Admission Rate • PQI #14 Uncontrolled
Diabetes Admission Rate • PQI #15 Asthma in Younger Adults Admission Rate •
PQI #16 Lower-Extremity Amputation among Patients with Diabetes Rate
Discharges that meet the inclusion and exclusion rules for the numerator in
more than one of the above PQIs are counted only once in the composite
numerator.
- Denominator: Population ages 18 years and older in metropolitan
area† or county. Discharges in the numerator are assigned to the denominator
based on the metropolitan area or county of the patient residence, not the
metropolitan area or county of the hospital where the discharge
occurred.
- Exclusions: See each component measure for exclusions.
http://www.qualityindicators.ahrq.gov/modules/PQI_TechSpec.aspx
- HHS NQS Priority: Best Practice of Healthy Living
- HHS Data Source: Claims
- Measure Type: Composite
- Steward: Agency for Healthcare Research & Quality
- Endorsement Status: This composite measure has not been submitted
to NQF. However, 7 of the measures are NQF-endorsed as population-level
measures for geographic areas:• PQI #1 Diabetes Short-Term Complications
Admission Rate (NQF #272)• PQI #3 Diabetes Long-Term Complications Admission
Rate (NQF #274)• PQI #5 Chronic Obstructive Pulmonary Disease (COPD) or Asthma
in Older Adults Admission Rate (NQF #275)• PQI #8 Heart Failure Admission Rate
(NQF #277)• PQI #14 Uncontrolled Diabetes Admission Rate (NQF #638) • PQI #15
Asthma in Younger Adults Admission Rate (NQF #283)• PQI #16 Lower-Extremity
Amputation among Patients with Diabetes Rate (NQF #285)In 2012 NQF removed
endorsement of two component measures: PQI #7 Hypertension Admission Rate This
measure only captures admissions with a primary diagnosis of hypertension.
Many admissions for uncontrolled hypertension are for AMI or stroke rather
than hypertension and are not captured in this measure. The Committee
questioned interpretation of results. Also the documentation from the
developer stated ” “Little evidence exists regarding the validity of this
indicator,” and “some of the variance in age-sex adjusted rates does not
reflect true differences in area performance.”. PQI #13 Angina Without
Procedure Admission Rate This measure is looking for inappropriate admissions
for angina - not over use of procedures. The measure implies that admission
for angina as long as it is accompanied by a procedure is appropriate – the
Committee thought this may encourage procedures. Also, coding has changed so
that many patients are coded as coronary artery disease rather than angina
which is a significant flaw in the measure.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Support
- Workgroup Rationale: Approximately 500,000 patients will die of
cancer in 2015. A 2014 study (Obermeyer Z, Makar M, et al) found that in
Medicare fee-for-service beneficiaries with poor-prognosis cancer, a
comparison of those receiving hospice care (60%) vs not (control) showed that
hospice patients had significantly lower rates of hospitalization, intensive
care unit admission, and invasive procedures at the end of life, along with
significantly lower total costs during the last year of life. This
NQF-endorsed measure addresses an important gap area identified by MAP in
end-of-life care for reporting by oncologists, is fully-specified and tested,
reflects patient-centered care, and addresses the important areas of care
coordination and appropriate use. MAP discussed the timeframe of 3 days
suggesting that a longer time, such as 7-days or more might be better. MAP
noted that the NQF Committee reviewing this measure for endorsement also
suggested that a longer timeframe might be useful. MAP recommends that the
NQF Committee re-evaluate the timeframe of this measure during NQF's upcoming
cancer project and consider potential unintended consequences of patients
being moved to hospice to avoid counting in the mortality statistics. MAP
noted that the measure could be expanded beyond cancer patients. Patients and
families value this type of information for public reporting.
- Public comments received: 14
Rationale for measure provided by HHS
Earlier referral and
admission to hospice allows patients to derive the maximal benefit from it
Measure Specifications
- NQF Number (if applicable): 216
- Description: Percentage of patients who died from cancer, and
admitted to hospice and spent less than 3 days there
- Numerator: Patients who died from cancer and spent fewer than three
days in hospice
- Denominator: Patients who died from cancer who were admitted to
hospice
- Exclusions: None
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: American Society of Clinical Oncology
- Endorsement Status: Never Submitted
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has not been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2011
- Project for Most Recent Endorsement Review: Cancer Endorsement
Maintenance 2011
- Review for Importance: The measure meets the Importance
criteria.(1a. High Impact; 1b. Performance Gap; 1c. Evidence)1a. Impact: H-14;
M-3; L-0; I-0; 1b. Performance Gap: H-13; M-3; L-1; I-0; 1c. Evidence: Y-16,
N-1, I-0Rationale:• It is well documented that short lengths of stay in
hospice compromises patients' quality of care and that there is a substantial
portion of hospice patients that are referred within 1-3 days of death.• The
measure affects a large number of patients and is high impact.• Many cancer
patients die in a hospital receiving futile care until the end. Referring
patients to hospice, when appropriate, addresses patient preferences, improves
quality of care, and reduces health care costs.• The Steering Committee noted
that poor performance on this measure would indicate that providers are
failing to have direct conversations with their patients about the futility of
further treatment and the benefits of hospice care.• The committee felt the
measure developer provided good evidence to support that the concept that
hospice referral would mean increased quality of care.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria.(2a. Reliability – precise specifications,
testing; 2b. Validity – testing, threats to validity)2a. Reliability: H-14;
M-3; L-1; I-0; 2b. Validity: H-13; M-4; L-0; I-0Rationale:• Steering Committee
members questioned why three days was selected as the numerator. The developer
noted that three days is the minimum lowest bar; seven days may be a better
indicator of quality of care. Also, data was more easily obtained with the
three day threshold than the seven day threshold.• The measure is well
specified.• The reliability testing for the measure is appropriate and
demonstrates the reliability of the measure.• Face validity of the measure was
demonstrated.
- Review for Feasibility: H-12; M-5; L-0; I-0(4a. Clinical data
generated during care process; 4b. Electronic data; 4c.Susceptibility to
inaccuracies/ unintended consequences identified 4d. Data collection strategy
can be implemented)Rationale:• The measure is reported using claims data and
is feasible to implement.• Steering Committee members noted that this measure
in conjunction with measure #0215 would prevent providers from not sending
patients to hospice because of the fear that the patient would die in the next
3 days and prevents providers from making patient care decisions about sending
patients to hospice based on measure performance.
- Review for Usability: H-11; M-6; L-0; I-0(Meaningful,
understandable, and useful to the intended audiences for 3a. Public Reporting
and 3b. Quality Improvement)Rationale:• The measure is usable for public
reporting, as it captures the use of hospice for appropriate patients.• The
measure is useful for QI, particularly when comparing facilities with similar
patient populations to see if there are irregularities in achieving this
measure.• The measure is in use through ASCO’s QOPI program.
- Endorsement Public Comments: Commenters indicated support for the
measure.
- Endorsement Committee Recommendation: Y-17; N-0Rationale: The
Steering Committee found that the measure affects a large patient population
and will help identify when facilities are providing overly aggressive, futile
care to patients rather than referring them to
hospice.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: This intermediate outcome measure assesses
imaging specialists for a wide variety of patient conditions and would inform
patients of the skill and effectiveness of clinicians performing image-guided
biopsies. The mean pooled success rates ranged from 70-96% for adequacy of
sampling across a range of biopsy locations in 23 studies. A consensus panel
suggested a threshold of 70-75% adequate sampling rate for internal quality
improvement purposes. MAP encourages continued development of this
intermediate outcome measure that would provide meaningful information to
patients and other stakeholders.
- Public comments received: 1
Rationale for measure provided by HHS
The success rate of
percutaneous biopsy is determined by the suitability of the sample for
pathological analysis. Patients in whom a biopsy procedure yields inadequate
specimens for analysis may be referred for repeat percutaneous biopsy, open
biopsy, or undergo imaging to assess for alternative sites for biopsy increasing
costs to the system, necessitating a second procedure or imaging test, and
resulting in a delay in diagnosis. This measure provides an overall assessment
of effective biopsy sampling, which directly influences the patient experience
and is an important component of efficient patient care. Evidence to support
this measure comes from several published studies which were reviewed in a SIR
Standards of Practice Document published in 2010 (Gupta S, Wallace MJ, Cardella
JF et al. Quality Improvement Guidelines for Percutaneous Needle Biopsy. JVIR
2010; 21:969=975). The mean pooled success rates ranged from 70-96% for adequacy
of sampling across a range of biopsy locations in 23 studies. The consensus
panel suggested a threshold of 70-75% adequate sampling rate for internal
quality improvement purposes. It is important to note that when a biopsy sample
is considered inadequate for analysis, the patient will likely require a second
biopsy procedure, either by the same operator or via a second approach with a
different operator increasing costs to payers. The proposed metric is intended
not to penalize operators for attempting difficult percutaneous biopsies, but
rather to place a priority on working with pathology to ensure adequacy of
sampling in a single procedure. This measure is a modified measure as submitted
for consideration last year, focusing on a different strategy for data capture.
Measure Specifications
- NQF Number (if applicable):
- Description: The percentage of percutaneous image-guided (US, CT,
fluoro) biopsy procedures performed in which sampling was adequate for
diagnosis on the final pathology report.
- Numerator: Number of percutaneous image-guided biopsy procedures
performed associated with a specimen sample considered adequate for
pathological analysis.
- Denominator: Number of percutaneous image-guided biopsies
performed
- Exclusions: Repeat biopsy procedures performed at the same site
following an initial inadequate sample
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Composite
- Steward: Society of Interventional Radiology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Hysterectomy is one of the most frequently
performed surgical procedures in the US. ACOG concludes that “evidence
demonstrates that, in general, vaginal hysterectomy is associated with better
outcomes and fewer complications.” 2010 data indicate that hysterectomies are
performed vaginally (19%), abdominally (56%), or with laparoscopic (25%) or
robotic assistance. ACOG notes that “abdominal hysterectomy is also an
important surgical procedure, especially when the vaginal or laparoscopic
approach is not appropriate to manage the patient's clinical situation or when
facilities cannot support a specific procedure.” While encouraging vaginal
hysterectomy as the safer procedure, it is unclear how many patients are not
candidates for a vaginal hysterectomy and what the target for this measure
should be or whether the patient clinical factors are equally distributed
among gynecologists. MAP encourages further development of this measure that
would provide important information to patients and suggests incorporating
shared-decision making also. MAP also notes that an appropriate use measure
for hysterectomy would be an important quality measure and important
information for patients. MAP is also interested in how this measure would
handle robotic surgeries.
- Public comments received: 5
Rationale for measure provided by HHS
The purpose of this measure
is to ensure that vaginal hysterectomy, the safest mode of hysterectomy, is
optimized as a treatment option for patients requiring hysterectomy for benign
indications. A Cochrane review evaluating route of hysterectomy asserts that
vaginal hysterectomy is the safest mode of hysterectomy and is associated with
fewer complications and better outcomes (Cochrane Database of Systematic Reviews
2009, Issue 3), and the American College of Obstetrics and Gynecology Committee
Opinion (Number 444 Nov 2009) asserts that vaginal hysterectomy is the approach
of choice whenever feasible.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients who underwent vaginal
hysterectomy
- Numerator: Total number of patients undergoing vaginal hysterectomy
(CPT codes 58270, 58275, 58280, 58290, 58291, 58292, 58293, 58294, 58260,
58262, 58263, 58267, 58553, 58550, 58552, 58554)
- Denominator: Total number of patients undergoing hysterectomy of
any type. (CPT codes 58270, 58275, 58280, 58290, 58291, 58292, 58293, 58294,
58260, 58262, 58263, 58267, 58553, 58550, 58552, 58554, 58544, 58570, 58571,
58572, 58573, 58541, 58542, 58543, 58150, 58152, 58180)
- Exclusions: Patients with a preoperative diagnosis of cancer
(applies to both numerator and denominator, ICD-10 codes) Exceptions:
None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Intermediate Outcome
- Steward: American Urogynecologic Society
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not encourage further
consideration
- Workgroup Rationale: Esophageal varices (dilated veins) are a
serious complications of cirrhosis of the liver. Screening for varices allows
treatment to prevent variceal hemorrhage. Endoscopy is the standard for
diagnosing varices. AASLD guidelines recommend endoscopy at the time of
diagnosis when the prevalence of medium/large varices is 15-25% (Class IIa,
Level C evidence.) Follow up screening every 1-2 years is recommended
depending on the initial findings. If patients have small varices, follow up
endoscopy is not necessary. All recommendations are Level C evidence so there
is little empirical evidence that screening endoscopy will impact patient
outcomes. Endoscopy carries significant costs, so evidence-based indications
are needed. MAP does not encourage continued development because while this
measure would address a new topic area in the set, the screening
recommendation is not based on solid empirical evidence. The submitter did not
provide any information on opportunity for improvement. Comments from the
American Gastroenterological Association do not support this measure and
American Society for Gastrointestinal Endoscopy commented "ASGE does not
support advancement of this measure as specified. This measure would not deter
overutilization of colonoscopy. Most guidelines suggest screening every 3
years in cirrhotic and within a year if they are decompensated."
- Public comments received: 6
Rationale for measure provided by HHS
Early detection of varices
in cirrhotic patients can improve long term survival
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with diagnosis of cirrhosis
that have documented endoscopy
- Numerator: Patients with diagnosis of cirrhosis that have
documented endoscopy in the measurement period
- Denominator: All patients with diagnosis of cirrhosis
- Exclusions: Exclusions: none Exceptions: Currently taking
non-selective beta – blocker, life expectancy of < 1 year, patient
declines
- HHS NQS Priority: Best Practice of Healthy Living
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Eugene Gastroenterology Consultants, PC Oregon Endoscopy
Center, LLC
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not encourage further
consideration
- Workgroup Rationale: This measure addresses a new topic area of
Hepatitis B and is related to PQRS# 401 Screening for Hepatocellular Carcinoma
(HCC) in patients with Hepatitis C Cirrhosis. A systematic review of Screening
for Hepatocellular Carcinoma in Chronic Liver Disease concluded that “There is
very-low-strength evidence about the effects of HCC screening on mortality in
patients with chronic liver disease. Screening tests can identify early-stage
HCC, but whether systematic screening leads to a survival advantage over
clinical diagnosis is uncertain.” The frequency of imaging is not specified.
MAP does not encourage further consideration because the current evidence
indicates that the benefit to patients is uncertain. The costs of screening
without evidence of a benefit are not justified. Comments from the American
Gastroenterological Association do not support this measure and American
Society for Gastrointestinal Endoscopy commented "ASGE does not support
advancement of this measure at this time as the measure concept lacks
sufficient evidence to show importance to measure and variation in
performance."
- Public comments received: 8
Rationale for measure provided by HHS
Early detection of hepatomas
in patients with Chronic Hepatitis B can improve long term survival.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with a diagnosis of Chronic
Hepatitis B that have had a documented abdominal US, CT Scan, or MRI in the
measurement period
- Numerator: Patients with a diagnosis of Chronic Hepatitis B that
have had a documented abdominal US, CT Scan, or MRI in the measurement
period
- Denominator: All patients with diagnosis of Chronic Hepatitis
B
- Exclusions: Exclusions: none Exceptions: All patients with known
diagnosis of hepatoma, life expectancy less than 1 year, or patient declined
screening during the measurement.
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Eugene Gastroenterology Consultants, PC Oregon Endoscopy
Center, LLC
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Ptosis is a condition in which the eyelid is
lower than normal position. Surgery may be indicated to improve vision or for
cosmetic reasons. It is unclear how many surgeries do not result in an
improvement in lid location. AAO indicates that this measure is in their QCRD
and data will be forthcoming on current performance. MAP encourages
development of outcome measures but must consider the opportunity for
improvement when data is available. This is an outcome measure for
oculoplastic surgeons – a subspecialty with few or no measures. A
patient-reported outcome may be more useful for this condition.
- Public comments received: 8
Rationale for measure provided by HHS
Improved marginal reflex
distance is the desired goal of surgery to improve clinical and functional
outcomes
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of surgical ptosis patients with an
improvement of MRD postoperatively
- Numerator: Patients who achieved an improvement in MRD
postoperatively compared to their preoperative level
- Denominator: Patients aged 18 years or older with a diagnosis of
acquired involutional ptosis who underwent a surgical procedure for the
condition
- Exclusions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Outcome
- Steward: American Academy of Ophthalmology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: No longer under consideration by
CMS
- Workgroup Rationale: No longer under consideration by
CMS
- Public comments received: 4
Rationale for measure provided by HHS
Grade 3 tumors with greater
than 50% myometrial invasion are at a higher risk of distant/metastatic spread.
The decision to recommend adjuvant chemotherapy and/or radiation has advantages
to patient outcomes in advanced stage diseases and if a lymph node dissection is
not performed, patient stage status is known and women maybe undertreated or
overtreated. The absence of an appropriate measure of this nature has the risk
of women having surgery performed by General Gynecologists without the surgical
expertise to perform a lymph node dissection. (1)National Cancer Center Network
Clinical Practice Guidelines in Oncology. Uterine Neoplasms. 2014
Measure Specifications
- NQF Number (if applicable):
- Description: Uterine cancer patients with adequate surgical staging
performed with a grade 3 tumor and deep uterine wall invasion.
- Numerator: Number of women with a grade 3 endometrial cancer
identified with greater than 50% myometrial invasion who have a surgical
staging procedure with lymph node removals
- Denominator: Total number of women with a grade 3 endometrial
cancer ( ICD-9 codes: 182 malignant neoplasm of body of uterus; 182.0 Corpus
uteri, except isthmus; 182.1 Isthmus; 182.8 ) undergoing surgery who are found
to have greater than 50% myometrial invasion
- Exclusions: Women with poor performance status or medical
co-morbidities in which increased surgical time or staging procedures place
patient at significant risk or women identified preoperatively with advanced
stage disease or treated with preoperative chemotherapy and/or radiation if
not a surgical candidate Exceptions: Women with poor performance status or
medical co-morbidities in which increased surgical time or staging procedures
place patient at significant risk or women identified preoperatively with
advanced stage disease or treated with preoperative chemotherapy and/or
radiation if not a surgical candidate
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Society of Gynecologic Oncology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not encourage further
consideration
- Workgroup Rationale: Crohn's disease is a chronic inflammatory
disease of the digestive tract. Symptoms include abdominal pain and diarrhea,
sometimes bloody, and weight loss. Crohn’s patients are at higher risk for
colon cancer. American Society for Gastrointestinal Endoscopy (ASGE)
guidelines recommend that patients with Crohn’s Disease for more than 10 years
should have a surveillance colonoscopy every 1-2 years. Although there are no
measures that focus on Crohn’s Disease in the current measures set and this
measure would complement other colonoscopy measures MAP is concerned that the
measure could be better specified to discourage overuse as well as encourage
appropriate use of endoscopy. Comments from the American Gastroenterological
Association do not support this measure and American Society for
Gastrointestinal Endoscopy commented "While ASGE finds the inclusion of
surveillance measures in public reporting programs worthy of exploration, this
measure, as specified, would not deter overutilization of colonoscopy. The
recommendations for surveillance colonoscopy in Crohn’s disease are based on
how long the patient has had the disease."
- Public comments received: 8
Rationale for measure provided by HHS
Early detection of dysplasia
or cancer in colonic Crohn’s Disease patients can improve long term survival.
All patients with diagnosis colonic Crohn’s Disease for > 10 years should
have a surveillance colonoscopy every 1-2 years (American Society of
Gastrointestinal Endoscopy Guidelines 2006)
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with diagnosis of colonic
Crohn’s Disease for 10 years or more that have documented colonoscopy in the
measurement period or 1 year prior to measurement period.
- Numerator: Patients with diagnosis of Crohn’s disease who have had
a colonoscopy in the measurement period or 1 year prior to measurement
year
- Denominator: All patients with diagnosis of colonic Crohn’s
Disease
- Exclusions: Exclusions: none Exceptions: Diagnosis of colonic
Crohn’s Disease for < 10 years, isolated small bowel Crohn’s disease, life
expectancy of < 1 year, patient declines
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Eugene Gastroenterology Consultants, PC Oregon Endoscopy
Center, LLC
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not encourage further
consideration
- Workgroup Rationale: American College of Gastroenterology
guidelines state “after 8 – 10 years of colitis, annual or biannual
surveillance colonoscopy with multiple biopsies at regular intervals should be
performed (Evidence B). Aft er 10 years of universal disease, the cancer risk
has been widely reported in the range of 0.5 – 1 % per year. However, a recent
nation-wide population-based analysis from the Netherlands found that 20% of
all UC-related cancers were detected before 8 years of disease had elapsed.
Although there are no measures that focus on Ulcerative Colitis in the current
measures list MAP is concerned that the measure could be better specified to
discourage overuse as well as encourage appropriate use of endoscopy. The
registry is not specified. Data on current performance would provide a better
understanding of the gap in care. Comments from the American
Gastroenterological Association do not support this measure and American
Society for Gastrointestinal Endoscopy commented "While ASGE finds the
inclusion of surveillance measures in public reporting programs worthy of
exploration, this measure, as specified, would not deter overutilization of
colonoscopy. The recommendations for surveillance colonoscopy in Ulcerative
Colitis are based on how long the patient has had the disease."
- Public comments received: 7
Rationale for measure provided by HHS
Early detection of dysplasia
or cancer in ulcerative colitis patients can improve long term survival ACG
guideline 2010
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with diagnosis of Ulcerative
Colitis for 10 years or more that have documented colonoscopy in the
measurement period or 1 year prior to measurement period.
- Numerator: Patients with diagnosis of Ulcerative Colitis who have
had a colonoscopy in the measurement period or 1 year prior to measurement
year
- Denominator: All patients with diagnosis of Ulcerative
Colitis
- Exclusions: Exclusions: none Exceptions: Diagnosis of colonic
Ulcerative Colitis for < 10 years, life expectancy of < 1 year, patient
declines
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Eugene Gastroenterology Consultants, PC Oregon Endoscopy
Center, LLC
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not encourage further
consideration
- Workgroup Rationale: Barrett’s esophagus is a serious complication
occurring in about 10-15% of patients with GERD (reflux).Esophageal dysplasia
and esophageal cancer occur at increased rates in patients with Barrett's
esophagus although less than 1% of patients develop cancer. Nov 2015 guideline
from American College of Gastroenterology recommend endoscopic surveillance
every 3-5 years (strong recommendation, moderate evidence).Although this
measure addresses a new topic area and provides an additional measure for
gastroenterologists MAP is concerned that the measure could be better
specified to discourage overuse as well as encourage appropriate use of
endoscopy. Comments from American Gastroenterological Association do not
support this measure and the American Society for Gastrointestinal Endoscopy
(ASGE) commented "ASGE finds the inclusion of surveillance measures in public
reporting programs worthy of exploration, this measure concept currently lacks
sufficient evidence to show importance to measure and variation in
performance. Further, as currently specified, this measure would not deter
overutilization." MAP also recommends that an overuse measure for GERD
endoscopy is needed.
- Public comments received: 6
Rationale for measure provided by HHS
Esophageal dyslasia and
esophageal cancer occur at increased rates in patients with Barrett's Esophagus.
Patients with esophageal dyslasia and esophageal cancer are often asymptomatic
until later stages. Earlier detection can improve outcomes. American College of
Gastroenterology Guidelines 2008
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients with diagnosis of Barrett’s
Esophagus that have documented endoscopy in the measurement
period
- Numerator: Patients with diagnosis of Barrett's Esophagus who have
had an upper endoscopy during the measurement period or the four years prior
to the measurement period
- Denominator: All patients with diagnosis of Barrett’s
Esophagus
- Exclusions: Exclusions: None Exceptions: Denominator: Life
expectancy of < 1 year, patient declines
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Eugene Gastroenterology Consultants, PC Oregon Endoscopy
Center, LLC
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: The lifetime risk of having surgery for
prolapse or incontinence by age 80-85 is 11-19% and projected to increase.
Obliterative surgery (colpocleisis) closes the vagina to keep the organs
within the pelvis and is an alternative for patients who cannot tolerate
extensive surgery and no longer desire preservation of sexual function. Before
surgery, work-up should eliminate any co-existing malignant condition before
access to the organs is closed off. Data could not be found on the number of
these surgeries performed each year. This is a patient safety measure
applicable to gynecologists and female pelvic medicine and reconstructive
surgery (FPMRS) specialists. This measure is closely related to PQRS #429
Pelvic Organ Prolapse: Preoperative Screening for Uterine Malignancy for
patients undergoing hysterectomy for prolapse. MAP suggests that these two
measures could be combined for measurement efficiency.
- Public comments received: 5
Rationale for measure provided by HHS
This measure will help
ensure that patients who do have a uterine malignancy are diagnosed prior to
colpocleisis. Thus avoiding the lack of access to the uterus for proper work up
and allowing proper referral to a gynecologic oncologist for appropriate staging
and treatment for the malignancy. The incidence of endometrial cancer found
unsuspectingly in patients with POP ranges from 0.3- 3.2%. In a review of all
surgical pathology reports for patients undergoing a hysterectomy for pelvic
organ prolapse, 644 women were evaluated and 2 were diagnosed with endometrial
cancer (0.3%). Ensuring that providers ask about possible symptoms that may hint
at the need for further evaluation would increase the quality of care provided
to these patients.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients having documented assessment of
abnormal uterine or postmenopausal bleeding prior to surgery for pelvic organ
prolapse (similar to CMS proposed measure named Preoperative exclusion of
uterine malignancy prior to any pelvic organ prolapse repair, see 80 FR
41852).
- Numerator: Number of patients that were asked about abnormal
uterine or postmenopausal bleeding, or those that had an ultrasound and/or
endometrial sampling of any kind. These would be identified by chart review or
entry into the PFD Registry.
- Denominator: CPT code 57120- colpocleisis
- Exclusions: Prior hysterectomy Exceptions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: American Urogynecologic Society
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: In the US there were 12,900 cases and 4100
deaths from cervical cancer this year. Radiation therapy is included in
treatment protocols for all but the earliest stage of cancer. Brachytherapy is
internal radiation placed in and near the cervix with minimal radiation
exposure to other areas. Brachytherapy is considered a critical component of
treatment by the National Comprehensive Cancer Network. According to the
American Brachytherapy Society Cervical Cancer Brachytherapy Task Group “The
radiation dose delivered by brachytherapy is critical in curing patients of
cervical cancer and has been the standard of treatment for over 100 years.” A
recent study from the National Cancer Database with a median overall survival
of 63.3 months in patients who did receive brachytherapy and 27.2 months among
patients who did not (Lin JF et al. Gynecol Oncol. 2014;132:416-422). These
studies also showed that only 47.5-58% of women are treated with brachytherapy
in addition to their external beam therapy and that rates of use of
brachytherapy have declined over time. The declination in use is attributed to
inadequate training and unavailability of appropriate technology in small
hospitals. Improvement in use of brachytherapy will improve survival in women
with cervical cancer. MAP encourages continued development of this process
measure closely linked to clinical outcomes (patient survival) with a
demonstrated quality problem/opportunity for improvement. The measure is
being collected in the Society of Gynecologic Oncology Clinical Outcomes
Registry.
- Public comments received: 5
Rationale for measure provided by HHS
Women with early stage
cervical cancer who are not operative candidates and those with stage 1B2 or
higher stage cancers are typically recommended to undergo radiation therapy with
external beam radiation and brachytherapy. Brachytherapy is considered a
critical component of treatment by the National Comprehensive Cancer Network.
Four year causes specific survival improved with the use of brachytherapy (64.3%
with brachytherapy v. 51.1% without) as did overall survival (58.2% with
brachytherapy v. 46.2% without) based on SEER data (Han K et al. Int J Rad Onc,
Biol, Phys. 2013;87:111-119). Similar results were seen in a recent study from
the National Cancer Database with a median overall survival of 63.3 months in
patients who did receive brachytherapy and 27.2 months among patients who did
not (Lin JF et al. Gynecol Oncol. 2014;132:416-422). These studies also showed
that only 47.5-58% of women are treated with brachytherapy in addition to their
external beam therapy and that rates of use of brachytherapy have declined over
time. The declination in use is attributed to inadequate training and
unavailability of appropriate technology in small hospitals.
Measure Specifications
- NQF Number (if applicable):
- Description: The percentage of cervical cancer patients who
undergoing curative intent radiation who receive brachytherapy in addition to
external beam therapy
- Numerator: Number of patients who receive brachytherapy as part of
their treatment for cervical cancer (Cervical cancer ICD-10 dx code C53.9) CPT
77785, 77786, 77787, 77761, 77762, 77763
- Denominator: All patients undergoing primary radiation for cervical
cancer (cervical cancer diagnosis code C53.9) with curative intent: 77385,
77386, 77402, 77407, 77412
- Exclusions: Patients receiving palliative radiation, patients with
stage IVB Exceptions: Patients on clinical trial
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Society of Gynecologic Oncology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: A 2010 Cochrane review found that women who
had chemoradiotherapy for cervical cancer were likely to live for longer than
women who had just radiotherapy. Although this measure promotes the best
recommended care and should improve the outcomes for women with cervical
cancer, it is unclear how many patients are not receiving appropriate
chemoradiation therapy. MAP encourages further development of the measure
pending data from testing that identifies variation in care. The impact will
be limited if patients are already receiving this standard of care. This
measure for treatment of advanced cervical cancer is one of four new measures
for cervical cancer management – an area that does not have current measures.
The measures are being collected in the Society of Gynecologic Oncology
Clinical Outcomes Registry.
- Public comments received: 4
Rationale for measure provided by HHS
The addition of
platinum-based chemotherapy to primary radiation therapy in the treatment of
patients with stage IIB-IV cervical cancer is associated with a significant
progression-free and overall survival benefit. This finding was demonstrated in
five landmark randomized clinical trials, which led to the National Cancer
Institute (NCI) clinical alert in 1999 that established the addition of
chemotherapy to radiation therapy as standard of care for cervical cancer
patients. Subsequently, the Chemoradiotherapy for Cervical Cancer Meta-analysis
Collaboration published a Cochrane Database systemic review and meta-analysis,
confirming the findings of the initial trials. The review and meta-analysis
demonstrated that the addition of platinum-based chemotherapy was associated
with a 17% improvement in overall survival (HR = 0.83, 95% CI 0.71- 0.97, P =
0.017). The addition of chemotherapy to radiation therapy also improved
disease-free survival by 22% (HR 0.78, 95% CI 0.70 - 0.87, P < 0.001). The
benefit of platinum-based chemotherapy to primary radiation therapy in the
treatment of stage IIB-IV cervical cancer patients has been clearly
demonstrated. However, there is a paucity of data on how often healthcare
providers and institutions are meeting this standard of care. REFERENCES
Chemoradiotherapy for Cervical
Cancer Meta-analysis Collaboration (CCCMAC).
Reducing uncertainties about
the effects of chemoradiotherapy for cervical
cancer: individual patient data meta-analysis. Cochrane Database
Syst Rev. 2010 Jan 20;(1):CD008285. doi: 10.1002/14651858.CD008285.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of patients who receive concurrent
platinum-based chemotherapy for patients with stage IIB-IV cervical cancer
receiving primary radiation therapy.
- Numerator: Numerator is the number of patients who receive
concurrent platinum-based chemotherapy for patients with stage IIB-IV cervical
cancer receiving primary radiation therapy. ICD9 codes 180.0-180.9, CPT codes
96409, 96411, 96417.
- Denominator: Number of patients with stage IIB-IV cervical cancer
who receive primary radiation therapy. ICD9 codes 180.0-180.9, CPT codes
57155, 57156, 77261-77299, 77300-77399, 77401-77421, 77785, 77786, 77787,
77799.
- Exclusions: Patients who have a medical contraindication to receipt
of platinum-based chemotherapy should receive an alternative chemotherapy
agent that has been demonstrated to have clinical benefit in patients with
cervical cancer. Exceptions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: Society of Gynecologic Oncology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP encourages development of this appropriate
use measure for dermatology. This measure evaluates the utilization of Mohs
and promotes the routine use of less expensive treatment modalities such as
traditional surgical excision or destructive methods like curettage and
electrodessication destruction for low-risk cancers on the trunk which should
result in savings for the healthcare system. The registry is the AAD’s
clinical data registry called DataDerm that will be launched January 2016.
- Public comments received: 7
Rationale for measure provided by HHS
The use of Mohs surgery has
increased substantially over the past decade. To prevent its over-utilization on
low-risk tumors, appropriate use criteria (AUC) have been developed which
indicate that treatment of truncal squamous cell carcinoma in situ (SCCis) and
keratoacanthoma type squamous cell carcinoma (SCC-KA) that are 1 cm or smaller
in immunocompetent patients is an inappropriate use of this treatment modality.
This measure evaluates the utilization of Mohs and promotes the routine use of
less expensive treatment modalities such as traditional surgical excision or
destructive methods like curettage and electrodessication destruction for
low-risk SCCis or SSC-KA on the trunk which should result in savings for the
healthcare system.
Measure Specifications
- NQF Number (if applicable):
- Description: This measure evaluates the number of inappropriately
utilized Mohs surgeries to treat primary squamous cell carcinomas in situ
(SCCis) and keratoacanthoma (SCC-KA) on the trunk that are 1 cm or smaller in
immunocompetent patients. The assessment of inappropriate use of Mohs surgery
will help to improve compliance with AUC and should result in healthcare
savings.
- Numerator: Number of pathologically-proven primary SCCis or SCC-KA
lesions on the trunk (chest, back, abdomen) that are 1 cm or smaller in
immunocompetent patients treated by the provider utilizing Mohs
surgery.
- Denominator: All pathologically-proven primary SCCis or SCC-KA
lesions on the trunk (chest, back, abdomen) that are 1 cm or smaller in
immunocompetent patients treated by the provider within the reporting
period.
- Exclusions: Exclusions: • Patients with a genetic syndrome that
increases their risk for skin cancer. • Tumors in areas of previous radiation
therapy. • Tumors that have pathologically documented areas of dermal
invasion, or dermal invasion is found on any stage if Mohs surgery is
performed. • Pathology report states that it cannot exclude a deeper or more
aggressive tumor histology for any reason other than because it is a partial
biopsy sample. • Pathology report states that there is a collision tumor with
another tumor that has a more aggressive histology.
- HHS NQS Priority: Making Care Affordable
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: American Academy of Dermatology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP encourages further development of this
appropriate use measure for dermatology. This measure evaluates the
utilization of Mohs and promotes the routine use of less expensive treatment
modalities such as traditional surgical excision or destructive methods like
curettage and electrodessication destruction for low-risk cancers on the trunk
which should result in savings for the healthcare system. The registry is the
AAD’s clinical data registry called DataDerm that will be launched January
2016.
- Public comments received: 7
Rationale for measure provided by HHS
The use of Mohs surgery has
increased substantially over the past decade. To prevent its over-utilization on
low-risk tumors, appropriate use criteria (AUC) have been developed which
indicate that treatment of superficial basal cell carcinoma (BCC) on the trunk
in immune-competent patients is an inappropriate use of this treatment modality.
This measure evaluates the utilization of Mohs and promotes the routine use of
less expensive treatment modalities such as traditional surgical excision or
destructive methods like curettage and electrodessication destruction for
low-risk SCCis or SSC-KA on the trunk which should result in savings for the
healthcare system.
Measure Specifications
- NQF Number (if applicable):
- Description: This measure evaluates the number of inappropriately
utilized Mohs surgeries to treat primary superficial basal cell carcinomas
(BCCs) on the trunk in immune-competent patients. The assessment of
inappropriate use of Mohs surgery will help to improve compliance with
appropriate use criteria (AUC) and should result in healthcare
savings.
- Numerator: Number of pathologically-proven primary superficial
BCC’s treated by the provider utilizing Mohs surgery.
- Denominator: All pathologically-proven primary superficial basal
cell carcinoma (BCC) lesions on the trunk (chest, back, abdomen) on
immune-competent patients treated by the provider within the reporting
period.
- Exclusions: Exclusions: • Tumors that have a pathologically
documented mixed histology including a more aggressive histologic subtype, or
a more aggressive tumor is found on any stage if Mohs surgery is performed. •
Pathology report states that it cannot exclude a deeper or more aggressive
tumor histology for any reason other than because it is a partial biopsy
sample. • Pathology report states that there is a collision tumor with
another tumor that has a more aggressive histology.
- HHS NQS Priority: Making Care Affordable
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: American Academy of Dermatology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Do not encourage further
consideration
- Workgroup Rationale: MAP does not encourage further consideration
of this measure focused on dermatologists. The denominator is all transplant
patients --transplant patients need a variety of care processes and this
standalone measure does not address the totality of care that should be
coordinated by the transplant team. A composite measure would be appropriate
for care of transplant patients.
- Public comments received: 5
Rationale for measure provided by HHS
It is well-established in
the literature that organ transplant recipients (OTRs) have increased incidences
of NMSC overtime. It is essential to provide a protocol to ensure that OTRs
receive appropriate levels of health promotion from their provider. This measure
seeks to ensure health promotion using three tiers to increase knowledge,
screenings, and protective methods to limit the morbidity and mortality that can
result from non-melanoma skin cancer (NMSC).
Measure Specifications
- NQF Number (if applicable):
- Description: This measure evaluates the number of organ transplant
recipients (OTRs) that receive sun protection education and a full skin exam
annually by their provider. Preventative screenings and education for OTRs is
critical in order to lower incidence and/or severity of skin cancers in these
increased risk individuals.
- Numerator: Number of patients receiving sun protection education
and a full skin exam once within the reporting period (1 year) by the provider
or documentation of either a referral to or completion of these preventative
activities by a dermatologist.
- Denominator: All organ transplant recipients seen by provider in an
outpatient setting within the reporting period.
- Exclusions: Exclusions: Documented refusal by patient to schedule
follow-up annual screens after documented appropriate counseling on risk for
skin cancer.
- HHS NQS Priority: Best Practice of Healthy Living
- HHS Data Source: Claims, Registry
- Measure Type: Process
- Steward: American Academy of Dermatology
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: No longer under consideration by
CMS
- Workgroup Rationale: No longer under consideration by
CMS
- Public comments received: 5
Rationale for measure provided by HHS
Given the increasing number
of women undergoing ambulatory surgical procedures for UI from 34,968 in 1996 to
105,656 in 2006, the need and demand for treatment of UI will rise significantly
due to current changes in demographics (Erekson EA, 2010, Ambulatory procedures
for female pelvic disorders in the United States). The procedures include the
slings if the urethra hypermobile or bulking agents for fixed (ISD) urethra. The
effectiveness of a sling decreases from 90% to 50% in someone with ISD. ISD
criteria usually: not mobile urethra, VLPP less than 60mm H2O or MUCP less than
20mm H2O. Patients with ISD. Bulking agents are effective 70-80% in patients
with ISD. Use of bulking agents should be utilized in appropriate patients with
ISD.
Measure Specifications
- NQF Number (if applicable):
- Description: Documentation of ISD prior to procedure
- Numerator: Percentage of patients who have documented ISD prior to
procedure
- Denominator: All patients who underwent the procedure CPT code
51715 and ICD-9 code 599.82
- Exclusions: None
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims, Registry
- Measure Type: Outcome
- Steward: American Urogynecologic Society
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Support
- Workgroup Rationale: This measure is aligned with PQRS/MIPS,
addresses an important need for patients and caregivers and is a cross-cutting
communication and care coordination measure applicable to all Medicare
patients..
- Public comments received: 17
Rationale for measure provided by HHS
Addresses a gap in patient
and family centered care, aligns with PQRS, and aligns with recent CMS payment
policy supporting advance care planning between providers and
patients/caregivers.
Measure Specifications
- NQF Number (if applicable): 326
- Description: Percentage of patients aged 65 years and older who
have an advance care plan or surrogate decision maker documented in the
medical record or documentation in the medical record that an advance care
plan was discussed but the patient did not wish or was not able to name a
surrogate decision maker or provide an advance care plan
- Numerator: Patients who have an advance care plan or surrogate
decision maker documented in the medical record or documentation in the
medical record that an advance care plan was discussed but patient did not
wish or was not able to name a surrogate decision maker or provide an advance
care plan.
- Denominator: All patients aged 65 years and older.
- Exclusions: N/A
- HHS NQS Priority: Patient and Family Engagement
- HHS Data Source: Other
- Measure Type: Process
- Steward: National Committee for Quality Assurance
- Endorsement Status: NQF measure #326 was endorsed in 2012 and was
tested in 220 Medicare patients using paper and electronic medical records in
four practice sites. Inter-rater reliability was high at all four sites.
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has not been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2012
- Project for Most Recent Endorsement Review: Care Coordination
Endorsement Maintenance 2012: Phases 1 and 2
- Review for Importance: based on decision logic): Yes(1a. High
Impact: 1b. Performance Gap 1c. Evidence)1a. Impact: H-23; M-3; L-0; I-0 1b.
Performance Gap: H-20; M-4; L-0; I-2 1c. Evidence: Y-15; N-4; I-7Rationale:
The Committee expressed strong support of the importance of advanced care
planning for this population. There was overall agreement on both a gap in
performance as well as an overall low performance for this measure, although
there was a desire by some members of the Committee to see performance
statistics for various population subgroups (e.g., underserved groups,
cognitively impaired, etc.). Committee members also suggested that while there
is strong evidence for the value of advanced care planning overall, there is
less evidence linking advanced care planning to desired outcomes such as
improved quality of life or potential cost savings.
- Review for Scientific Acceptability: based on decision logic):
Yes(2a. Reliability – precise specifications, testing; 2b. Validity – testing,
threats to validity)2a. Reliability: H-6; M-11; L-5; I-4 2b. Validity: H-2;
M-11; L-7; I-6Rationale: There was considerable difference of opinion between
Committee members regarding the reliability and validity of the measure (note
that there was a tie for validity). Much of the concern with this measure was
related to how the measure is specified. Committee members were confused about
what is actually being measured (i.e., that a “conversation” occurred, that
various components of an advanced care plan, such as an advanced directive,
durable power of attorney, etc.—have been documented, or some combination).
They were also concerned about the time frame of the measure, since it seems
to be measuring, on an annual basis, whether or not an advanced care plan is
documented in the medical record—but is not measuring whether the plan has
been updated, or at least discussed, at least annually. While the developer
clarified that this measure holds the physician accountable for the
documentation, Committee members maintained it is often other providers (e.g.,
nurse, social worker) who often have advanced care conversations with
patients. Additionally, Committee members were concerned that advanced care
planning conversations are actually occurring, but for some reason, they are
not being captured with this measure through the use of CPT-II codes. There
was also considerable discussion about the testing of the measure, and
although the developer described inter-rater reliability testing done based on
manual record abstraction, some Committee members were not convinced that
adequate testing had been done to assure that reporting of a CPT-II code does
in fact reflect actual documentation of advanced care planning in the medical
record.
- Review for Feasibility: H-2; M-12; L-10; I-2(4a. Clinical data
generated during care delivery; 4b. Electronic sources; 4c.Susceptibility to
inaccuracies/ unintended consequences identified 4d. Data collection strategy
can be implemented)Rationale: There was disagreement among Committee members
about the feasibility of this measure due to uncertainties about the
specificity of the measure, it’s reliance on the use of CPT-II codes, the
relatively low reporting rate of the measure in the 2008 PQRI, and
reservations about capturing appropriate data elements in electronic
systems.
- Review for Usability: H-4; M-14; L-8; I-0(Meaningful,
understandable, and useful to the intended audiences for 3a. Public
Reporting/Accountability and 3b. Quality Improvement)Rationale: Developers
noted that the reporting rate submitted by the developer was based on all
physicians, and that specialists or those with few patients age 65 years or
older in their practice likely would not choose to report on this
measure.
- Endorsement Public Comments: Comments included:
- Commenters were concerned that this measure is a “check-box” measure and
will not have an effect on quality, outcomes, or cost.
- Suggested areas for improvement included specifying required elements
for the advance care plan, including a broader array of providers who could
be held accountable for, and empowered to, create and document such a plan
in the patient record, measuring whether the advance care plan was followed
and updated accordingly, and identifying and including patient preferences
in the advance care plan
- The measure represents a reasonable starting point but more development
is needed in this area
Developer Response:
- NCQA and AMA/PCPI agrees this measure is limited in the information it
captures. However, it is important to note that even as a limited measure,
performance (50% in 2010) demonstrates an important quality gap that needs
to be addressed. There are many tools which are available to physicians to
guide the advanced care planning discussion with patients and outline the
important elements which should be documented. The measure specification
provided by NCQA and AMA/PCPI on the AMA website lists several elements
which may be important to include or discuss in the advanced care planning
process. However, NCQA and AMA/PCPI believes the specific elements of an
advanced care plan are best decided on by the provider and patient.
- We appreciate this comment and wish to clarify that this measure does
not limit advanced care planning documentation to a physician.
- Regarding the comment that more development is needed in this area: NCQA
appreciates the suggestion and encourages the development of more measures
in this area.
Steering Committee Response: In their discussion of these comments, the
Committee remained somewhat divided on this measure. One member reiterated
concerns about the validity of the measure, and agreed with the commenters
that it is a check-the-box measure. However, other members stated that while
the measure, as specified, may not go far enough, it is better than nothing.
The Committee agreed to re-evaluate the measure after further reviewing the
measure specifications, notes from the in-person meeting, and comments. Upon
re-evaluation, the Committee again decided to recommend the measure.Vote
Following Consideration of Public and Member Comments:1. Importance to Measure
and Report (based on decision logic): Yes1a. Impact: H-12; M-4; L-2; I-0 1b.
Performance Gap: H-11; M-7; L-0; I-0 1c. Evidence: Y-12; N-1; I-52. Scientific
Acceptability of Measure Properties (based on decision logic): Yes2a.
Reliability: H-0; M-13; L-2; I-3 2b. Validity: H-0; M-11; L-4; I-3Usability:
H-5; M-9; L-2; I-2Feasibility: H-3; M-11; L-2; I-2Steering Committee
Recommendation on Overall Suitability for Endorsement: Y-13; N-5
Rationale: While the Committee acknowledged weaknesses with the measure, they
again noted the importance of the topic and encouraged developers to continue
to refine the measure.
- Endorsement Committee Recommendation: Y-18; N-8Rationale: Committee
members recommended this measure as suitable for endorsement at this time
because of the importance of the topic; however, the Committee strongly
expressed their desire for better measures of advanced care planning. CSAC
Review (July 12, 2012) Decision: Approved for continued endorsement
The CSAC, like the Steering Committee, was divided on the usefulness of
this measure. Some members reiterated concerns that the measure, as currently
specified, is a “check-the-box” measure that will not impact patient outcomes
while others considered the measure “a starting point” that is necessary
because currently the creation/discussion of an advance care plan is still far
from standard practice.,. Some CSAC members voiced the idea that not
recommending the measure might drive other developers to create a better, more
meaningful measure; others however, voiced the their belief that continued
endorsement would at least signal to providers that creation of an advance
care plan is an expected component of good quality care. Ultimately, the CSAC
voted 9 to 5 (with one abstention), to support the Steering Committee’s
recommendation for endorsement, noting that the measure should be considered
as one step on the way to a more progressive measure that incorporates such
aspects as patient and family understanding.
Board Review (August 8, 2012)Decision: Ratified for continued
endorsement
Summary of Workgroup Deliberations
- Workgroup Recommendation: Support
- Workgroup Rationale: Prevention of falls is a cross-cutting,
patient safety measure applicable to all Medicare patients. This NQF-endorsed
measure is aligned with PQRS.
- Public comments received: 7
Rationale for measure provided by HHS
Complications associated
with falls affect many patients.
Measure Specifications
- NQF Number (if applicable): 101
- Description: This is a clinical process measure that assesses falls
prevention in older adults. The measure has three rates: A) Screening for
Future Fall Risk: Percentage of patients aged 65 years of age and older who
were screened for future fall risk at least once within 12 months; B) Falls:
Risk Assessment: Percentage of patients aged 65 years of age and older with a
history of falls who had a risk assessment for falls completed within 12
months; C) Plan of Care for Falls: Percentage of patients aged 65 years of age
and older with a history of falls who had a plan of care for falls documented
within 12 months.
- Numerator: This measure has three rates. The numerators for the
three rates are as follows: A) Screening for Future Fall Risk: Patients who
were screened for future fall* risk** at last once within 12 months B) Falls:
Risk Assessment: Patients who had a risk assessment*** for falls completed
within 12 months C) Plan of Care for Falls: Patients with a plan of care****
for falls documented within 12 months. *A fall is defined as a sudden,
unintentional change in position causing an individual to land at a lower
level, on an object, the floor, or the ground, other than as a consequence of
a sudden onset of paralysis, epileptic seizure, or overwhelming external
force. **Risk of future falls is defined as having had had 2 or more falls in
the past year or any fall with injury in the past year. ***Risk assessment is
comprised of balance/gait assessment AND one or more of the following
assessments: postural blood pressure, vision, home fall hazards, and
documentation on whether medications are a contributing factor or not to falls
within the past 12 months. ****Plan of care must include consideration of
vitamin D supplementation AND balance, strength and gait
training.
- Denominator: A) Screening for Future Fall Risk: All patients aged
65 years and older. B & C) Risk Assessment for Falls & Plan of Care
for Falls: All patients aged 65 years and older with a history of falls
(history of falls is defined as 2 or more falls in the past year or any fall
with injury in the past year).
- Exclusions: Patients who have documentation of medical reason(s)
for not screening for future fall risk, undergoing a risk-assessment or having
a plan of care (e.g., patient is not ambulatory) are considered exclusions to
this measure.
- HHS NQS Priority: Making Care Safer
- HHS Data Source: Paper medical record
- Measure Type: Process
- Steward: National Committee for Quality Assurance
- Endorsement Status: Previously endorsed in 2007 and 2012, NQF #101
has been recommended for continued endorsement by the Patient Safety Standing
Committee in 2015.
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has not been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Patient Safety 2015
(Draft report available as of 9/17/2015)
- Review for Importance: The measure meets the Importance criteria
(1a. Evidence, 1b. Performance Gap) 1a. Evidence: 13-H; 8-M; 1-L; 0-I; 1b.
Performance Gap: 15-H; 6-M; 2-L; 0-I; Rationale: Evidence supported by the
USPSTF, the American Geriatric Society, the British Geriatric Society, and the
American Organization of Orthopedic Surgeons. However, there is more evidence
on plans of care than assessments of falls being links to lower fall rates. ·
The measure focuses on people who have fallen more than once or who have had
an injurious fall. · The reported rates demonstrate room for improvement as
well as disparities in performance.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria (2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity) 2a. Reliability: 11-H;
11-M; 1-L; 0-I 2b. Validity: 8-H; 14-M; 1-L; 0-I Rationale: · This is a
long-endorsed measure that is currently in use and the Committee had no
concerns regarding the reliability or validity. After the original
endorsement, additional reliability testing was performed in 2013 at the data
element level; the measure has undergone face validity testing. · Reliability
testing was done at the data element level. The denominators across all three
rates had a 100% rate. The numerators had kappa scores above 0.90. · For a
systematic assessment of face validity, the AMA-convened Physician Consortium
for Performance Improvement (PCPI) oversees the measure development process of
clinically relevant physician-level performance measures. The scale was used
1-5, where 1=Strongly Disagree; 2= Disagree; 3=Neither Disagree nor Agree; 4=
Agree; 5=Strongly Agree o Mean scores were: § Results for Future Fall
Risk:4.30 § Results for Risk Assessment for Falls: 4.39 § Plan of Care for
Falls: 4.35
- Review for Feasibility: 4-H; 17-M; 2-L; 0-I (Meaningful,
understandable, and useful to the intended audiences for 4a. Public
Reporting/Accountability and 4b. Quality Improvement) Rationale: · Through its
inclusion in PQRS, physicians who chose to report on this measure are paid for
reporting, not performance. However, the screening element of the measure is
also included in the GPRO program, which requires reporting and is beginning
to pay for performance; PQRS is expected to move towards being a penalty
program in the near future.
- Review for Usability: 7-H; 13-M; 2-L; 0-I (3a. Clinical data
generated during care delivery; 3b. Electronic sources; 3c.Susceptibility to
inaccuracies/ unintended consequences identified 3d. Data collection strategy
can be implemented) Rationale: · The measure is collected through
administrative claims, electronic claims, and paper medical records. Again, as
a long-standing measure, there were no concerns regarding
feasibility.
- Review for Related and Competing Measures: This measure is related
to 0035: Fall Risk Management (NCQA) and 0537: Multifactor Fall Risk
Assessment Conducted For All Patients Who Can Ambulate (CMS). There are no
competing measures.
- Endorsement Public Comments: Not yet available
- Endorsement Committee Recommendation: This measure was originally
endorsed in 2007 and re-endorsed in 2012. The measure includes three
indicators to be reported together across the continuum of care for fall
prevention, focusing on people who have fallen more than once or who have had
an injurious fall. The measure is based on recommendations from the US
Preventive Services Task Force and the American Geriatric Society; the
evidence is also supported by the British Geriatric Society and the American
Organization of Orthopedic Surgeons. This provider-level measure is currently
used in the PQRS program. Because of this measure’s evidence, important,
scientific validity, and long-standing use, the Committee agreed it meets the
criteria for NQF endorsement. Standing Committee Recommendation for
Endorsement: 22-Y; 1-N
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support
- Workgroup Rationale: Composite measures of evidence-based processes
and intermediate clinical outcomes combine multiple factors important to care
and address whether a patients is receiving all the evidence-based care they
receive. Most of the atherosclerotic disease measures enjoy high performance
individually, but the composite reveals that the results are not uniformly
high for individual patients. Opportunity for improvement exists which can
further reduce the risks of poor outcomes for patients and represents a
measure that promotes high performance. CMS recently removed PQRS #349
(NQF#0076) Optimal Vascular Care - an all-or-none-composite measure - because
it is duplicative of the Millions Hearts measures. MAP supports use of both a
composite measure as well as the individual measures for the Millions Hearts
campaign. This measure, MUC15-275 is a competing measure with PQRS #349
(NQF#0076) – both are all-or-none composite measures for ischemic vascular
disease. NQF will be evaluating both measures side-by-side in the upcoming
Cardiovascular - Phase 4 project. CONDITION: MAP conditionally supports this
measure pending the outcome of the NQF evaluation of both composite measures.
MAP supports inclusion of the composite measure that is considered
best-in-class by the NQF review.
- Public comments received: 5
Rationale for measure provided by HHS
There has been important
evidence from clinical trials that further supports and broadens the merits of
risk-reduction therapies for patients with established coronary and other
atherosclerotic vascular disease, including peripheral arterial disease,
atherosclerotic aortic disease, and carotid artery disease. References: Smith SC
Jr, Benjamin EJ, Bonow RO, Braun LT, Creager MA, Franklin BA, Gibbons RJ, Grundy
SM, Hiratzka LF, Jones DW, Lloyd-Jones DM, Minissian M, Mosca L, Peterson ED,
Sacco RL, Spertus J, Stein JH, Taubert KA. AHA/ACCF secondary prevention and
risk reduction therapy for patients with coronary and other atherosclerotic
vascular disease: 2013 ACC/AHA Guideline on the Treatment of Blood Cholesterol
to Reduce : Atherosclerotic Cardiovascular Risk in Adults: A Report of the
American College of Cardiology/American Heart Association Task Force on Practice
Guidelines-
http://circ.ahajournals.org/search?tocsectionid=ACC/AHA+Prevention+Guideline&sortspec=date&submit=Submit
AHA/ACC Guidelines for Preventing Heart Attack and Death in Patients With
Atherosclerotic Cardiovascular Disease: 2001 Update
http://content.onlinejacc.org/article.aspx?articleid=1127560 The All or None
(Composite) method was chosen because of the benefits it provides to both the
patient and the practitioner. First, this methodology more closely reflects the
interests and likely desires of the patient. With the data collected in one
score patients can easily look and see how their provider group is performing on
these criteria rather than trying to make sense of multiple scores on individual
measures. Second, this method represents a systems perspective emphasizing the
importance of optimal care through a patient's entire healthcare experience.
Third, this method gives a more sensitive scale for improvement. For those
organizations scoring high marks on individual measures, the All-or-None measure
will give room for benchmarks and additional improvements to be made.
Measure Specifications
- NQF Number (if applicable):
- Description: The IVD All-or-None Measure is one outcome measure
(optimal control). The measure contains four goals. All four goals within a
measure must be reached in order to meet that measure. The numerator for the
all-or-none measure should be collected from the organization's total IVD
denominator. All-or-None Outcome Measure (Optimal Control) - Using the IVD
denominator optimal results include: Most recent blood pressure measurement is
less than 140/90 mm Hg -- And Most recent tobacco status is Tobacco Free --
And Daily Aspirin or Other Antiplatelet Unless Contraindicated -- And Statin
Use
- Numerator: Most recent BP is less than 140/90 mm Hg And Most recent
tobacco status is Tobacco Free (NOTE: If there is No Documentation of Tobacco
Status the patient is not compliant for this measure) And Daily Aspirin or
Other Antiplatelet Unless Contraindicated And Statin Use
- Denominator: Patients with CAD or a CAD Risk-Equivalent Condition
18-75 years of age and alive as of the last day of the Measurement Period. A
minimum of two CAD or CAD Risk-Equivalent Condition coded office visits OR one
Acute Coronary Event (AMI, PCI, CABG) from a hospital visit and must be seen
by a PCP / Cardiologist for two office visits in 24 months and one office
visit in 12 months.
- Exclusions: History of Gastrointestinal Bleed or Intra-cranial
Bleed or documentation of active anticoagulant use during the MP for the
Aspirin/Other Anticoagulant component (numerator) of the measure. Inpatient
Stays, Emergency Room Visits, Urgent Care Visits, and Patient Self-Reported
BP’s (Home and Health Fair BP results) for the Blood Pressure Control
component (numerator) of the composite measure.
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Registry
- Measure Type: Composite
- Steward: Wisconsin Collaborative for Healthcare Quality
(WCHQ)
- Endorsement Status: The measure is under review by NQF’s
Cardiovascular Standing Committee. The Committee has deferred an endorsement
recommendation until the measure can be judged side-by-side with NQF #0076
Optimal Vascular Care measure from Minnesota Community
Measurement.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: This composite measure combines AHRQ's PQIs
individual measures for three acute conditions. MAP encourages continued
development of this composite with testing at the ACO level with the new
risk-adjustment model that includes co-morbidities. This composite measure for
population health encourages care coordination and efficient use of healthcare
services and is sensitive to dual eligible patients. This measure encourages
appropriate care of acute conditions in the ambulatory setting to avoid
hospitalization which is highly desirable for patients and families. However,
MAP raised concerns about the potential for promoting antibiotic overuse such
as overtreatment for aspiration pneumonia particularly in patients residing in
nursing homes and unnecessary treatment for asymptomatic bactiuria. MAP
questioned whether there could be interaction of this measure with the
hospital acquired condition(HACs)measures - the developer responded that the
present on admission codes used for these measures are excluded for the HACs.
CMS advised MAP that this composite is already used in the Physician Value
Modifier Program.
- Public comments received: 7
Rationale for measure provided by HHS
The Prevention Quality
Indicators (PQIs) are a set of measures that can be used with hospital inpatient
discharge data to identify quality of care for "ambulatory care sensitive
conditions." These are conditions for which good outpatient care can potentially
prevent the need for hospitalization or for which early intervention can prevent
complications or more severe disease. The PQIs are population based.
Measure Specifications
- NQF Number (if applicable):
- Description: PQI composite of acute conditions per 100,000
population, ages 18 years and older. Includes admissions with a principal
diagnosis of one of the following conditions: dehydration, bacterial
pneumonia, or urinary tract infection. (Includes PQIs 10, 11, and
12)
- Numerator: Discharges, for patients ages 18 years and older, that
meet the inclusion and exclusion rules for the numerator in any of the
following PQIs: • PQI #10 Dehydration Admission Rate • PQI #11 Bacterial
Pneumonia Admission Rate • PQI #12 Urinary Tract Infection Admission Rate
Discharges that meet the inclusion and exclusion rules for the numerator in
more than one of the above PQIs are counted only once in the composite
numerator.
- Denominator: Population ages 18 years and older in metropolitan
area or county. Discharges in the numerator are assigned to the denominator
based on the metropolitan area or county of the patient residence, not the
metropolitan area or county of the hospital where the discharge
occurred.
- Exclusions: See each component measure for exclusions.
http://www.qualityindicators.ahrq.gov/modules/PQI_TechSpec.aspx
- HHS NQS Priority: Effective Prevention and Treatment
- HHS Data Source: Claims
- Measure Type: Composite
- Steward: Agency for Healthcare Research & Quality
- Endorsement Status: The composite has not been submitted to NQF,
but all three component measures are NQF-endorsed as population-level measures
for geographic areas: PQI #10 Dehydration Admission Rate (NQF #280)• PQI #11
Bacterial Pneumonia Admission Rate (NQF #279)• PQI #12 Urinary Tract
Infection Admission Rate (NQF #281)
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: This composite measure combines AHRQ's PQI
individual measures for admissions for several chronic conditions. This
composite measure for population health encourages care coordination and
efficient use of healthcare services and is sensitive to dual eligible
patients. MAP encourages continued development and testing of this measure
with attention to applicability at the ACO level of analysis and the
risk-adjustment model under development. MAP suggests considering
sociodemographic factors also. CMS advised MAP that this composite is already
used in the Physician Value Modifier Program.
- Public comments received: 9
Rationale for measure provided by HHS
2 component measures already
in the program.
Measure Specifications
- NQF Number (if applicable):
- Description: PQI composite of chronic conditions per 100,000
population, ages 18 years and older. Includes admissions for one of the
following conditions: diabetes with short-term complications, diabetes with
long-term complications, uncontrolled diabetes without complications, diabetes
with lower-extremity amputation, chronic obstructive pulmonary disease,
asthma, hypertension, heart failure, or angina without a cardiac procedure.
(Includes PQIs 1, 3, 5, 7, 8, 13, 14, 15, and 16)
- Numerator: Discharges, for patients ages 18 years and older, that
meet the inclusion and exclusion rules for the numerator in any of the
following PQIs: • PQI #1 Diabetes Short-Term Complications Admission Rate •
PQI #3 Diabetes Long-Term Complications Admission Rate • PQI #5 Chronic
Obstructive Pulmonary Disease (COPD) or Asthma in Older Adults Admission Rate
• PQI #7 Hypertension Admission Rate • PQI #8 Heart Failure Admission Rate •
PQI #13 Angina Without Procedure Admission Rate • PQI #14 Uncontrolled
Diabetes Admission Rate • PQI #15 Asthma in Younger Adults Admission Rate •
PQI #16 Lower-Extremity Amputation among Patients with Diabetes Rate
Discharges that meet the inclusion and exclusion rules for the numerator in
more than one of the above PQIs are counted only once in the composite
numerator.
- Denominator: Population ages 18 years and older in metropolitan
area† or county. Discharges in the numerator are assigned to the denominator
based on the metropolitan area or county of the patient residence, not the
metropolitan area or county of the hospital where the discharge
occurred.
- Exclusions: See each component measure for exclusions.
http://www.qualityindicators.ahrq.gov/modules/PQI_TechSpec.aspx
- HHS NQS Priority: Best Practice of Healthy Living
- HHS Data Source: Claims
- Measure Type: Composite
- Steward: Agency for Healthcare Research & Quality
- Endorsement Status: This composite measure has not been submitted
to NQF. However, 7 of the measures are NQF-endorsed as population-level
measures for geographic areas:• PQI #1 Diabetes Short-Term Complications
Admission Rate (NQF #272)• PQI #3 Diabetes Long-Term Complications Admission
Rate (NQF #274)• PQI #5 Chronic Obstructive Pulmonary Disease (COPD) or Asthma
in Older Adults Admission Rate (NQF #275)• PQI #8 Heart Failure Admission Rate
(NQF #277)• PQI #14 Uncontrolled Diabetes Admission Rate (NQF #638) • PQI #15
Asthma in Younger Adults Admission Rate (NQF #283)• PQI #16 Lower-Extremity
Amputation among Patients with Diabetes Rate (NQF #285)In 2012 NQF removed
endorsement of two component measures: PQI #7 Hypertension Admission Rate This
measure only captures admissions with a primary diagnosis of hypertension.
Many admissions for uncontrolled hypertension are for AMI or stroke rather
than hypertension and are not captured in this measure. The Committee
questioned interpretation of results. Also the documentation from the
developer stated ” “Little evidence exists regarding the validity of this
indicator,” and “some of the variance in age-sex adjusted rates does not
reflect true differences in area performance.”. PQI #13 Angina Without
Procedure Admission Rate This measure is looking for inappropriate admissions
for angina - not over use of procedures. The measure implies that admission
for angina as long as it is accompanied by a procedure is appropriate – the
Committee thought this may encourage procedures. Also, coding has changed so
that many patients are coded as coronary artery disease rather than angina
which is a significant flaw in the measure.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF review
and endorsement, with a consideration for CDP standing committee to consider
the exclusions and risk-adjustment
- Workgroup Rationale: MAP advised that the measure of admissions and
emergency department visits for patients receiving outpatient chemotherapy
must undergo review and endorsement by NQF, with a consideration from the
consensus development process standing committee of the exclusions and
risk-adjustment methods when they are developed.
- Public comments received: 9
Rationale for measure provided by HHS
Cancer patients receiving
chemotherapy have much higher rates of admissions and ED use than other
patients. A study of 2007 commercial claims data for more than 14 million
patients found that cancer patients average one admission per year; 40 percent
of those admissions were chemotherapy related (Kolodziej et al. 2011). The
authors also found that cancer patients average approximately two ED visits per
year, about half of which were chemotherapy related. Common complications of
chemotherapy treatment include nausea, emesis, anemia, neutropenic fever,
diarrhea, dehydration, and pain (Burton et al. 2007; Crawford et al. 2004;
Groopman and Itri 2000; Osoba et al. 1997; Richardson and Dobish 2007; Stein et
al. 2010). Chemotherapy-related admissions and ED visits may be due to
outpatient chemotherapy patients having unmet needs and gaps in care, which, if
addressed, could reduce admissions and ED visits and increase patients’ quality
of life (Hassett et al. 2006; Mayer et al. 2011; McKenzie et al. 2011). Although
it is extremely unlikely that all admissions and ED visits related to
chemotherapy can be avoided by prevention and treatment of side effects and
complications, there is evidence and consensus among providers on ways to
prevent and treat each of the symptoms included in the numerator of this
measure. Measurement of admissions and ED visits for patients receiving
outpatient chemotherapy should encourage reporting facilities to take steps to
prevent and improve management of side effects and complications from treatment.
Poor performance on the measure would reflect high resource use and significant
consequences for patient/society due to poor quality; admissions and ED visits
are costly to payers and reduce quality of life for patients. Burton, A.W.,
G.J. Fanciullo, R.D. Beasley, and M.J. Fisch. “Chronic Pain in the Cancer
Survivor: A New Frontier”. Pain Medicine, vol. 8, 2007, pp. 189–198. Crawford,
J.C., D.C. Dale, and G.H. Lyman. “Chemotherapy-Induced Neutropenia.” Cancer,
vol. 15, 2004, pp. 228–237. Groopman, J.E., and L.M. Itri.
“Chemotherapy-Induced Anemia in Adults: Incidence and Treatment.” Journal of the
National Cancer Institute, vol. 91, 2000, pp. 1616–1634. Hassett, M.J., J.
O’Malley, J.R. Pakes, J.P. Newhouse, and C.C. Earle. “Frequency and Cost of
Chemotherapy-Related Serious Adverse Effects in a Population Sample of Women
with Breast Cancer.” Journal of the National Cancer Institute, vol. 98, no. 16,
2006, pp. 1108–1117. Kolodziej, M., J.R. Hoverman, J.S. Garey, J. Espirito, S.
Sheth, A. Ginsburg, M.A. Neubauer, D. Patt, B. Brooks, C. White, M. Sitarik, R.
Anderson, and R. Beveridge. “Benchmarks for Value in Cancer Care: An Analysis of
a Large Commercial Population.” Journal of Oncology Practice, vol. 7, 2011, pp.
301–306. Mayer, D.K., D. Travers, A. Wyss, A. Leak, A. Waller. “Why Do Patients
with Cancer Visit Emergency Departments? Results of a 2008 Population Study in
North Carolina.” Journal of Clinical Oncology, vol. 26, no. 19, 2011, pp.
2683–2688. McKenzie, H., L. Hayes, K. White, K. Cox, J. Fethney, M. Boughton,
and J. Dunn. “Chemotherapy Outpatients’ Unplanned Presentations to Hospital: A
Retrospective Study.” Support Care Cancer, vol. 19, 2011, pp. 963–969. Osoba,
D., B. Zee, D. Warr, J. Latreilee, L. Kaizer, and J. Pater. “Effect of
Postchemotherapy Nausea and Vomiting on Health-Related Quality of Life.” Support
Care Cancer, vol. 5, 1997, pp. 307–313. Richardson, G., and R. Dobish.
“Chemotherapy Induced Diarrhea.” Journal of Oncology Pharmacy Practice, vol. 13,
no.4, 2007, pp. 181–98. Stein, A., W. Voigt, and K. Jordan.
“Chemotherapy-Induced Diarrhea: Pathophysiology, Frequency, and Guideline-Based
Management.” Therapeutic Advances Medical Oncology, vol. 2, 2010, pp. 51–63.
Measure Specifications
- NQF Number (if applicable):
- Description: Measure estimates risk-adjusted rates of inpatient
admissions or emergency department (ED) visits for cancer patients >18
years of age with at least one of the following diagnoses—anemia, dehydration,
diarrhea, emesis, fever, nausea, neutropenia, pain, pneumonia, or
sepsis—within 30 days of hospital outpatient chemotherapy treatment. Two rates
are reported.
- Numerator: The outcomes for this measure are one or more inpatient
admissions or one or more emergency department (ED) visits for one of the
following diagnoses—anemia, dehydration, diarrhea, emesis, fever, nausea,
neutropenia, pain, pneumonia, or sepsis—within 30 days among cancer patients
receiving a hospital outpatient chemotherapy treatment. Qualifying diagnosis
on the admission or ED visit claim must be listed as (1) the primary diagnosis
or (2) a secondary diagnosis accompanied by a primary diagnosis of cancer.
Outcomes are identified separately for the inpatient and ED categories. A
patient can only qualify for an outcome once. Patients who experience both an
inpatient admission and an ED visit during the measurement period are counted
towards the inpatient admission outcome. Among those with no qualifying
inpatient admissions, qualifying ED visits will be counted. Outcome
Attribution: The outcome is attributed to the hospital outpatient facility
where the patient received chemotherapy treatment during the 30 days prior to
the outcome.
- Denominator: The measure cohort includes Medicare Fee-for-Service
(FFS) patients aged 18 years and older as of the start of the measurement
period with a diagnosis of any cancer (except leukemia) who received at least
one hospital outpatient chemotherapy treatment at the reporting facility
during the measurement period.
- Exclusions: 1) Patients with a diagnosis of leukemia at any time
during the measurement period. 2) Patients who were not enrolled in Medicare
FFS Parts A and B in the year prior to the first outpatient chemotherapy
treatment during the measurement period. 3) Patients who received chemotherapy
treatments for whom Medicare FFS Parts A and B enrollment is not maintained
for the 30-days following treatment for at least one chemotherapy treatment
during the measurement period.
- HHS NQS Priority: Communication and Care Coordination, Effective
Prevention and Treatment
- HHS Data Source: Claims
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF annual
update
- Workgroup Rationale: MAP conditionally supported this update to the
name of the measure from “reliability adjusted SIR” to “Adjusted Ranking
Metric (ARM),” pending NQF annual update. The continued use of this measure
will promote SSI prevention activities, which will lead to an improvement in
patient outcomes, reducing avoidable medical costs, patient morbidity and
mortality.
- Public comments received: 6
Rationale for measure provided by HHS
Affects large numbers,
Frequently performed procedures, A leading cause of morbidity/mortality, High
resource use, Severity of illness, Patient/societal consequences of poor
quality. SSIs estimated to account for 20% of all HAIs[1] 290,485 estimated
SSIs/yr[2] Estimated 8,205 deaths associated with SSIs each year[1] Estimated
11% of all deaths occurring in intensive care units are associated with SSIs[1]
$34,670 medical cost/SSI[2] Total >$10 billion attributable to SSI in U.S.
each year[2] Estimated additional 7-10 days of hospitalization for each SSI per
patient[1] [1] Klevens RM, Edwards JR, et al. Estimating healthcare-associated
infection and deaths in U.S. hospitals, 2002. Public Health Reports 2007;
122:160-166. [2] Scott, RD. The Direct Medical Costs of Healthcare-Associated
Infections in U.S. Hospitals and the Benefits of Prevention.
http://www.cdc.gov/ncidod/dhqp/pdf/Scott_CostPaper.pdf accessed April 12, 2010.
Measure Specifications
- NQF Number (if applicable): 753
- Description: Organ/space Surgical Site Infections (SSI) at the
primary incision site among adult patients at least 18 years of age undergoing
inpatient colon procedures and/or abdominal hysterectomies as reported through
the ACS-NSQIP or CDC NHSN. The measure yields separate SIRs for each
procedure. (The endorsed specifications of the measure are: Prototype
measure for the facility adjusted Standardized Infection Ratio (SIR) of deep
incisional and organ/space Surgical Site Infections (SSI) at the primary
incision site among adult patients aged >= 18 years as reported through the
ACS National Surgical Quality Improvement Program (ACS-NSQIP) or CDC National
Health and Safety Network (NHSN). Prototype also includes a systematic,
retrospective sampling of operative procedures in healthcare facilities. This
prototype measure is intended for time-limited use and is proposed as a first
step toward a more comprehensive SSI measure or set of SSI measures that
include additional surgical procedure categories and expanded SSI
risk-adjustment by procedure type. This single prototype measure is applied
to two operative procedures, colon surgeries and abdominal hysterectomies, and
the measure yields separate SIRs for each procedure.)
- Numerator: Deep incisional primary (DIP) and organ/space SSIs
during the 30-day postoperative period among patients at least 18 years of age
undergoing inpatient colon surgeries or abdominal hysterectomies. SSIs will be
identified before discharge from the hospital, upon readmission to the same
hospital, or during outpatient care or admission to another hospital
(post-discharge surveillance). Case accrual will be guided by sampling
algorithms as described below.
- Denominator: Using multivariable logistic regression models for
colon surgeries and abdominal hysterectomies, the expected number of SSIs is
obtained. These expected numbers are summed by facility and surgical procedure
and used as the denominator of this measure
- Exclusions: Persons under the age of 18, those having a procedure
performed on an outpatient basis, those with ASA Class VI (6) are
excluded.(The endorsed specifications of the measure are: Persons under the
age of 18, those having a procedure performed on an outpatient basis, those
with ASA Class VI (6) are excluded. In the NHSN, patients without primary
closure of the surgical incision are not considered eligible cases and are
excluded- the NSQIP will match this practice for this measure, although this
is not standard practice within the NSQIP.)
- HHS NQS Priority: Making Care Safer
- HHS Data Source: National Healthcare Safety Network
- Measure Type: Outcome
- Steward: Centers for Disease Control and Prevention
- Endorsement Status: Endorsed; MUC same as endorsed
version:Yes
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2012
- Project for Most Recent Endorsement Review: Patient Safety
Measures
- Review for Importance: The measure addresses a high impact area.
Each year, approximately 11 percent of all deaths in ICUs are associated with
SSIs, resulting in up to 20,000 deaths and $2 billion in additional costs.2
Moreover, evidence-based interventions have shown significant reductions in
SSI rates and improved health outcomes.
- Review for Scientific Acceptability: See CDP
Recommendation]
- Review for Feasibility: See CDP Recommendation]
- Review for Usability: See CDP Recommendation]
- Review for Related and Competing Measures: See CDP
Recommendation]
- Endorsement Committee Recommendation: The Steering Committee
discussed the newly-harmonized measure in a supplemental conference call,
reviewing the relevant changes, while also receiving clarification from the
developers on several issues. Committee members inquired as to why these two
particular measures had been chosen, and asked for clarification on the plan
for public reporting. The developer explained that the CMS IPPS requirements
released on August 1, 2011, call for abdominal hysterectomies and colon
surgeries to be reported by the CDC to CMS. The NHSN will serve as the single
reporting system for CMS-required reporting. However, facilities may choose
which calculations of performance on the measure can be accomplished using
either the NHSN or NSQIP data system. The measure developer acknowledged that
for hospitals participating in both systems, there could be duplication.The
Steering Committee questioned why both organ space and deep incisional
infections were included in the measure. The developer described the approach
as a long standing precedent and stated that superficial infections are
considered trivial events and therefore not included. However, organ space
infections that drain through the incisions are classified as deep incisional
infections. The combination of organ space and deep incisional infections are
considered a clinically coherent grouping. The Committee expressed their
appreciation for the developers’ efforts at harmonization, and agreed that the
measure continues to meet the four major evaluation criteria. The Steering
Committee recommended this measure for endorsement in a unanimous vote.This
outcome measure replaces NQF-endorsed measure #0299 (Surgical Site Infection
Rate) and addresses the National Priority area of
safety.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF annual
update
- Workgroup Rationale: MAP conditionally supported this measure,
which is already in the program and will continue to promote multi-drug
resistant organism prevention activities, such as CDI. CDC estimated that
107,700 infections occurred in United States acute care hospitals in 2011 (http://www.cdc.gov/hicpac/pubs.html).
Adherence to clinical guidelines has resulted in decreased rates of
infection.
- Public comments received: 8
Rationale for measure provided by HHS
Clostridium difficile is
responsible for a spectrum of C. difficile infections (CDI), including
uncomplicated diarrhea, pseudomembranous colitis, and toxic megacolon, which
can, in some instances lead to sepsis and even death. In recent years, a
previously unrecognized strain of C. difficile, with increased virulence and
high levels of antimicrobial resistance, has resulted in outbreaks in healthcare
facilities in the United States. Additionally, CDI has become more common in the
community setting, with increased risk in those with history of recent inpatient
stay in a healthcare facility. Significant increases in cost of inpatient care
have been seen in cases of CDI.
Measure Specifications
- NQF Number (if applicable): 1717
- Description: Standardized infection ratio (SIR) of hospital-onset
CDI Laboratory-identified events (LabID events) among all inpatients in the
facility, excluding well-baby nurseries and neonatal intensive care units
(NICUs). Additional metric added- Adjusted Ranking Metric also known as the
“reliability-adjusted SIR.” (The endorsed specifications of the measure
are: Standardized infection ratio (SIR) of hospital-onset CDI
Laboratory-identified events (LabID events) among all inpatients in the
facility, excluding well-baby nurseries and neonatal intensive care units
(NICUs))
- Numerator: Total number of observed hospital-onset CDI LabID events
among all inpatients in the facility, excluding well baby-nurseries and
NICUs
- Denominator: Total number of expected hospital-onset CDI LabID
events, calculated using the facility´s number of inpatient days, bed size,
affiliation with medical school, microbiological test used to identify C.
difficile, and community-onset CDI admission prevalence rate
- Exclusions: Data from patients who are not assigned to an inpatient
bed are excluded from the denominator counts, including outpatient clinic and
emergency department visits. Additionally, data from well-baby nurseries and
NICUs are excluded from the denominator count
- HHS NQS Priority: Making Care Safer
- HHS Data Source: National Healthcare Safety Network
- Measure Type: Outcome
- Steward: Centers for Disease Control and Prevention
- Endorsement Status: Endorsed; MUC same as endorsed
version:No
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has not been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2013
- Project for Most Recent Endorsement Review: Patient Safety –
Complications Endorsement Maintenance: Phase II
- Review for Importance: The measure meets the Importance
criteria(1a. High Impact: 1b. Performance Gap, 1c. Evidence)1a. Impact: H-15;
M-1; L-0; I-0 1b. Performance Gap: H-6; M-10; L-0; I-0 1c. Evidence: Y-16;
N-0Rationale:· This measure is important since concern about Clostridium
difficile Infection (CDI) has risen significantly in the medical community.
Rates of CDI are highest for patients in healthcare facilities and increase
with patient age.· In 2010, 715 facilities from 28 states monitored CDI events
in NHSN. A total of 20,803 HO CDI events were reported from 5,757,846
admissions and 28,279,284 patient-days. CDI incidence rates differed
significantly by facility teaching type, bed size, test type, and Community
Onset (CO) prevalence.· The measure is supported by clinical practice
guidelines from the Society for Healthcare Epidemiology or America (SHEA),
Infectious Disease Society of America (IDSA) and the CDC Healthcare infections
Control Practices Advisory Committee (HICPAC). By adhering to these guidelines
can decrease the rate of CDI transmission and infection.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria(2a. Reliability – precise specifications,
testing; 2b. Validity – testing, threats to validity)2a. Reliability: H-7;
M-9; L-0; I-0 2b. Validity: H-7; M-9; L-0; I-0Rationale:· The denominator time
window in 10,000 patient days was used to create an easily understandable time
period for measure calculations. The Committee expressed concern that the
number of infections may be low since the measure included a lengthy time
period. However, the developer explained that CDI was increasing and that
rates are reviewed annually, and that this is the standard way that CDI rates
are reported.· The time window is monthly reporting, with each facility
completing a reporting plan to that they are following infections.· Neonates
and babies less than one year of age are excluded from the measure since
whether an infection is present or whether they are carriers is not clear and
easy to differentiate.· More sensitive testing for CDI has become available,
through the use of Polymerase Chain Reaction (PCR), and is increasingly
available to facilities. Because PCR-based tests are more sensitive, it may
appear that facilities using PCR-based testing would have higher rates than
non-PCR based testing.· The Committee was satisfied with the Standardized
Infection Ratio (SIR) methodology and did not have concerns about the
measure’s validity or reliability.
- Review for Feasibility: H-10; M-6; L-0; I-0(4a. Clinical data
generated during care delivery; 4b. Electronic sources; 4c.Susceptibility to
inaccuracies/ unintended consequences identified 4d. Data collection strategy
can be implemented)Rationale:· The Committee noted that the use of antibiotics
to treat CDI could be susceptible to overuse and misuse. The developer
indicated that they will have an antimicrobial use and resistance model to
monitor this issue through NHSN, which will likely be ready in August
2013.
- Review for Usability: H-12; M-4; L-0; I-0(Meaningful,
understandable, and useful to the intended audiences for 3a. Public
Reporting/Accountability and 3b. Quality Improvement)Rationale: This measure
will be included in CMS´ Hospital Inpatient Quality Reporting (IQR) Program
for events identified starting in January 2013.
- Review for Related and Competing Measures: No related or competing
measures noted.
- Endorsement Public Comments:
Comments included: Standardized infection rates are not as meaningful to
consumers as the actual risk-adjusted rates of infection per admission.
Developer response: We appreciate the commenter’s feedback. The
standardized infection ratio (SIR) offers clear advantages to healthcare
consumers over infection rates as the summary metric for this measure. The SIR
produces a single risk-adjusted metric that can be further aggregated to the
state, regional, or national level, all while maintaining appropriate
comparisons between healthcare facilities. Further, observed-to-predicted
ratios, such as the SIR, are widely used in public reporting of healthcare
quality data. CDC, the Centers for Medicare and Medicaid Services, health
departments in many states, and Consumers Union all use the SIR to report HAI
data.
Committee response: The Committee was satisfied with the developer’s
response and reaffirmed its recommendation of measure 1717 as specified.
However, they suggested the developer consider reporting actual risk-adjusted
rates of infection per admission in the future. The Committee also recognized
the importance of measures that are meaningful to consumers and it was noted
as an area of future measure development in the draft report.
- Endorsement Committee Recommendation: Y-16; N-0 CSAC
Approved (November 7, 2012). Board Endorsed (December 13,
2012).
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF annual
update
- Workgroup Rationale: MAP conditionally supported this measure,
which is already in the program and will continue to promote multi-drug
resistant organism prevention activities, (http://www.cdc.gov/hicpac/pubs.html)
including MRSA, which will help improve patient outcomes including reduction
of avoidable costs, morbidity, and mortality.
- Public comments received: 6
Rationale for measure provided by HHS
Clinical guidelines for the
management of multidrug resistant organisms (MDROs), including MRSA, have been
published. Adherence to the recommendations in the guidelines can result in
decreased rates of MDRO transmission and infection. Decreasing rates of
infection will result in a lower SIR, which indicates improving performance.
Measure Specifications
- NQF Number (if applicable): 1716
- Description: Standardized infection ratio (SIR) of hospital-onset
unique blood source MRSA Laboratory identified events (LabID events) among all
inpatients in the facility
- Numerator: Total number of observed hospital-onset unique blood
source MRSA LabID events among all inpatients in the facility
- Denominator: Total number of expected hospital-onset unique blood
source MRSA LabID events, calculated using the facility´s number of inpatient
days, bed size, affiliation with medical school, and community-onset MRSA
bloodstream infection admission prevalence rate.
- Exclusions: Data from patients who are not assigned to an inpatient
bed are excluded from the denominator counts. These include outpatient clinic
and emergency department visits.
- HHS NQS Priority: Making Care Safer
- HHS Data Source: National Healthcare Safety Network
- Measure Type: Outcome
- Steward: Centers for Disease Control and Prevention
- Endorsement Status: Endorsed; MUC same as endorsed
version:No
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has not been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2013
- Project for Most Recent Endorsement Review: Patient Safety –
Complications Endorsement Maintenance: Phase II
- Review for Importance: The measure meets the Importance
criteria(1a. High Impact: 1b. Performance Gap, 1c. Evidence)1a. Impact: H-15;
M-1; L-0; I-0 1b. Performance Gap: H-10; M-6; L-0; I-0 1c. Evidence: Y-15;
N-1Rationale:· The measure is aimed at reducing infection rates.
Multidrug-Resistant Organisms (MDROs), including Methicillin-resistant
Staphylococcus aureus (MRSA), have been associated with increased mortality,
length of stay and cost. Additionally, 56.8% of all central line-associated
bloodstream infections reported to the National Healthcare Safety Network
(NHSN) in 2006-2007 caused by Staphylococcus aureus were MRSA.· In 2010, MRSA
bacteremia was monitored in 548 facilities from 29 states. A total of 1,078
Healthcare Facility-Onset (HO) MRSA bacteremia events were reported from
3,807,920 admissions and 17,427,005 patient-days. MRSA bacteremia incidence
rates differed significantly by teaching type and bed size.· Following the
2006 Healthcare Infection Control Practices and Advisory Committee (HICPAC)
guideline can be used to reduce the incidence and transmission of infections
with MDROs in healthcare facilities.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria(2a. Reliability – precise specifications,
testing; 2b. Validity – testing, threats to validity)2a. Reliability: H-7;
M-9; L-0; I-0 2b. Validity: H-7; M-9; L-0; I-0Rationale:· The measure examines
the hospital onset of MRSA that occurs more than three days after admission to
a facility. It counts patient days within the facility, which are collected
and entered by infection preventionists. Data are presented as a standardized
infection ratio and the denominator is measured in 1000 patient days.· The
Committee requested clarification on the CDC’s risk-adjustment methods, with
some questioning whether the measure could account for institutions with
higher concentrations of immune-compromised patients (e.g., cancer hospitals).
The CDC provided additional information on the variables included in the
Standardized Infection Ratio (SIR) for this measure.· The Committee was
satisfied with the SIR methodology and did not have concerns about the
measure’s validity or reliability.
- Review for Feasibility: H-10; M-6; L-0; I-0(4a. Clinical data
generated during care delivery; 4b. Electronic sources; 4c.Susceptibility to
inaccuracies/ unintended consequences identified 4d. Data collection strategy
can be implemented)Rationale:· Data are entered both manually and through an
automated system.· There was concern that lab tests confirming MRSA may not be
ordered by hospitals in order to artificially reduce the number of MRSA
infections reported. The developer thought this would be unlikely; however,
they stated that if they had an indication of this type of situation, they
could create another measure relating to the use of antimicrobials without
obtaining a culture as another method of capturing MRSA infections focused
exclusively treatment.
- Review for Usability: H-11; M-5; L-0; I-0(Meaningful,
understandable, and useful to the intended audiences for 3a. Public
Reporting/Accountability and 3b. Quality Improvement)Rationale: This measure
will be included in CMS´ Hospital Inpatient Quality Reporting (IQR) Program
for events identified starting in January 2013.
- Review for Related and Competing Measures: No related or competing
measures noted.
- Endorsement Public Comments:
Comments included: Standardized infection rates are not as meaningful to
consumers as the actual risk-adjusted rates of infection per admission.
Developer response: We appreciate the commenter’s feedback. The
standardized infection ratio (SIR) offers clear advantages to healthcare
consumers over infection rates as the summary metric for this measure. The SIR
produces a single risk-adjusted metric that can be further aggregated to the
state, regional, or national level, all while maintaining appropriate
comparisons between healthcare facilities. Further, observed-to-predicted
ratios, such as the SIR, are widely used in public reporting of healthcare
quality data. CDC, the Centers for Medicare and Medicaid Services, health
departments in many states, and Consumers Union all use the SIR to report HAI
data.
Committee response: The Committee was satisfied with the developer’s
response and reaffirmed its recommendation of measure 1716 as specified.
However, they suggested the developer consider reporting actual risk-adjusted
rates of infection per admission in the future. The Committee also recognized
the importance of measures that are meaningful to consumers and it was noted
as an area of future measure development in the draft report.
- Endorsement Committee Recommendation: Y-16; N-0 CSAC Approved
(November 7, 2012). Board Endorsed (December 13,
2012).
Summary of Workgroup Deliberations
- Workgroup Recommendation: Conditional support, pending NQF annual
update
- Workgroup Rationale: MAP conditionally supported this measure,
which will continue to promote effective coordination of care for oncology
patients by identifying normal tissue dose constraints for those who receive
radiation therapy treatments. Even though there is no specific data available,
the American College of Radiation Oncology has found that normal dose
constraints are not frequently included in the patient chart.
- Public comments received: 4
Rationale for measure provided by HHS
This measure is rated as
moderate by the measure developer. The quality of the body of evidence
supporting the guideline recommendation is summarized according to the National
Comprehensive Cancer Network (NCCN) categories of evidence and consensus as
being based on "lower-level evidence". Lower-level evidence is later described
as evidence that may include non-randomized trials; case series; or when other
data are lacking, the clinical experience of expert physicians. Although there
is no explicit statement regarding the overall consistency of results across
studies in the guidelines supporting the measure, the recommendation received
uniform NCCN consensus that the intervention is appropriate. The description of
the evidence review in the guideline did not address the overall quantity of
studies in the body of evidence. However, 330 articles are cited in NCCN´s
pancreatic adenocarcinoma guideline. 408 and 172 articles are cited in NCCN´S
non small cell lung cancer and small cell lung cancer guidelines, respectively.
A panel of experts with members from each of the NCCN Member Institutions
develops the NCCN Guidelines. Specialties that must be included on a particular
panel are identified before that panel is convened but also evolve as the
standard of care changes over time. This multidisciplinary representation varies
from panel to panel. The NCCN Guidelines Panel Chairs are charged with ensuring
that representatives of all treatment strategies are included. Many of the
panels also include a patient representative, especially when issues of
long-term care and patient preference are paramount in the panel´s
considerations.
Measure Specifications
- NQF Number (if applicable): 382
- Description: Percentage of patients, regardless of age, with a
diagnosis of breast, rectal, pancreatic or lung cancer receiving 3D conformal
radiation therapy who had documentation in medical record that radiation dose
limits to normal tissues were established prior to the initiation of a course
of 3D conformal radiation for a minimum of two tissues
- Numerator: Patients who had documentation in medical record that
radiation dose limits to normal tissues were established prior to the
initiation of a course of 3D conformal radiation for a minimum of two
tissues
- Denominator: All patients, regardless of age, with a diagnosis of
breast, rectal, pancreatic or lung cancer receiving conformal radiation
therapy
- Exclusions: None
- HHS NQS Priority: Communication and Care Coordination
- HHS Data Source: Administrative claims, Administrative clinical
data, Paper medical record, Record review
- Measure Type: Process
- Steward: ASTRO (American Society for Radiation
Oncology)
- Endorsement Status: Endorsed; MUC same as endorsed
version:Yes
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2012
- Project for Most Recent Endorsement Review: Cancer Endorsement
Maintenance 2011
- Review for Importance: The measure meets the Importance
criteria.(1a. High Impact; 1b. Performance Gap; 1c. Evidence)1a. Impact: H-12;
M-4; L-0; I-0; 1b. Performance Gap: H-2; M-12; L-2; I-0; 1c. Evidence: Y-14,
N-2, I-0Rationale:• The measure applies to lung and pancreatic cancer, with
lung especially being a prevalent cancer with high morbidity and mortality.
Radiation is a commonly used treatment.• There was evidence cited showing 89%
compliance with the PQRS measure, which highlights some, but not much room for
improvement. The Steering Committee considered this a “never event” and felt
compliance should be 100%.• The Steering Committee stated the importance of
calculating dose limits when giving radiation to a patient and noted that
there is evidence to support this practice.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria.(2a. Reliability – precise specifications,
testing; 2b. Validity – testing, threats to validity)2a. Reliability: H-11;
M-5; L-0; I-0; 2b. Validity: H-7; M-9; L-0; I-0Rationale:• The measure
contains specifications that allow for reliable ascertainment and data on
reliability.• The measure includes data on face validity from an expert
panel.
- Review for Feasibility: H-11; M-5; L-0; I-0(4a. Clinical data
generated during care process; 4b. Electronic data; 4c.Susceptibility to
inaccuracies/ unintended consequences identified 4d. Data collection strategy
can be implemented)Rationale:• The data elements are all feasibly extracted
from an EHR and generated during routine care delivery.
- Review for Usability: H-10; M-6; L-0; I-0(Meaningful,
understandable, and useful to the intended audiences for 3a. Public Reporting
and 3b. Quality Improvement)Rationale:• The measure has been successfully
implemented in PQRS.• The measure should be easily understood for public
reporting.
- Endorsement Public Comments: Comments included:• Commenters were
concerned that the measure only assesses standard practice that should be
occurring routinely.Developer Response:• Identifying normal tissue dose
constraints is an important step in the process of care for patients receiving
radiation therapy treatments with significant impact on outcomes including
reducing the toxic effects of radiation to normal tissues and subsequently
reducing the long term potential for late carcinogenesis and a second
malignancy, while delivering the desired dose distribution of radiation to
target tissue. Unfortunately, as indicated by performance rates for this
measure noted in the submission form, adherence remains suboptimal
demonstrating a significant opportunity to improve the care provided to cancer
patients.Steering Committee Response:• The Steering Committee agrees with the
developer’s response, which is in line with discussions that occurred at the
in-person meeting and on related conference calls.
- Endorsement Committee Recommendation: Y-16; N-0Rationale: The
Steering Committee noted that there is near universal concordance from an
expert panel, excellent reliability, usability, and feasibility, and the
target population comprises large numbers. There is no contradictory evidence
for the measure.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: The functional status measures are adaptations
of currently endorsed measures for the IRF population. MAP encouraged
continued development to ensure alignment across PAC settings, but also noted
there should be some caution in interpretation of measure results due to
patient differentiation between facilities.MAP also stressed the importance of
considering burden on providers when measures are considered for
implementation.
- Public comments received: 13
Rationale for measure provided by HHS
During a Skilled Nursing
Facility (SNF) stay, the goals of treatment include fostering the patient’s
ability to manage his or her daily activities so that the patient can complete
self-care and mobility activities as independently as possible and if feasible,
return to a safe, active and productive life in a community-based setting.
Previous research has found direct relationships between increased intense
therapy services and improved functional outcomes in the SNF setting. Jette et.
al (2005) found that higher physical and occupational therapy intensities were
associated with greater odds of improving by at least 1 stage in the mobility
and activities of daily living functional independence across each condition
including patients with stroke, orthopedic conditions, and cardiovascular and
pulmonary conditions. Similarly, a randomized control trial, of 26 SNF patients
compared higher intensity rehabilitation to the standard-of-care found greater
improvement for mobility activities including gait speed, longer walking
distances, and a trend for improvement for self-care activities as measured by
the Barthel index (Lenze et. al 2012). The mobility and self-care quality
measures will standardize the collection of functional status data, which can
improve communication when patients are transferred between providers. Most SNF
patients receive care in an acute care hospital prior to the SNF stay, and many
SNF patients receive care from another provider after the SNF stay. Use of
standardized clinical data to describe a patient´s status across providers can
facilitate communication across providers. In describing the importance of
functional status, the National Committee on Vital and Health Statistics
Subcommittee on Health (2001) noted, “Information on functional status is
becoming increasing essential for fostering healthy people and a healthy
population. Achieving optimal health and well-being for Americans requires an
understanding across the life space of the effects of people’s health conditions
on their ability to do basic activities and participate in life situations, in
other words, their functional status.” This quality measure will inform SNF
providers about opportunities to improve care in the area of function and
strengthen incentives for quality improvement related to patient function.
Jette, D. U., R. L. Warren, & C. Wirtalla. (2005). The relation between
therapy intensity and outcomes of rehabilitation in skilled nursing facilities.
Archives of Physical Medicine and Rehabilitation, 86 (3), 373-9. Lenze, E. J.,
Host, H. H., Hildebrand M. W., Morrow-Howell, N., Carpenter, B., Freedland, K.
E., … Binder, E, F. (2012). Enhanced medical rehabilitation increases therapy
intensity and engagement and improves functional outcomes in postacute
rehabilitation of older adults: a randomized-controlled trial. Journal of the
American Medical Directors Association. 13(8):708-12. National Committee on
Vital and Health Statistics Subcommittee on Health. Classifying and Reporting
Functional Status. 2001. Retrieved from http://www.ncvhs.hhs.gov/010617rp.pdf
Measure Specifications
- NQF Number (if applicable): 2634
- Description: This quality measure estimates the risk-adjusted mean
change in mobility score between admission and discharge among Skilled Nursing
Facility residents. (The endorsed specifications of the measure are: This
measure estimates the mean risk-adjusted mean change in mobility score between
admission and discharge for Inpatient Rehabilitation Facility (IRF) Medicare
patients.)
- Numerator: The measure does not have a simple form for the
numerator and denominator. This measure estimates the risk-adjusted change in
mobility score between admission and discharge among Skilled Nursing Facility
residents age 21 and older. The change in mobility score is calculated as the
difference between the discharge mobility score and the admission mobility
score. (The endorsed specifications of the measure are: The measure does
not have a simple form for the numerator and denominator. This measure
estimates the risk-adjusted change in mobility score between admission and
discharge among Inpatient Rehabilitation Facility (IRF) patients age 21 and
older. The change in mobility score is calculated as the difference between
the discharge mobility score and the admission mobility
score.)
- Denominator: Skilled Nursing Facility residents included in this
measure are at least 21 years of age, Medicare Fee-for-Service beneficiaries,
are not independent with all of the mobility activities at the time of
admission, and have complete stays.(The endorsed specifications of the
measure are: Inpatient Rehabilitation Facility patients included in this
measure are at least 21 years of age, Medicare beneficiaries, are not
independent with all of the mobility activities at the time of admission, and
have complete stays.)
- Exclusions: This quality measure has 8 exclusion criteria: 1.
Residents with incomplete stays 2. Residents who are independent with all
mobility activities at the time of admission 3. Residents with the following
medical conditions: coma; persistent vegetative state; complete tetraplegia;
locked-in syndrome; severe anoxic brain damage, cerebral edema, or compression
of brain 4. Residents younger than 21 years 5. Residents discharged to
hospice 6. residents who are not Medicare Fee-for-Service beneficiaries 7.
Residents in swing beds in critical access hospitals 8. Residents who do not
receive rehabilitation therapy services(The endorsed specifications of the
measure are: This quality measure has 5 exclusion criteria:1) Patients with
incomplete stays. Rationale: It can be challenging to gather accurate
discharge functional status data for patients who experience incomplete stays.
Patients with incomplete stays include patients who are unexpectedly
discharged to an acute care setting (Short-stay Acute Hospital, Critical
Access Hospital, Inpatient Psychiatric Facility, or Long-term Care Hospital)
because of a medical emergency; patients who die or leave an Inpatient
Rehabilitation Facility (IRF) against medical advice; and patients with a
length of stay less than 3 days. 2) Patients who are independent with all
mobility activities at the time of admission. Rationale: Patients who are
independent with CARE mobility items at the time of admission are assigned the
highest score on all the mobility items, and thus, would not be able to show
functional improvement on this same set of items at discharge. 3) Patients
with the following medical conditions: coma, persistent vegetative state;
complete tetraplegia; locked-in syndrome or severe anoxic brain damage,
cerebral edema or compression of brain.Rationale: These patients are excluded
because they may have limited or less predictable mobility improvement with
the selected mobility items.4) Patients younger than age 21.Rationale: There
is only limited evidence published about functional outcomes for individuals
younger than 21.5) Patients discharged to hospice.Rationale: Patient goals may
change during the IRF stay.6) Patients not covered by the Medicare
program.)
(New information provided by CMS on January 19,
2016) This quality measure has 8 exclusion criteria: 1. residents with
incomplete stays 2. residents who are independent with all mobility
activities at the time of admission 3. residents with the following medical
conditions: coma; persistent vegetative state; complete tetraplegia; locked-in
syndrome; severe anoxic brain damage, cerebral edema, or compression of brain
4. residents younger than 21 years 5. residents discharged to hospice 6.
residents who are not Medicare Fee-for-Service beneficiaries 7. Residents in
swing beds in critical access hospitals 8. Residents who do not receive
rehabilitation therapy services
- HHS NQS Priority: This quality measure has 8 exclusion criteria:
1. Residents with incomplete stays 2. Residents who are independent with all
mobility activities at the time of admission 3. Residents with the following
medical conditions: coma; persistent vegetative state; complete tetraplegia;
locked-in syndrome; severe anoxic brain damage, cerebral edema, or compression
of brain 4. Residents younger than 21 years 5. Residents discharged to
hospice 6. residents who are not Medicare Fee-for-Service beneficiaries 7.
Residents in swing beds in critical access hospitals 8. Residents who do not
receive rehabilitation therapy services(The endorsed specifications of the
measure are: This quality measure has 5 exclusion criteria:1) Patients with
incomplete stays. Rationale: It can be challenging to gather accurate
discharge functional status data for patients who experience incomplete stays.
Patients with incomplete stays include patients who are unexpectedly
discharged to an acute care setting (Short-stay Acute Hospital, Critical
Access Hospital, Inpatient Psychiatric Facility, or Long-term Care Hospital)
because of a medical emergency; patients who die or leave an Inpatient
Rehabilitation Facility (IRF) against medical advice; and patients with a
length of stay less than 3 days. 2) Patients who are independent with all
mobility activities at the time of admission. Rationale: Patients who are
independent with CARE mobility items at the time of admission are assigned the
highest score on all the mobility items, and thus, would not be able to show
functional improvement on this same set of items at discharge. 3) Patients
with the following medical conditions: coma, persistent vegetative state;
complete tetraplegia; locked-in syndrome or severe anoxic brain damage,
cerebral edema or compression of brain.Rationale: These patients are excluded
because they may have limited or less predictable mobility improvement with
the selected mobility items.4) Patients younger than age 21.Rationale: There
is only limited evidence published about functional outcomes for individuals
younger than 21.5) Patients discharged to hospice.Rationale: Patient goals may
change during the IRF stay.6) Patients not covered by the Medicare
program.)
(New information provided by CMS on January 19,
2016) This quality measure has 8 exclusion criteria: 1. residents with
incomplete stays 2. residents who are independent with all mobility
activities at the time of admission 3. residents with the following medical
conditions: coma; persistent vegetative state; complete tetraplegia; locked-in
syndrome; severe anoxic brain damage, cerebral edema, or compression of brain
4. residents younger than 21 years 5. residents discharged to hospice 6.
residents who are not Medicare Fee-for-Service beneficiaries 7. Residents in
swing beds in critical access hospitals 8. Residents who do not receive
rehabilitation therapy services
- HHS Data Source: CARE data
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Person- and
Family-Centered Care: Phase 2
- Review for Importance: The measure meets the Importance criteria
(1a. Evidence, 1b. Performance Gap, 1c. High Impact) 1a. Evidence: Y-13; N-0;
1b. Performance Gap: H-3; M-8; L-2; I-0; 1c. High Priority: H-7; M-6; L-0; I-0
Rationale:
- The developer noted that IRF measures are limited to Medicare only and
that the Long-Term Care Hospital Quality Reporting Program was established
as a Medicare program.
- The Committee highlighted that there are talks about these quality
measures becoming pay-for-performance measures; however, in IRFs there are
currently requirements for pay for performance such as a two-percent
reduction in payments for failure to submit certain quality data. The
Committee questioned the connection between these specific measures and
pay-for-performance measures. The developer clarified that the Inpatient
Rehabilitation Quality Reporting Program assigns a penalty for failure to
report, however it is not tied to a pay-for-performance
program.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria (2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity) 2a. Reliability: H-0;
M-10; L-0; I-3 2b. Validity: H-1; M-9; L-1; I-2 Rationale:
- The developers utilized different types of reliability including
Inter-rater reliability and patient videos reliability. Items that did not
test well during the PAC demo were not included. Test-retest reliability was
not performed due to the instability of the patients’ function.
- The Committee expressed concerns that reliability and validity data was
at the care level and not at the facility level; however, since this is an
outcome measure the Committee agreed that both reliability and validity
should be considered moderate.
- The developers confirmed that the data elements they are using in the
risk adjustment model and that the observed or expected calculation comes
from the assessment data and comorbidities from the claims
data.
- Review for Feasibility: H-6; M-5; L-2; I-0 (4a. Clinical data
generated during care delivery; 4b. Electronic sources; 4c.Susceptibility to
inaccuracies/ unintended consequences identified 4d. Data collection strategy
can be implemented) Rationale: The Committee questioned the length of time it
takes to administer or grade the instrument. The developer noted that
clinicians are assessing patients on the ability to complete the activities
listed in the measure.
- Review for Usability: H-6; M-5; L-0; I-2 (Meaningful,
understandable, and useful to the intended audiences for 3a. Public
Reporting/Accountability and 3b. Quality Improvement) Rationale: The
Committee had no concerns with the usability of the measure.
- Review for Related and Competing Measures:
- The Committee considered this measure to potentially compete with 2321:
Functional Change: Change in Mobility Score (UDSMR) and was asked to vote to
determine whether these measures are directly competing and select the best
in class measure. While the Committee agreed that these measures are
competing, they did not achieve consensus on whether one measure is
superior. Therefore, these measures will both continue on to NQF member vote
as recommended and be brought forward to the CSAC on June 9th for resolution
of the best-in-class decision.
- The Committee also considered this measure to be related to 2636:
Inpatient Rehabilitation Facility (IRF) Functional Outcome Measure:
Discharge Mobility Score for Medical Rehabilitation Patients (CMS), however
there were no recommendations for harmonization.
- Endorsement Public Comments: March 2, 2015- March 31, 2015
Comments received: Measures 2634 and 2636 received two similar comments.
The first commenter supported the underlying concept of the measures, stating
that inpatient rehabilitation facilities need to be measured on outcomes based
on functional improvement. However, the commenter suggested that an
alternative measure that determines how the provider improved the patient’s
life (mobility) would better incentivize a change in clinical practice and
associated patient-level outcomes as opposed to measure 2634 and measure 2636.
Another commenter concurred with the Committee’s concern with the validity and
reliability of measures developed using a cross-sectional study design from a
demonstration project, which did not follow the same patients across venues of
care and thus limiting applicability across sites.
NQF response: NQF is limited to reviewing measures that are submitted for
endorsement. We have added this suggestion to the measure gap list in the
report. Thank you for your comment.
Developer response: Thank you for your comment. As discussed during the
measure review on January 22, 2015 and documented in the Person- and
Family-Centered Care Phase 2 Draft Report on page 11, the Post-Acute Care
Payment Reform demonstration was a prospective cohort study, not a
cross-sectional study. In addition to collecting admission and discharge data
using the CARE Tool during the post-acute care stay, inpatient claims data for
acute care stays prior to and following the post-acute care stay were linked
to the CARE admission and discharge data. The reliability and validity of the
CARE function items were presented and discussed during the January 21-22,
2015 meeting, and several committee members referred to our analysis as very
good. We have also submitted provider-level reliability data to the committee
for review, as requested during the January 21-22, 2015 meeting. The Improving
Medicare Post Acute Care Transformation (IMPACT) Act directs the Secretary to
specify quality measures on which PAC providers are required to submit
standardized patient assessment data and other necessary data specified by the
Secretary with respect to five quality domains, one of which is functional
status, cognitive function, and changes in function and cognitive
function.
- Endorsement Committee Recommendation: Standing Committee
Recommendation for Endorsement: Y-11; N-2
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: The functional status measures are adaptations
of currently endorsed measures for the IRF population. MAP encouraged
continued development to ensure alignment across PAC settings, but also noted
there should be some caution in interpretation of measure results due to
patient differentiation between facilities.MAP also stressed the importance of
considering burden on providers when measures are considered for
implementation.
- Public comments received: 17
Rationale for measure provided by HHS
During a Skilled Nursing
Facility (SNF) stay, the goals of treatment include fostering the patient’s
ability to manage his or her daily activities so that the patient can complete
self-care and mobility activities as independently as possible and if feasible,
return to a safe, active and productive life in a community-based setting.
Previous research has found direct relationships between increased intense
therapy services and improved functional outcomes in the SNF setting. Jette et.
al (2005) found that higher physical and occupational therapy intensities were
associated with greater odds of improving by at least 1 stage in the mobility
and activities of daily living functional independence across each condition
including patients with stroke, orthopedic conditions, and cardiovascular and
pulmonary conditions. Similarly, a randomized control trial, of 26 SNF patients
compared higher intensity rehabilitation to the standard-of-care found greater
improvement for mobility activities including gait speed, longer walking
distances, and a trend for improvement for self-care activities as measured by
the Barthel index (Lenze et. al 2012). The mobility and self-care quality
measures will standardize the collection of functional status data, which can
improve communication when patients are transferred between providers. Most SNF
patients receive care in an acute care hospital prior to the SNF stay, and many
SNF patients receive care from another provider after the SNF stay. Use of
standardized clinical data to describe a patient´s status across providers can
facilitate communication across providers. In describing the importance of
functional status, the National Committee on Vital and Health Statistics
Subcommittee on Health (2001) noted, “Information on functional status is
becoming increasing essential for fostering healthy people and a healthy
population. Achieving optimal health and well-being for Americans requires an
understanding across the life space of the effects of people’s health conditions
on their ability to do basic activities and participate in life situations, in
other words, their functional status.” This quality measure will inform SNF
providers about opportunities to improve care in the area of function and
strengthen incentives for quality improvement related to patient function.
Jette, D. U., R. L. Warren, & C. Wirtalla. (2005). The relation between
therapy intensity and outcomes of rehabilitation in skilled nursing facilities.
Archives of Physical Medicine and Rehabilitation, 86 (3), 373-9. Lenze, E. J.,
Host, H. H., Hildebrand M. W., Morrow-Howell, N., Carpenter, B., Freedland, K.
E., … Binder, E, F. (2012). Enhanced medical rehabilitation increases therapy
intensity and engagement and improves functional outcomes in postacute
rehabilitation of older adults: a randomized-controlled trial. Journal of the
American Medical Directors Association. 13(8):708-12. National Committee on
Vital and Health Statistics Subcommittee on Health. Classifying and Reporting
Functional Status. 2001. Retrieved from http://www.ncvhs.hhs.gov/010617rp.pdf
Measure Specifications
- NQF Number (if applicable): 2633
- Description: This quality measure estimates the risk-adjusted mean
change in self-care score between admission and discharge among SNF residents.
(The endorsed specifications of the measure are: This measure estimates the
risk-adjusted mean change in self-care score between admission and discharge
for Inpatient Rehabilitation Facility (IRF) Medicare
patients.)
- Numerator: The measure does not have a simple form for the
numerator and denominator. This measure estimates the risk-adjusted change in
self-care score between admission and discharge among SNF residents age 21 and
older. The change in self-care score is calculated as the difference between
the discharge self-care score and the admission self-care score. (The
endorsed specifications of the measure are: The measure does not have a simple
form for the numerator and denominator. This measure estimates the
risk-adjusted change in self-care score between admission and discharge among
Inpatient Rehabilitation Facility (IRF) Medicare patients age 21 or older. The
change in self-care score is calculated as the difference between the
discharge self-care score and the admission self-care score.)
- Denominator: SNF residents included in this measure are at least 21
years of age, Medicare Fee-for-Service beneficiaries, are not independent with
all of the self-care activities at the time of admission, and have complete
stays.(The endorsed specifications of the measure are: Inpatient
Rehabilitation Facility patients included in this measure are at least 21
years of age, Medicare beneficiaries, are not independent on all of the
self-care activities at the time of admission, and have complete
stays.)
- Exclusions: This quality measure has 8 exclusion criteria: 1.
Residents with incomplete stays 2. Residents who are independent with all
self-care activities at the time of admission 3. Residents with the following
medical conditions: coma; persistent vegetative state; complete tetraplegia;
locked-in syndrome; severe anoxic brain damage, cerebral edema, or compression
of brain 4. Residents younger than 21 years 5. Residents discharged to
hospice 6. Residents who are not Medicare Fee-for-Service beneficiaries 7.
Residents in swing beds in critical access hospitals 8. Residents who do not
receive rehabilitation therapy services(The endorsed specifications of the
measure are: This quality measure has 6 exclusion criteria:1) Patients with
incomplete stays. Rationale: It can be challenging to gather accurate
discharge functional status data for patients who experience incomplete stays.
Patients with incomplete stays include patients who are unexpectedly
discharged to an acute care setting (Short-stay Acute Hospital, Critical
Access Hospital, Inpatient Psychiatric Facility, or Long-term Care Hospital),
because of a medical emergency; patients who die or leave an Inpatient
Rehabilitation Facility (IRF) against medical advice; patients discharged
directly to another IRF and patients with a length of stay less than 3 days.
2) Patients who are independent with all self-care activities at the time of
admission. Rationale: Patients who are independent with all the self-care
items at the time of admission are assigned the highest score on all the
self-care items, and thus, would not be able to show functional improvement on
this same set of items at discharge. 3) Patients with the following medical
conditions: coma; persistent vegetative state; complete tetraplegia; locked-in
syndrome; or severe anoxic brain damage, cerebral edema or compression of
brain.Rationale: These patients are excluded because they may have limited or
less predictable mobility improvement with the selected self-care items.4)
Patients younger than age 21.Rationale: There is only limited evidence
published about functional outcomes for children.5) Patients discharged to
hospice.Rationale: Patient goals may change during the IRF stay. 6) Patients
who are not Medicare beneficiaries.Patients not covered by the Medicare
program.)
- HHS NQS Priority: This quality measure has 8 exclusion criteria:
1. Residents with incomplete stays 2. Residents who are independent with all
self-care activities at the time of admission 3. Residents with the following
medical conditions: coma; persistent vegetative state; complete tetraplegia;
locked-in syndrome; severe anoxic brain damage, cerebral edema, or compression
of brain 4. Residents younger than 21 years 5. Residents discharged to
hospice 6. Residents who are not Medicare Fee-for-Service beneficiaries 7.
Residents in swing beds in critical access hospitals 8. Residents who do not
receive rehabilitation therapy services(The endorsed specifications of the
measure are: This quality measure has 6 exclusion criteria:1) Patients with
incomplete stays. Rationale: It can be challenging to gather accurate
discharge functional status data for patients who experience incomplete stays.
Patients with incomplete stays include patients who are unexpectedly
discharged to an acute care setting (Short-stay Acute Hospital, Critical
Access Hospital, Inpatient Psychiatric Facility, or Long-term Care Hospital),
because of a medical emergency; patients who die or leave an Inpatient
Rehabilitation Facility (IRF) against medical advice; patients discharged
directly to another IRF and patients with a length of stay less than 3 days.
2) Patients who are independent with all self-care activities at the time of
admission. Rationale: Patients who are independent with all the self-care
items at the time of admission are assigned the highest score on all the
self-care items, and thus, would not be able to show functional improvement on
this same set of items at discharge. 3) Patients with the following medical
conditions: coma; persistent vegetative state; complete tetraplegia; locked-in
syndrome; or severe anoxic brain damage, cerebral edema or compression of
brain.Rationale: These patients are excluded because they may have limited or
less predictable mobility improvement with the selected self-care items.4)
Patients younger than age 21.Rationale: There is only limited evidence
published about functional outcomes for children.5) Patients discharged to
hospice.Rationale: Patient goals may change during the IRF stay. 6) Patients
who are not Medicare beneficiaries.Patients not covered by the Medicare
program.)
- HHS Data Source: CARE Data
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Person- and
Family-Centered Care: Phase 2
- Review for Importance: The measure meets the Importance criteria
(1a. Evidence, 1b. Performance Gap, 1c. High Impact) 1a. Evidence: Y-15; N-1;
1b. Performance Gap: H-2; M-12; L-1; I-1; 1c. High Priority: H-9; M-6; L-1;
I-0 Rationale:
- The Committee noted that the measure is proposed for use for Medicare
only, and felt that this limits the use of the measure and potentially
introduces duplication of efforts if using multiple tools for differing
payer populations.
- The Committee requested clarification on the intent of the measure and
if it was a reflection of the care in the IRF or how the patient was prepare
for integration back into the community. Specifically, they wanted to know
if there is a connection between how a patient is doing at discharge and how
they will do in the community. The developer indicated that information was
provided in the supplemental information specific to the evidence behind the
measure. CMS further explained this is another attempt to standardize
measurement and allow tracking of patients as they traverse the care
continuum and between settings. The measures allow the comparison of uniform
assessment data, whether it’s self-care or mobility.
- The Committee asked for the reasoning behind the proposal of four
measures using essentially the same data. The developer indicated that when
testing understanding of the measures with consumers, they were led to
develop both a change score concept for use by facilities and then the
percentage of patients that achieve a certain status to improve consumer
understanding. They would have provided both in the same measure if the NQF
submissions allowed. There was a suggestion that these two pairs of measures
be considered “paired” measure to promote their use together. A member from
the rehabilitation community indicated he would find the information
provided from both levels of measurement useful. Internally they can be used
for the facility for quality improvement and externally for use with
consumers.
- The Committee requested clarification of the 6-point measure scale.
Based on input from an expert panel and comparison of current tools in use
for similar purposes, the scale proposed was deemed the best fit for
purpose. This became important because there is another tool in use by IRFs
– the FIM– that is required for payment and uses a different scale; members
indicated that facilities may find that confusing if there were different
requirements for different programs. CMS indicated that a determination has
not been made to convert to function items from the CARE Item Set
[tool].
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria (2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity) 2a. Reliability: H-0;
M-7; L-2; I-6 (consensus not reached) 2b. Validity: H-1; M-7; L-1; I-6
(consensus not reached) UPDATED VOTES FOR 2a. Reliability: H-5; M-10; L-3; I-0
2b. Validity: H-4; M-12; L-2; I-0 Rationale:
- As raised with previous measures, the Committee indicated a strong
interest in seeing scientific acceptability data at the facility level. A
member notes that Crohnbach alphas provided are at the patient level. The
developer indicated they could provide facility level error bars on splines
for consideration.
The Committee asked the developer to consider if it
would be more accurate to assess change in function between admission and
discharge versus coming up with an expected functional level and seeing if
it could be achieved. The assumption is that the comparison to an expected
score would be more game-able. The developer indicated they use every bit of
data they have available and the true intent of the percent of patients
measure is for consumer understandability.
- The Committee acknowledged the wealth of data provided on the
reliability and validity of the CARE tool. They continued to struggle with
lack of data at the facility level. The developer directed the Committee to
supplemental information they provided which may have come in after the
Committee reviewed each measure. Supplemental information included the
relationship between discharge scores and discharge back to the community
and between CARE scores and length of stay.
- The Committee noted that there was some data available, specifically
generalized estimation equation data that have splines and error bars, and
upon submission that data will be extremely helpful.
- NQF staff clarified that this is not a unique situation and as measures
become operationalized, more data becomes available and as this is a
standing committee, that data will come back to this committee for further
review. There is also the understanding that with the movement toward pay
for performance, Committees want more data and NQF is trying to work those
issues into the process.
- Review for Feasibility: H-4; M-8; L-3; I-0 (4a. Clinical data
generated during care delivery; 4b. Electronic sources; 4c.Susceptibility to
inaccuracies/ unintended consequences identified 4d. Data collection strategy
can be implemented) Rationale: The Committee had no questions or concerns on
the feasibility of this measure
- Review for Usability: H-3; M-7; L-3; I-2 (Meaningful,
understandable, and useful to the intended audiences for 3a. Public
Reporting/Accountability and 3b. Quality Improvement) Rationale: The
Committee had no questions or concerns on the use and usability of this
measure
- Review for Related and Competing Measures:
- The Committee considered this measure to potentially competes with 2286:
Functional Change: Change in Self-Care Score (UDSMR) and was asked to vote
on these measures. While the Committee agreed that these measures are
competing, the Committee did not achieve consensus on whether one measure is
superior. Therefore, these measures will go forward to NQF Member vote as
recommended and will be brought forward to the CSAC on June 9th for
resolution of the best in class decision.
- The Committee also considered this measure to be related to 2635:
Inpatient Rehabilitation Facility (IRF) Functional Outcome Measure:
Discharge Self-Care Score for Medical Rehabilitation Patients (CMS), however
there were no recommendations for harmonization.
- Endorsement Public Comments: March 2, 2015- March 31, 2015 Comments
received:
- One commenter noted that these are important measures but they need to
be analyzed and improved as additional data is collected. Another commenter
concurred with the Committee’s concern with the validity and reliability of
measures developed using a cross-sectional study design from a demonstration
project, which did not follow the same patients across venues of care and
thus limiting applicability across sites.
Committee response:
- The Committee requested additional information to allow for more
comprehensive evaluation of the consensus not reached and not recommended
measures. This additional information was discussed on the post-comment
committee call and the Committee had an opportunity to re-vote on the
applicable measures. This measure was recommended by the Committee after
reviewing the additional information and the comments.
Developer
response:
- Thank you for your comment. As discussed during the measure review on
January 22, 2015 and documented in the Person- and Family-Centered Care
Phase 2 Draft Report on page 11, the Post-Acute Care Payment Reform
demonstration was a prospective cohort study, not a cross-sectional study.
In addition to collecting admission and discharge data using the CARE Tool
during the post-acute care stay, inpatient claims data for acute care stays
prior to and following the post-acute care stay were linked to the CARE
admission and discharge data. The reliability and validity of the CARE
function items were presented and discussed during the January 21-22, 2015
meeting, and several committee members referred to our analysis as very
good. We have also submitted provider-level reliability data to the
committee for review, as requested during the January 21-22, 2015 meeting.
The Improving Medicare Post Acute Care Transformation (IMPACT) Act directs
the Secretary to specify quality measures on which PAC providers are
required to submit standardized patient assessment data and other necessary
data specified by the Secretary with respect to five quality domains, one of
which is functional status, cognitive function, and changes in function and
cognitive function.
- The Post-Acute Care Payment Reform Demonstration was a prospective
cohort study. It was not a cross-sectional study. For the study, data were
collected at admission and discharge for each patient in the study. In
addition, we collected interim assessment data for patients in the
cost-resource utilization segment of the study. As part of the study, we
also linked the CARE admission and discharge data with acute care and
post-acute care claims data in order to examine episodes of care and post
discharge readmissions. (B). The items and the summed self-care and mobility
scores are statistically significantly associated with several outcomes,
including length of stay and discharge destination. The admission IRF
self-care and IRF mobility scores were moderately correlated with length of
stay with coefficients of -0.463 (p < .0001) for self-care and -0.474 (p
< .001) for mobility. As expected, the summed self-care and mobility
discharge scores for patients who were discharged to home were significantly
different than the scores of patients discharged to a long-term care/nursing
home setting. The mean (standard deviation) discharge self-care score for
patients going home and to long-term care/nursing home were 34.29 (7.04) and
24.57 (9.39), respectively. For mobility, the mean (standard deviation)
scores were 57.35 (15.68) and 36.57 (15.07), respectively. The patients
going home had higher scores, indicating more function, as we expected. (C).
The CARE function items included in the 4 IRF quality measures and 2 LTCH
quality measures have undergone validity testing. In addition to the results
we present in our testing documentation, the data presented above (in 3b),
we examined the relationship between the current functional assessment items
and the CARE items for each PAC setting. The reports describing the testing
are available at:
http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Post-Acute-Care-Quality-Initiatives/CARE-Item-Set-and-B-CARE.html.
- Endorsement Committee Recommendation: Standing Committee
Recommendation for Endorsement: Y-10; N-5; Y-16;
N-2
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: The functional status measures are adaptations
of currently endorsed measures for the IRF population. MAP encouraged
continued development to ensure alignment across PAC settings, but also noted
there should be some caution in interpretation of measure results due to
patient differentiation between facilities.MAP also stressed the importance of
considering burden on providers when measures are considered for
implementation.
- Public comments received: 13
Rationale for measure provided by HHS
During a Skilled Nursing
Facility (SNF) stay, the goals of treatment include fostering the patient’s
ability to manage his or her daily activities so that the patient can complete
self-care and mobility activities as independently as possible and if feasible,
return to a safe, active and productive life in a community-based setting.
Previous research has found direct relationships between increased intense
therapy services and improved functional outcomes in the SNF setting. Jette et.
al (2005) found that higher physical and occupational therapy intensities were
associated with greater odds of improving by at least 1 stage in the mobility
and activities of daily living functional independence across each condition
including patients with stroke, orthopedic conditions, and cardiovascular and
pulmonary conditions. Similarly, a randomized control trial, of 26 SNF patients
compared higher intensity rehabilitation to the standard-of-care found greater
improvement for mobility activities including gait speed, longer walking
distances, and a trend for improvement for self-care activities as measured by
the Barthel index (Lenze et. al 2012). The mobility and self-care quality
measures will standardize the collection of functional status data, which can
improve communication when patients are transferred between providers. Most SNF
patients receive care in an acute care hospital prior to the SNF stay, and many
SNF patients receive care from another provider after the SNF stay. Use of
standardized clinical data to describe a patient´s status across providers can
facilitate communication across providers. In describing the importance of
functional status, the National Committee on Vital and Health Statistics
Subcommittee on Health (2001) noted, “Information on functional status is
becoming increasing essential for fostering healthy people and a healthy
population. Achieving optimal health and well-being for Americans requires an
understanding across the life space of the effects of people’s health conditions
on their ability to do basic activities and participate in life situations, in
other words, their functional status.” This quality measure will inform SNF
providers about opportunities to improve care in the area of function and
strengthen incentives for quality improvement related to patient function.
Jette, D. U., R. L. Warren, & C. Wirtalla. (2005). The relation between
therapy intensity and outcomes of rehabilitation in skilled nursing facilities.
Archives of Physical Medicine and Rehabilitation, 86 (3), 373-9. Lenze, E. J.,
Host, H. H., Hildebrand M. W., Morrow-Howell, N., Carpenter, B., Freedland, K.
E., … Binder, E, F. (2012). Enhanced medical rehabilitation increases therapy
intensity and engagement and improves functional outcomes in postacute
rehabilitation of older adults: a randomized-controlled trial. Journal of the
American Medical Directors Association. 13(8):708-12. National Committee on
Vital and Health Statistics Subcommittee on Health. Classifying and Reporting
Functional Status. 2001. Retrieved from http://www.ncvhs.hhs.gov/010617rp.pdf
Measure Specifications
- NQF Number (if applicable): 2636
- Description: This quality measure estimates the percentage of
Skilled Nursing Facility residents who meet or exceed an expected discharge
mobility score. (The endorsed specifications of the measure are: This
measure estimates the percentage IRF patients who meet or exceed an expected
discharge mobility score.)
- Numerator: The numerator is the number of residents in a Skilled
Nursing Facility with a discharge mobility score that is equal to or higher
than a calculated expected discharge mobility score. (The endorsed
specifications of the measure are: The numerator is the number of patients in
an IRF with a discharge mobility score that is equal to or higher than a
calculated expected discharge mobility score.)
- Denominator: Skilled Nursing Facility residents included in this
measure are at least 21 years of age, Medicare Fee-for-Service beneficiaries,
and have complete stays.(The endorsed specifications of the measure are:
IRF patients included in this measure are at least 21 years of age, Medicare
beneficiaries, and have complete stays.)
- Exclusions: This quality measure has 7 exclusion criteria: 1.
Residents with incomplete stays 2. Residents with the following medical
conditions: coma; persistent vegetative state; complete tetraplegia; locked-in
syndrome; or severe anoxic brain damage, cerebral edema, or compression of the
brain 3. Residents younger than age 21 4. Residents discharged to hospice
5. Residents not covered by the Medicare Fee-for-Service program 6. Residents
in swing beds in critical access hospitals 7. Residents who do not receive
rehabilitation therapy services(The endorsed specifications of the measure
are: This quality measure has 4 exclusion criteria:1) Patients with incomplete
stays. Rationale: It can be challenging to gather accurate discharge
functional status data for patients who experience incomplete stays. Patients
with incomplete stays include patients who are unexpectedly discharged to an
acute care setting (Short-stay Acute Hospital, Critical Access Hospital,
Inpatient Psychiatric Facility, or Long-term Care Hospital) because of a
medical emergency; patients who die or leave an Inpatient Rehabilitation
Facility (IRF) against medical advice; and patients with a length of stay less
than 3 days. 2) Patients with the following medical conditions on admission:
coma, persistent vegetative state, complete tetraplegia, locked-in syndrome,
or severe anoxic brain damage, cerebral edema or compression of
brain.Rationale: These patients are excluded because they may have limited or
less predictable mobility improvement with the selected items.3) Patients
younger than age 21.Rationale: There is only limited evidence published about
functional outcomes for individuals younger than 21.4) Patients discharged to
hospice.Rationale: Patient goals may change during the IRF stay. 5) Patients
who are not Medicare beneficiaries.)
(New information provided
by CMS on January 19, 2016) This quality measure has 7 exclusion criteria:
1. residents with incomplete stays 2. residents with the following medical
conditions: coma; persistent vegetative state; complete tetraplegia; locked-in
syndrome; or severe anoxic brain damage, cerebral edema, or compression of the
brain 3. residents younger than age 21 4. residents discharged to hospice
5. residents not covered by the Medicare Fee-for-Service program 6. Residents
in swing beds in critical access hospitals 7. Residents who do not receive
rehabilitation therapy services
- HHS NQS Priority: This quality measure has 7 exclusion criteria:
1. Residents with incomplete stays 2. Residents with the following medical
conditions: coma; persistent vegetative state; complete tetraplegia; locked-in
syndrome; or severe anoxic brain damage, cerebral edema, or compression of the
brain 3. Residents younger than age 21 4. Residents discharged to hospice
5. Residents not covered by the Medicare Fee-for-Service program 6. Residents
in swing beds in critical access hospitals 7. Residents who do not receive
rehabilitation therapy services(The endorsed specifications of the measure
are: This quality measure has 4 exclusion criteria:1) Patients with incomplete
stays. Rationale: It can be challenging to gather accurate discharge
functional status data for patients who experience incomplete stays. Patients
with incomplete stays include patients who are unexpectedly discharged to an
acute care setting (Short-stay Acute Hospital, Critical Access Hospital,
Inpatient Psychiatric Facility, or Long-term Care Hospital) because of a
medical emergency; patients who die or leave an Inpatient Rehabilitation
Facility (IRF) against medical advice; and patients with a length of stay less
than 3 days. 2) Patients with the following medical conditions on admission:
coma, persistent vegetative state, complete tetraplegia, locked-in syndrome,
or severe anoxic brain damage, cerebral edema or compression of
brain.Rationale: These patients are excluded because they may have limited or
less predictable mobility improvement with the selected items.3) Patients
younger than age 21.Rationale: There is only limited evidence published about
functional outcomes for individuals younger than 21.4) Patients discharged to
hospice.Rationale: Patient goals may change during the IRF stay. 5) Patients
who are not Medicare beneficiaries.)
(New information provided
by CMS on January 19, 2016) This quality measure has 7 exclusion criteria:
1. residents with incomplete stays 2. residents with the following medical
conditions: coma; persistent vegetative state; complete tetraplegia; locked-in
syndrome; or severe anoxic brain damage, cerebral edema, or compression of the
brain 3. residents younger than age 21 4. residents discharged to hospice
5. residents not covered by the Medicare Fee-for-Service program 6. Residents
in swing beds in critical access hospitals 7. Residents who do not receive
rehabilitation therapy services
- HHS Data Source: CARE data
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Person- and
Family-Centered Care: Phase 2
- Review for Importance: The measure meets the Importance criteria
(1a. Evidence, 1b. Performance Gap, 1c. High Impact) 1a. Evidence: Y-13; N-0;
1b. Performance Gap: H-3; M-8; L-2; I-0; 1c. High Priority: H-7; M-6; L-0; I-0
Rationale: The Committee highlighted that there are talks about these
quality measures becoming pay-for-performance measures; however, in IRFs there
are currently requirements for pay for reporting such as a two-percent
reduction in payments for failure to submit certain quality data. The
Committee questioned the connection between these specific measures and
pay-for-performance measures. The developer clarified that the Inpatient
Rehabilitation Quality Reporting Program assigns a penalty for failure to
report quality data however it is not tied to a pay-for-performance
program.
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria (2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity) 2a. Reliability: H-0;
M-10; L-0; I-3 2b. Validity: H-1; M-9; L-1; I-2
Rationale:
- The developers utilized different types of reliability including
inter-rater reliability and the use of video to assess clinician
assessments. Items that did not test well during the PAC demo were not
included. Test-retest reliability was not performed due to the instability
of the patients’ change in function.
- The Committee expressed concerns that reliability and validity data was
at the scale level and the not facility level. However, since this is an
outcome measure, the Committee agreed that both reliability and validity
should be considered moderate.
- The developers confirmed that the data elements they are using in the
risk adjustment model and the observed or expected calculation comes from
the other assessment data and comorbidities from the claims
data.
- Review for Feasibility: H-6; M-5; L-2; I-0 (4a. Clinical data
generated during care delivery; 4b. Electronic sources; 4c.Susceptibility to
inaccuracies/ unintended consequences identified 4d. Data collection strategy
can be implemented)
Rationale: The Committee questioned the length of time it takes to
administer or grade the instrument. The developer noted that clinicians are
assessing patients on the ability to complete the items activities listed in
the measure.
- Review for Usability: H-6; M-5; L-0; I-2 (Meaningful,
understandable, and useful to the intended audiences for 3a. Public
Reporting/Accountability and 3b. Quality Improvement)
Rationale: The developer noted that IRF measures are limited to Medicare
only and that the Long-Term Care Hospital Quality Reporting Program was
established as a Medicare program.
- Review for Related and Competing Measures: The Committee considered
this measure to be related to 2321: Functional Change: Change in Mobility
Score and 2634: Inpatient Rehabilitation Facility (IRF) Functional Outcome
Measure: Change in Mobility Score for Medical Rehabilitation Patients. however
there were no recommendations for harmonization.
- Endorsement Public Comments: March 2, 2015- March 31, 2015
Comments received: Measures 2634 and 2636 received two similar comments.
The first commenter supported the underlying concept of the measures, stating
that inpatient rehabilitation facilities need to be measured on outcomes based
on functional improvement. However, the commenter suggested that an
alternative measure that determines how the provider improved the patient’s
life (mobility) would better incentivize a change in clinical practice and
associated patient-level outcomes as opposed to measure 2634 and measure 2636.
Another commenter concurred with the Committee’s concern with the validity and
reliability of measures developed using a cross-sectional study design from a
demonstration project, which did not follow the same patients across venues of
care and thus limiting applicability across sites.
NQF response: NQF is limited to reviewing measures that are submitted for
endorsement. We have added this suggestion to the measure gap list in the
report. Thank you for your comment.
Developer response: Thank you for your comment. As discussed during the
measure review on January 22, 2015 and documented in the Person- and
Family-Centered Care Phase 2 Draft Report on page 11, the Post-Acute Care
Payment Reform demonstration was a prospective cohort study, not a
cross-sectional study. In addition to collecting admission and discharge data
using the CARE Tool during the post-acute care stay, inpatient claims data for
acute care stays prior to and following the post-acute care stay were linked
to the CARE admission and discharge data. The reliability and validity of the
CARE function items were presented and discussed during the January 21-22,
2015 meeting, and several committee members referred to our analysis as very
good. We have also submitted provider-level reliability data to the committee
for review, as requested during the January 21-22, 2015 meeting. The Improving
Medicare Post Acute Care Transformation (IMPACT) Act directs the Secretary to
specify quality measures on which PAC providers are required to submit
standardized patient assessment data and other necessary data specified by the
Secretary with respect to five quality domains, one of which is functional
status, cognitive function, and changes in function and cognitive
function.
- Endorsement Committee Recommendation: Standing Committee
Recommendation for Endorsement: Y-11; N-2
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: The functional status measures are adaptations
of currently endorsed measures for the IRF population. MAP encouraged
continued development to ensure alignment across PAC settings, but also noted
there should be some caution in interpretation of measure results due to
patient differentiation between facilities.MAP also stressed the importance of
considering burden on providers when measures are considered for
implementation.
- Public comments received: 13
Rationale for measure provided by HHS
During a Skilled Nursing
Facility (SNF) stay, the goals of treatment include fostering the patient’s
ability to manage his or her daily activities so that the patient can complete
self-care and mobility activities as independently as possible and if feasible,
return to a safe, active and productive life in a community-based setting.
Previous research has found direct relationships between increased intense
therapy services and improved functional outcomes in the SNF setting. Jette et.
al (2005) found that higher physical and occupational therapy intensities were
associated with greater odds of improving by at least 1 stage in the mobility
and activities of daily living functional independence across each condition
including patients with stroke, orthopedic conditions, and cardiovascular and
pulmonary conditions. Similarly, a randomized control trial, of 26 SNF patients
compared higher intensity rehabilitation to the standard-of-care found greater
improvement for mobility activities including gait speed, longer walking
distances, and a trend for improvement for self-care activities as measured by
the Barthel index (Lenze et. al 2012). The mobility and self-care quality
measures will standardize the collection of functional status data, which can
improve communication when patients are transferred between providers. Most SNF
patients receive care in an acute care hospital prior to the SNF stay, and many
SNF patients receive care from another provider after the SNF stay. Use of
standardized clinical data to describe a patient´s status across providers can
facilitate communication across providers. In describing the importance of
functional status, the National Committee on Vital and Health Statistics
Subcommittee on Health (2001) noted, “Information on functional status is
becoming increasing essential for fostering healthy people and a healthy
population. Achieving optimal health and well-being for Americans requires an
understanding across the life space of the effects of people’s health conditions
on their ability to do basic activities and participate in life situations, in
other words, their functional status.” This quality measure will inform SNF
providers about opportunities to improve care in the area of function and
strengthen incentives for quality improvement related to patient function.
Jette, D. U., R. L. Warren, & C. Wirtalla. (2005). The relation between
therapy intensity and outcomes of rehabilitation in skilled nursing facilities.
Archives of Physical Medicine and Rehabilitation, 86 (3), 373-9. Lenze, E. J.,
Host, H. H., Hildebrand M. W., Morrow-Howell, N., Carpenter, B., Freedland, K.
E., … Binder, E, F. (2012). Enhanced medical rehabilitation increases therapy
intensity and engagement and improves functional outcomes in postacute
rehabilitation of older adults: a randomized-controlled trial. Journal of the
American Medical Directors Association. 13(8):708-12. National Committee on
Vital and Health Statistics Subcommittee on Health. Classifying and Reporting
Functional Status. 2001. Retrieved from http://www.ncvhs.hhs.gov/010617rp.pdf
Measure Specifications
- NQF Number (if applicable): 2635
- Description: This quality measure estimates the percentage of
Skilled Nursing Facility residents who meet or exceed an expected discharge
self-care score. (The endorsed specifications of the measure are: This
measure estimates the percentage of IRF patients who meet or exceed an
expected discharge self-care score.)
- Numerator: The numerator is the number of residents in a Skilled
Nursing Facility with a discharge self-care score that is equal to or higher
than a calculated expected self-care mobility score. (The endorsed
specifications of the measure are: The numerator is the number of patients in
an IRF with a discharge score that is equal to or higher than the calculated
expected discharge score.)
- Denominator: Skilled Nursing Facility residents included in this
measure are at least 21 years of age, Medicare Fee-for-Service beneficiaries,
and have complete stays.(The endorsed specifications of the measure are:
Inpatient Rehabilitation Facility patients included in this measure are at
least 21 years of age, Medicare beneficiaries, and are not independent on all
of the self-care activities at the time of admission, and have complete
stays.)
- Exclusions: This quality measure has 7 exclusion criteria: 1.
Residents with incomplete stays. 2. Residents with the following medical
conditions: coma; persistent vegetative state; complete tetraplegia; locked-in
syndrome; or severe anoxic brain damage, cerebral edema, or compression of the
brain. 3. Residents younger than age 21 4. Residents discharged to hospice.
5. Residents not covered by the Medicare Fee-for-Service program. 6. Residents
in swing beds in critical access hospitals 7. Residents who do not receive
rehabilitation therapy services(The endorsed specifications of the measure
are: This quality measure has 5 exclusion criteria:1) Patients with incomplete
stays. Rationale: It can be challenging to gather accurate discharge
functional status data for patients who experience incomplete stays. Patients
with incomplete stays include patients who are unexpectedly discharged to an
acute care setting (Short-stay Acute Hospital, Critical Access Hospital,
Inpatient Psychiatric Facility, or Long-term Care Hospital), because of a
medical emergency; patients discharged to a hospice; patients discharged to
another IRF; patients who die or leave an Inpatient Rehabilitation Facility
(IRF) against medical advice; patients discharged directly to another IRF and
patients with a length of stay less than 3 days. 2) Patients with the
following medical conditions: coma; persistent vegetative state; complete
tetraplegia; locked-in syndrome; or severe anoxic brain damage, cerebral edema
or compression of the brain.Rationale: These patients are excluded because
they may have limited or less predictable self-care improvement with the
selected self-care items.3) Patients younger than age 21.Rationale: There is
only limited evidence published about functional outcomes for children.4)
Patients discharged to Hospice.Rationale: Patient goals may change during the
IRF stay.5) Patients not covered by the Medicare program.)
(New
information provided by CMS on January 19, 2016) This quality measure has
7 exclusion criteria: 1. residents with incomplete stays. 2. residents with
the following medical conditions: coma; persistent vegetative state; complete
tetraplegia; locked-in syndrome; or severe anoxic brain damage, cerebral
edema, or compression of the brain. 3. residents younger than age 21 4.
residents discharged to hospice. 5. residents not covered by the Medicare
Fee-for-Service program. 6. Residents in swing beds in critical access
hospitals 7. Residents who do not receive rehabilitation therapy
services
- HHS NQS Priority: This quality measure has 7 exclusion criteria:
1. Residents with incomplete stays. 2. Residents with the following medical
conditions: coma; persistent vegetative state; complete tetraplegia; locked-in
syndrome; or severe anoxic brain damage, cerebral edema, or compression of the
brain. 3. Residents younger than age 21 4. Residents discharged to hospice.
5. Residents not covered by the Medicare Fee-for-Service program. 6. Residents
in swing beds in critical access hospitals 7. Residents who do not receive
rehabilitation therapy services(The endorsed specifications of the measure
are: This quality measure has 5 exclusion criteria:1) Patients with incomplete
stays. Rationale: It can be challenging to gather accurate discharge
functional status data for patients who experience incomplete stays. Patients
with incomplete stays include patients who are unexpectedly discharged to an
acute care setting (Short-stay Acute Hospital, Critical Access Hospital,
Inpatient Psychiatric Facility, or Long-term Care Hospital), because of a
medical emergency; patients discharged to a hospice; patients discharged to
another IRF; patients who die or leave an Inpatient Rehabilitation Facility
(IRF) against medical advice; patients discharged directly to another IRF and
patients with a length of stay less than 3 days. 2) Patients with the
following medical conditions: coma; persistent vegetative state; complete
tetraplegia; locked-in syndrome; or severe anoxic brain damage, cerebral edema
or compression of the brain.Rationale: These patients are excluded because
they may have limited or less predictable self-care improvement with the
selected self-care items.3) Patients younger than age 21.Rationale: There is
only limited evidence published about functional outcomes for children.4)
Patients discharged to Hospice.Rationale: Patient goals may change during the
IRF stay.5) Patients not covered by the Medicare program.)
(New
information provided by CMS on January 19, 2016) This quality measure has
7 exclusion criteria: 1. residents with incomplete stays. 2. residents with
the following medical conditions: coma; persistent vegetative state; complete
tetraplegia; locked-in syndrome; or severe anoxic brain damage, cerebral
edema, or compression of the brain. 3. residents younger than age 21 4.
residents discharged to hospice. 5. residents not covered by the Medicare
Fee-for-Service program. 6. Residents in swing beds in critical access
hospitals 7. Residents who do not receive rehabilitation therapy
services
- HHS Data Source: CARE data
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2015
- Project for Most Recent Endorsement Review: Person- and
Family-Centered Care: Phase 2
- Review for Importance: The measure meets the Importance criteria
(1a. Evidence, 1b. Performance Gap, 1c. High Impact) 1a. Evidence: Y-15; N-1;
1b. Performance Gap: H-2; M-12; L-1; I-1; 1c. High Priority: H-9; M-6; L-1;
I-0
Rationale:
- The Committee noted that the measure is proposed for use for Medicare
only, and felt that this limits the use of the measure and potentially
introduces duplication of efforts if using multiple tools for differing
payer populations.
- The Committee requested clarification on the intent of the measure and
if it was a reflection of the care in the IRF or how the patient was
prepared for integration back into the community. Specifically, they wanted
to know if there is a connection between how a patient is doing at discharge
and how they will do in the community. The developer indicated that
information was provided in the supplemental information for the measure’s
evidence. CMS further explained this is another attempt to standardize
measurement and allow tracking of patients as they traverse the care
continuum and between settings. The measures allow the comparison of uniform
outcome measurement, whether it is self-care or mobility.
- The Committee asked for the reasoning behind the proposal of four
measures using essentially the same data. The developer explained that when
testing understanding of the measures with consumers, they were led to
develop both a change score concept for use by facilities, and then the
percentage of patients that achieve a certain status to improve consumer
understanding. They would have provided in the same measure if the NQF
submissions allowed. There was a suggestion that these two pairs of measures
be considered “paired” measure to promote their use together. A member from
the rehabilitation community indicated he would find the information
provided from both levels of measurement useful; it could be used internally
for the facility for quality improvement and externally with consumers.
- The Committee requested clarification of the 6-point measure scale.
Based on input from an expert panel and comparison of current tools in use
for similar purposes, the scale proposed was deemed the best fit for
purpose. This became important because there is another tool in use by IRFs
(the FIM) that is required for payment and uses a different scale; members
indicated that facilities may find that confusing if there were different
requirements for different programs. CMS indicated that a determination has
not been made to convert to the function items from the CARE item Set
[tool].
- Review for Scientific Acceptability: The measure meets the
Scientific Acceptability criteria (2a. Reliability - precise specifications,
testing; 2b. Validity - testing, threats to validity) 2a. Reliability: H-0;
M-7; L-2; I-6 (Consensus not reached) 2b. Validity: H-1; M-7; L-1; I-6
(consensus not reached) UPDATED VOTES FOR 2a. Reliability: H-5; M-11; L-2; I-0
2b. Validity: H-3; M-14; L-0; I-1
Rationale:
- As raised with previous measures, the Committee indicated a strong
interest in seeing scientific acceptability data at the facility level. A
member noted that Crohnbach alphas provided are at the patient level. The
developer indicated they could provide facility level error bars on splines
for consideration.
- The Committee asked the developer to consider if it would be more
accurate to assess change in function between admission and discharge versus
coming up with an expected functional level and seeing if it could be
achieved. The assumption is that the comparison to an expected score would
be more gameable. The developer indicated they use every bit of data they
have available and the true intent of the percent of patients measure is for
consumer understandability.
- The Committee acknowledged the wealth of data provided on the
reliability and validity of the CARE tool. They continued to struggle with
lack of data at the facility level. The developer directed the Committee to
supplemental information they provided which was submitted late and may have
come in after the Committee reviewed each measure. The supplemental
information included the relationship between discharge scores and discharge
back to the community and between CARE scores and length of stay.
- The Committee noted that there was some data available, specifically
generalized estimation equation data, that have splines and error bars, and
upon submission will be extremely helpful.
- NQF staff clarified that this is not a unique situation and as measures
become operationalized, more data becomes available and as a standing
committee, that data will come back for further review. There is also the
understanding that with the movement toward pay for performance, Committees
want more data and NQF is trying to work those issues into the
process.
- Review for Feasibility: H-4; M-8; L-3; I-0 (4a. Clinical data
generated during care delivery; 4b. Electronic sources; 4c.Susceptibility to
inaccuracies/ unintended consequences identified 4d. Data collection strategy
can be implemented)
Rationale: The Committee had no questions or concerns on the feasibility
of this measure
- Review for Usability: H-3; M-7; L-3; I-2 (Meaningful,
understandable, and useful to the intended audiences for 3a. Public
Reporting/Accountability and 3b. Quality Improvement) Rationale: The
Committee had no questions or concerns on the use and usability of this
measure
- Review for Related and Competing Measures: The Committee considered
this measure to be related to 2633: IRF Functional Outcome Measure: Discharge
Self-Care Score for Medical Rehabilitation Patients (CMS) and 2286: Functional
Change: Change in Self-Care Score (USDMR), however there were no
recommendations for harmonization.
- Endorsement Public Comments: March 2, 2015- March 31, 2015
Comments received: One commenter noted that these are important measures
but they need to be analyzed and improved as additional data is collected.
Another commenter concurred with the Committee’s concern with the validity and
reliability of measures developed using a cross-sectional study design from a
demonstration project, which did not follow the same patients across venues of
care and thus limiting applicability across sites.
Committee response: The Committee requested additional information to allow
for more comprehensive evaluation of the consensus not reached and not
recommended measures. This additional information was discussed on the
post-comment committee call and the Committee had an opportunity to re-vote on
the applicable measures. This measure was recommended by the Committee after
reviewing the additional information and the comments.
Developer response:
- Thank you for your comment. As discussed during the measure review on
January 22, 2015 and documented in the Person- and Family-Centered Care
Phase 2 Draft Report on page 11, the Post-Acute Care Payment Reform
demonstration was a prospective cohort study, not a cross-sectional study.
In addition to collecting admission and discharge data using the CARE Tool
during the post-acute care stay, inpatient claims data for acute care stays
prior to and following the post-acute care stay were linked to the CARE
admission and discharge data. The reliability and validity of the CARE
function items were presented and discussed during the January 21-22, 2015
meeting, and several committee members referred to our analysis as very
good. We have also submitted provider-level reliability data to the
committee for review, as requested during the January 21-22, 2015 meeting.
The Improving Medicare Post Acute Care Transformation (IMPACT) Act directs
the Secretary to specify quality measures on which PAC providers are
required to submit standardized patient assessment data and other necessary
data specified by the Secretary with respect to five quality domains, one of
which is functional status, cognitive function, and changes in function and
cognitive function.
- The Post-Acute Care Payment Reform Demonstration was a prospective
cohort study. It was not a cross-sectional study. For the study, data were
collected at admission and discharge for each patient in the study. In
addition, we collected interim assessment data for patients in the
cost-resource utilization segment of the study. As part of the study, we
also linked the CARE admission and discharge data with acute care and
post-acute care claims data in order to examine episodes of care and post
discharge readmissions. (B). The items and the summed self-care and mobility
scores are statistically significantly associated with several outcomes,
including length of stay and discharge destination. The admission IRF
self-care and IRF mobility scores were moderately correlated with length of
stay with coefficients of -0.463 (p < .0001) for self-care and -0.474 (p
< .001) for mobility. As expected, the summed self-care and mobility
discharge scores for patients who were discharged to home were significantly
different than the scores of patients discharged to a long-term care/nursing
home setting. The mean (standard deviation) discharge self-care score for
patients going home and to long-term care/nursing home were 34.29 (7.04) and
24.57 (9.39), respectively. For mobility, the mean (standard deviation)
scores were 57.35 (15.68) and 36.57 (15.07), respectively. The patients
going home had higher scores, indicating more function, as we expected. (C).
The CARE function items included in the 4 IRF quality measures and 2 LTCH
quality measures have undergone validity testing. In addition to the results
we present in our testing documentation, the data presented above (in 3b),
we examined the relationship between the current functional assessment items
and the CARE items for each PAC setting. The reports describing the testing
are available at:
http://www.cms.gov/Medicare/Quality-Initiatives-Patient-Assessment-Instruments/Post-Acute-Care-Quality-Initiatives/CARE-Item-Set-and-B-CARE.html.
- Endorsement Committee Recommendation: Standing Committee
Recommendation for Endorsement: Y-10; N-5; Y-17;
N-1
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP noted that available discharge codes and
coding practices could cause confusion about the results of this measure and
could also introduce validity concerns. MAP asked for greater clarity about
the intent of these measures, especially how they may impact patients and
consumers. MAP members raised concerns about the multiple ways that
readmissions are being measured and noted that a provider could potentially be
penalized multiple times for the same occurrence. MAP noted the need for
excluding patients who are admitted to hospice to prevent discouraging
discharges to hospice. MAP also noted that discharge to community can reflect
access to social support and the measure may need to reflect this. MAP
indicated the need for these measures to be submitted for NQF review and
endorsement to address psychometric concerns about the measures.MAP members
noted concerns about the risk adjustment of these measures, particularly for
the home health setting. MAP specifically noted the need to appropriately risk
adjust the measures to avoid unintended consequences.
- Public comments received: 14
Rationale for measure provided by HHS
The ultimate goals of
post-acute care are avoiding institutionalization and returning patients to
their previous level of independence and functioning, with discharge to
community being the primary goal for the majority of post-acute patients. For
many, home is a symbol of independence, privacy, and competence. Discharge to
community is considered a valuable outcome to measure because it is a
multifaceted measure that captures the patient’s functional status, cognitive
capacity, physical ability, and availability of social support at home. There
is considerable variation in discharge to community rates within and across
post-acute settings. Studies show geographic variation, variation across patient
socioeconomic characteristics (for example, race and ethnicity), and variation
by facility characteristics (for profit vs. nonprofit, freestanding vs.
hospital-based, urban vs. rural). In the IRF setting, discharge to community
rates vary across providers, ranging from about 60% to 75%. The 2015 MedPAC
report shows that, in FY 2013, the facility-level, mean risk-adjusted discharge
to community rate for IRFs within 100 days of admission was 75.8%, and the mean
observed rate was 74.7%. Discharge to community rates also vary widely in the
SNF setting, ranging from as low as 31% to as high as 65%. The 2015 MedPAC
report shows a mean risk-adjusted discharge to community rate of 37.5% for SNFs
within 100 days of admission, and mean observed rate of 40.1%. A multicenter
study of 23 LTCHs reported that only 28.8% of 1,061 patients who were
ventilator-dependent on admission were discharged to home or assisted living
facility. A study of 66,510 Medicare beneficiaries during pre- and post-HH
episodes, revealed that 64 percent of beneficiaries discharged from HH did not
use any other Medicare-reimbursed acute or post-acute services in the 30 days
following HH discharge. Significant numbers of patients were admitted to
inpatient facilities (29 percent) and lesser numbers to skilled nursing
facilities (7.6 percent), inpatient rehabilitation (1.5 percent) and home health
(7.2 percent) or hospice (3.3 percent) within 30 days of HH discharge (Wolff et
al., 2008).
Measure Specifications
- NQF Number (if applicable):
- Description: This measure describes the risk-standardized rate of
Medicare fee-for-service (FFS) patients/residents/persons who are discharged
to the community following a post-acute stay/episode, and do not have an
unplanned (re)admission to an acute care hospital or LTCH in the 31 days
following discharge to community, and remain alive during the 31 days
following discharge to community.
- Numerator: This measure does not have a simple form for the
numerator and denominator. The numerator is defined as the risk-adjusted
estimate of the number of patients/residents/persons included in the measure
who are discharged to the community, and do not have an unplanned
(re)admission to an acute care hospital or LTCH on the day of discharge or in
the 31 days following discharge to community, and remain alive during the 31
days following discharge to community. The numerator estimate includes risk
adjustment for patient/resident/person characteristics, and a statistical
estimate of the facility/agency effect beyond case mix.
- Denominator: The denominator is computed with the same model used
for the numerator. It is the model developed using all non-excluded
facility/agency stays/episodes in the national data. The measure includes all
facility/agency stays/episodes in the measurement period that are observed in
national Medicare FFS data and do not fall into an excluded category. For a
particular facility/agency, the model is applied to the
patient/resident/person population, but the facility/agency effect term is 0.
In essence, it is the number of discharges to community that would be expected
for that patient/resident/person population at the average
facility/agency.
- Exclusions: i) Age under 18 years; (ii) No short-term acute care
stay within 30 days prior to SNF admission; (iii) Discharges to psychiatric
hospital; (iv) Discharges against medical advice; (v) Discharges to federal
hospitals or disaster alternative care sites;; (vi) Patients not continuously
enrolled in Part A FFS Medicare for the 12 months prior to the SNF admission
date, and at least 31 days after SNF discharge date; (vii) Patients whose
prior short-term acute-care stay was for non-surgical treatment of cancer;
(viii) Discharges to hospice; (ix) SNF stays that end in transfer to another
SNF; (x) SNF stays with claims data that are problematic (e.g., anomalous
records for stays that overlap wholly or in part, or are otherwise erroneous
or contradictory); (xi) Patients who received care from a provider located
outside of the US, Puerto Rico, or a US territory..
- HHS NQS Priority: i) Age under 18 years; (ii) No short-term acute
care stay within 30 days prior to SNF admission; (iii) Discharges to
psychiatric hospital; (iv) Discharges against medical advice; (v) Discharges
to federal hospitals or disaster alternative care sites;; (vi) Patients not
continuously enrolled in Part A FFS Medicare for the 12 months prior to the
SNF admission date, and at least 31 days after SNF discharge date; (vii)
Patients whose prior short-term acute-care stay was for non-surgical treatment
of cancer; (viii) Discharges to hospice; (ix) SNF stays that end in transfer
to another SNF; (x) SNF stays with claims data that are problematic (e.g.,
anomalous records for stays that overlap wholly or in part, or are otherwise
erroneous or contradictory); (xi) Patients who received care from a provider
located outside of the US, Puerto Rico, or a US territory..
- HHS Data Source: Claims
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP noted the importance of medication
reconciliation but raised concerns and asked for greater clarity about the
definition of reconciliation versus drug regimen review. Members also noted
the challenge of defining some of the measure components, specifically “a
clinically significant issue” given the large number of medications a patient
may be taking. MAP stressed that medication reconciliation is a step in a drug
regimen review and asked for greater clarity on defining the drug regimen
review process. MAP stressed the importance of conducting a complete
medication review from all sites of care, including the home. MAP members
noted the value of the role of family caregivers in providing this information
and the hope that technology can help to minimize the burden of getting this
information. MAP members asked for greater emphasis of the inclusion of
non-prescription medication (including supplements), noting that this is a
particular concern in the PAC/LTC population.MAP members raised some concerns
about the feasibility of this measure and noted the need to clarify the roles
of the interdisciplinary team. MAP noted the importance of attribution issues
for this measure. Additionally, Workgroup members raised concerns about the
challenges of competing guidelines and need for greater clarity about when a
medication can be withdrawn. MAP stressed that medication reconciliation needs
to be an on-going process. MAP also noted that this is a particular concern
for dual-eligible beneficiaries.
- Public comments received: 11
Rationale for measure provided by HHS
Medication review in
post-acute care is generally considered to include medication reconciliation for
all medications and medication review for what poses as potential clinically
significant medication issues for the patient/resident. As a process measure,
medication reconciliation and medication review for potential clinically
significant medication issues are expected to reduce re-hospitalizations, reduce
adverse events related to medications and improve health outcomes.
(New information provided by CMS on January 19, 2016) Medication
review in post-acute care is generally considered to include medication
reconciliation and drug regimen review for all medications and for what poses as
potential clinically significant medication issues for the patient/resident. As
a process measure, medication reconciliation and drug regimen review for
potential clinically significant medication issues are expected to reduce
re-hospitalizations, reduce adverse events related to medications and improve
health outcomes.
Measure Specifications
- NQF Number (if applicable):
- Description: Percentage of stays Inpatient Rehabilitation Facility
(IRF), Long Term Care Facility (LTCH), and Skilled Nursing Facility (SNF) or
care episodes Home Health (HH) in which a drug regimen review was conducted at
the Admission (IRF, LTCH or SNF)/ Start of Care (SOC)/ Resumption of Care
(ROC) (HH) and timely follow-up with a physician occurred each time potential
clinically significant medication issues were identified throughout the stay
(IRF, LTCH, or SNF) or care episode (HH).
- Numerator: Number of stays or care episodes where the medical
record contains documentation of a drug regimen review conducted at admission
or start-of-care or resumption-of-care with all potential clinically
significant medication issues identified during the course of care and
followed-up with a physician or physician designee.
- Denominator: Care episodes or stays ending during the reporting
period. Assessment timing is as follows: Beginning of care
episode or stay: • HH – SOC or ROC • SNF – Admission • IRF - Admission • LTCH
– Admission End of care episode or stay: • HH – Transfer, Discharge, or
Death at Home • SNF – Discharge, or expired • IRF – Discharge, or expired •
LTCH – Discharge, or expired
- Exclusions: Denominator Exclusion: NONE Numerator Exclusion:
NONE
- HHS NQS Priority: Denominator Exclusion: NONE Numerator Exclusion:
NONE
(New information provided by CMS on January 19, 2016)
Denominator Exclusion: NONE Numerator Exclusion: NONE
- HHS Data Source: Patient Assessment Data - the Minimum Data Set
(MDS)
- Measure Type: Process
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Members noted the importance of balancing cost
measures with quality and access. Although the MAP encouraged continued
development, they did note concerns about the potential for unintended
consequences. The group also raised concerns about the impact on rural
providers. Additionally, MAP raised concerns that measuring acute and
post-acute care separately could discourage innovative partnerships between
hospitals and PAC/LTC providers.
- Public comments received: 10
Rationale for measure provided by HHS
Medicare payments to PAC
have grown at a consistently higher rate than other major Medicare sectors.
Between 2001 and 2013, Medicare PAC spending grew at an annual rate of 6.1
percent and doubled to $59.4 billion.
Measure Specifications
- NQF Number (if applicable):
- Description: The MSPB-PAC Measure for SNFs evaluates providers’
efficiency relative to the efficiency of the national median SNF provider.
Specifically, the MSPB-PAC Measure assesses the cost to Medicare for services
during an episode of care, which consists of a treatment period and an
associated services period. The episode is triggered by an admission to a SNF
stay. The treatment period begins at the trigger and ends at discharge. The
associated services period begins at the trigger and ends 30 days after the
end of the treatment period (i.e., discharge). These periods constitute the
episode window during which beneficiaries’ Medicare services are counted
toward the episode. The MSPB-PAC episode includes all services during the
episode window that are attributable to the SNF provider and those rendered by
other providers, except those services during the associated services period
that are clinically unrelated to SNF responsibilities (e.g., planned care and
routine screening).
- Numerator: The numerator is the attributed provider’s average
MSPB-PAC Amount. The MSPB-PAC Amount for each SNF provider depends on two
factors: i) the average of the ratio of standardized episode spending level
and expected episode spending for each SNF provider; and ii) the average
standardized episode spending across all SNF providers. To calculate the
MSPB-PAC Amount for each SNF, one finds the average of the ratio of the
standardized episode spending over the expected episode spending, and then
multiplies this quantity by the average episode spending level across all
SNFs.
- Denominator: The denominator for a SNF’s MSPB-PAC Measure is the
weighted median MSPB-PAC Amount across all episodes for SNFs nationally.
- Exclusions: The measure excludes the following episodes: • Any
episode that is triggered by an SNF stay that happens outside the 50 states or
DC. • Any episode that is triggered by an SNF stay for which we see Part C
crossover claims. • Any episode for which standard allowed amount of the SNF
stay could not be calculated or is equal to 0. • Any episode in which a
beneficiary is not enrolled in Medicare Fee-for-Service for the entirety of
the lookback period plus the episode window or is enrolled in Part C for any
part of the lookback plus episode window. • Any episode in which a beneficiary
has a primary payer other than Medicare for any part of the lookback plus
episode window. • Any episode for which the lookback period extends beyond our
observation period.
- HHS NQS Priority: The measure excludes the following episodes: •
Any episode that is triggered by an SNF stay that happens outside the 50
states or DC. • Any episode that is triggered by an SNF stay for which we see
Part C crossover claims. • Any episode for which standard allowed amount of
the SNF stay could not be calculated or is equal to 0. • Any episode in which
a beneficiary is not enrolled in Medicare Fee-for-Service for the entirety of
the lookback period plus the episode window or is enrolled in Part C for any
part of the lookback plus episode window. • Any episode in which a beneficiary
has a primary payer other than Medicare for any part of the lookback plus
episode window. • Any episode for which the lookback period extends beyond our
observation period.
- HHS Data Source: Claims
- Measure Type: Cost/Resource Use
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Although MAP encouraged continued development,
members noted concerns about the behavioral health population and recommended
that bipolar disorder be added to the exclusions.
- Public comments received: 5
Rationale for measure provided by HHS
Antipsychotic medications
can be potentially dangerous for the elderly, especially for those who do not
have the clinical indication. Of particular concern is the off-label use of
these drugs for elders with dementia or dementia-related psychoses or agitation
(Jeste et al., 2008). In April 2005, the FDA issued a black box warning against
prescribing atypical antipsychotic medications for elderly with dementia
(Rosack, 2005). The evidence on which the black box warning was based came from
a meta-analysis of data from 17 randomized trials with a total of 5,106 patients
which identified an “approximately 1.6- to 1.7-fold increase in mortality in the
combined studies” (Rosack, 2005). In June 2008, the FDA extended the warning to
all categories of antipsychotic drugs, conventional as well as atypical (Rosack,
2005). In this warning, the FDA advised health care professionals,
"Antipsychotics are not indicated for the treatment of dementia-related
psychosis." Besides elevated mortality risk, clinical trials of atypical
antipsychotic medications also show elevated risk for serious adverse events
including falls, somnolence and abnormal gait (Rosack, 2005; FDA, 2008; Ballard
& Margallo-Lana, 2004; Martin et al., 2003; Neil, Curran, and Wattis, 2003;
Doody et al., 2001; Jackson-Siegal, 2004). Additionally, there is evidence of
increased risk for cerebrovascular adverse events associated with certain
atypical antipsychotic medications (e.g., risperidone, olanzapine, and
aripiprazole) (Jeste et al., 2008). While the black box warnings applied to all
antipsychotic medications, a recent study identified some differences in
mortality risk by medication and dose among a large population based cohort of
dually-eligible nursing home residents prescribed antipsychotic medications
(Huybrechts et al., 2012). In addition to being a threat to patient safety,
antipsychotic medications are also expensive to consumers and Medicare. Atypical
antipsychotic drugs cost more than $13 billion in 2007, "nearly 5 percent of all
U.S. drug expenditures" (Alexander et al., 2011). They are also responsible for
a significant portion of expenditures for Medicare Part D (Doody et al., 2001).
Furthermore, the OIG report found that 51% of Medicare atypical antipsychotic
drug claims for elderly nursing home residents were erroneous, amounting to $116
million. (OIG, 2011). Use of this measure should prompt nursing facilities to
re-examine their prescribing patterns which may result in practice consistent
with clinical recommendations and guidelines. Reference: Alexander, G.,
Gallagher, S., Mascola, A., et al.: Increasing off-label use of antipsychotic
medications in the United States, 1995-2008. Pharmacoepidemiol Drug Saf
20(2):177-184, 2011. Ballard, C.G., and Margallo-Lana, M.L.: The relationship
between antipsychotic treatment and quality of life for patients with dementia
living in residential and nursing home care facilities. J Clin Psychiatry 65
Suppl 11:23-28, 2004. Doody, R.S., Stevens, J.C., Beck, C., et al.: Practice
parameter: management of dementia (an evidence-based review). Report of the
Quality Standards Subcommittee of the American Academy of Neurology. Neurology
56(9):1154-1166, 2001. FDA: Information for Healthcare Professionals:
Conventional Antipsychotics. FDA Alert (June 16, 2008).
http://www.fda.gov/drugs/drugsafety/postmarketdrugsafetyinformationforpatientsandproviders/ucm124830.htm
Huybrechts, K.F., Gerhard, T., Crystal, S., et al.: Differential risk of death
in older residents in nursing homes prescribed specific antipsychotic drugs:
population based cohort study. BMJ 344:e977, 2012. Jackson-Siegal, J.M.,
Schneider, L.S., Baskys, A., et al.: Recognizing and responding to atypical
antipsychotic side effects. J Am Med Dir Assoc 5(4 Suppl):H7-10, 2004. Jeste,
D.V., Blazer, D., Casey, D., et al.: ACNP White Paper: update on use of
antipsychotic drugs in elderly persons with dementia. Neuropsychopharmacology
33(5):957-970, 2008. Martin, H., Slyk, M.P., Deymann, S., et al.: Safety
profile assessment of risperidone and olanzapine in long-term care patients with
dementia. J Am Med Dir Assoc 4(4):183-188, 2003. Neil, W., Curran, S., and
Wattis, J.: Antipsychotic prescribing in older people. Age Ageing 32(5):475-483,
2003. Office of Inspector General (OIG): Medicare Atypical Antipsychotic Drug
Claims For Elderly Nursing Home Residents, 2011. Rosack, J.: FDA orders new
warning on atypical antipsychotics. Psychiatr News 40(9):1-50, 2005."
Measure Specifications
- NQF Number (if applicable):
- Description: This measure reports the percentage of skilled nursing
facility residents who are receiving an antipsychotic medication during a
quarter but who were not receiving an antipsychotic medication at
admission.
- Numerator: Skilled nursing facility residents who are receiving an
antipsychotic medication during a quarter but who were not receiving an
antipsychotic medication on their first assessment after
admission.
- Denominator: Skilled nursing facility residents, except for those
who meet the exclusion criteria.
- Exclusions: Residents are excluded from the denominator if they are
diagnosed with any of the following conditions: Schizophrenia, Tourette’s
Syndrome and Huntington’s Disease.
- HHS NQS Priority: Residents are excluded from the denominator if
they are diagnosed with any of the following conditions: Schizophrenia,
Tourette’s Syndrome and Huntington’s Disease.
- HHS Data Source: Nursing Home Minimum Data Set (MDS) Version 3.0
- Measure Type: Process
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Although MAP encouraged continued development,
MAP members noted concerns about different versions of a measure being used
for the Nursing Home Quality Reporting Program and Nursing Home Quality
Initiative.
- Public comments received: 7
Rationale for measure provided by HHS
The opportunity for
improving unrelieved pain in nursing home residents continues to be demonstrated
by reports of less-than-optimal pain management, considerable variation in pain
management, and data from interventions aimed at improving pain management in
nursing homes. In 2011, a report from the Institute of Medicine stated,
“evidence indicates that nursing homes undertreat pain, especially in
cognitively impaired and minority residents” (Institute of Medicine, 2011).
Recent reports indicate that pain management in nursing home can be improved by
improving pain assessment, including use of structured assessment tools.
Investigations of pain management strategies have increasingly broadened to
include comprehensive approaches that are evidence based, multidisciplinary, and
use behavioral approaches to educate and train staff (Cervo, et al., 2012;
Savvas et al., 2014). Comprehensive interventions attempt to improve both pain
assessment and pain treatment by adopting pain-assessment tools and
pain-management clinical guidelines. Pain management may also be improved by
nonpharmacological approaches to pain management, such as cognitive behavioral
therapy, mindfulness meditation, relaxation techniques, assistive devices,
physical activity and exercise, and complementary therapies. (Abdulla et al.,
2013). References: 1. Abdulla, A., Adams, N., Bone, M., Elliott, A. M.,
Gaffin, J., Jones, D., et al. (2013). Guidance on the management of pain in
older people. Age and Ageing, 42 Suppl 1, i1-57. 2. Cervo, F. A., Bruckenthal,
P., Fields, S., Bright-Long, L. E., Chen, J. J., Zhang, G., et al. (2012). The
role of the CNA Pain Assessment Tool (CPAT) in the pain management of nursing
home residents with dementia. Geriatric Nursing (New York, NY), 33(6), 430-438.
3. Institute of Medicine. (2011). Relieving Pain in America: A Blueprint for
Transforming Prevention, Care, Education, and Research. Washington DC: National
Academics Press. 4. Savvas, S. M., Toye, C. M., Beattie, E. R., & Gibson,
S. J. (2014). An evidence-based program to improve analgesic practice and pain
outcomes in residential aged care facilities. Journal of the American Geriatrics
Society, 62(8), 1583-1589.
Measure Specifications
- NQF Number (if applicable): 676
- Description: This measure reports the percentage of skilled nursing
facility residents who have reported daily pain with at least one episode of
moderate to severe pain, or severe or horrible pain of any frequency in the 5
days prior to the assessment. (The endorsed specifications of the measure
are: This measure reports the percentage of short-stay residents, of all ages,
in a nursing facility, who have reported almost constant or frequent pain,
and at least one episode of moderate to severe pain, or any severe or horrible
pain, in the 5 days prior to the target assessment. This measure is based on
data from the Minimum Data Set (MDS 3.0) OBRA, PPS, and/or discharge
assessments. Short-stay residents are identified as residents who have had 100
or fewer days of nursing facility care. )A separate measure (NQF#0677,
Percent of Residents Who Self-Report Moderate to Severe Pain (Long-Stay)) is
to be used for residents who had at least 100 days of nursing facility
care.
- Numerator: The numerator is the number of skilled nursing facility
residents who are able to self-report with a selected Minimum Data Set (MDS)
assessment during the selected quarter and who report almost constant or
frequent pain AND at least one episode of moderate to severe pain in the 5
days prior to the assessment OR who report very severe/horrible pain of any
frequency in the 5 days prior to the assessment. (The endorsed
specifications of the measure are: The numerator is the number of short-stay
residents who are able to self-report with a selected Minimum Data Set (MDS)
assessment (OBRA admission, quarterly, annual or significant change/correction
assessments; PPS 5-,14-, 30-, 60-, 90-day, or readmission/return assessments;
or discharge assessment with or without return anticipated) during the
selected quarter and who report almost constant or frequent pain AND at least
one episode of moderate to severe pain in the 5 days prior to the assessment
OR who report very severe/horrible pain of any frequency in the 5 days prior
to the assessment.)
- Denominator: Skilled nursing facility residents, except those who
meet the exclusion criteria. (The endorsed specifications of the measure
are: The denominator is the total of all short-stay residents in the nursing
facility who have an OBRA, PPS or discharge MDS assessment during the selected
6 month period and who do not meet the exclusion criteria.)
- Exclusions: A resident is excluded if they did not meet the pain
symptom conditions for the numerator AND any of the following conditions are
true: 1) The pain assessment interview was not completed (J0200 = 0, -, ^) OR
2) The pain presence item was not completed (J0300 = 09, ^) OR 3) For
residents with pain or hurting at any time in the last 5 days (J0300 = 1), any
of the following are true: 3.1) The pain frequency item was not completed
(J0400 = [9, -, ^]); 3.2) Neither of the pain intensity items were completed
(J0600A = [99, -, ^] and J0600B = [99, -, ^]); 3.3) The numeric pain
intensity item indicates no pain (J06000A = [00]). (The endorsed
specifications of the measure are: A resident is excluded from the denominator
if they did not meet the pain symptom conditions for the numerator AND any of
the following conditions are true: 1) the resident cannot self-report; 2)
there are missing data in the responses to the relevant questions in the MDS
assessment; OR 3) the assessment indicates that the resident had pain or
hurting at any time in the last 5 days (J0300 = 1), but the numeric pain
intensity item indicates no pain (J0600A = 00).Nursing facilities with fewer
than 20 residents in the sample are excluded from public reporting because of
small sample size.)
- HHS NQS Priority: A resident is excluded if they did not meet the
pain symptom conditions for the numerator AND any of the following conditions
are true: 1) The pain assessment interview was not completed (J0200 = 0, -,
^) OR 2) The pain presence item was not completed (J0300 = 09, ^) OR 3) For
residents with pain or hurting at any time in the last 5 days (J0300 = 1), any
of the following are true: 3.1) The pain frequency item was not completed
(J0400 = [9, -, ^]); 3.2) Neither of the pain intensity items were completed
(J0600A = [99, -, ^] and J0600B = [99, -, ^]); 3.3) The numeric pain
intensity item indicates no pain (J06000A = [00]). (The endorsed
specifications of the measure are: A resident is excluded from the denominator
if they did not meet the pain symptom conditions for the numerator AND any of
the following conditions are true: 1) the resident cannot self-report; 2)
there are missing data in the responses to the relevant questions in the MDS
assessment; OR 3) the assessment indicates that the resident had pain or
hurting at any time in the last 5 days (J0300 = 1), but the numeric pain
intensity item indicates no pain (J0600A = 00).Nursing facilities with fewer
than 20 residents in the sample are excluded from public reporting because of
small sample size.)
- HHS Data Source: Nursing Home Minimum Data Set (MDS) Version 3.0
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Endorsed; MUC same as endorsed version:No
(target population differs)
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has not been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2011
- Project for Most Recent Endorsement Review: National Voluntary
Consensus Standards for Nursing Homes
- Review for Importance: See CDP Recommendation]
- Review for Scientific Acceptability: See CDP
Recommendation]
- Review for Feasibility: See CDP Recommendation]
- Review for Usability: See CDP Recommendation]
- Review for Related and Competing Measures: See CDP
Recommendation]
- Endorsement Public Comments: Multiple commenters were concerned
about nursing home residents who are unable to self-report pain. In response,
the developer proposed changing the title of the measure to include "who
self-report," and the Committee agreed that this adequately addressed
theissue.
- Endorsement Committee Recommendation: For both NQF 0676 and 0677):
Research indicates that at least 40 percent to 85 percent of nursing facility
residents have persistent pain. The percentage may be evenhigher; research
suggests pain often is not fully documented. 63,64,65,66,67,68,69These two
measures were discussed concurrently with measure 009, and many of the same
issues apply. The Committee voted to recommend the measure for time-limited
endorsement with the following conditions: evaluate the patient’s cognitive
status whenreporting pain;further examine missing data to ensure there is not
an underreporting of pain in order to improve the facility’s rating;address
concerns regarding the frequency of pain, e.g., does decreased frequency, but
increased intensity, equal effective care;address concerns around
unintendedconsequences that may occur when interpreting the measure results
during reliability testing. The range of 0 to 10 is not linear and therefore
does not account for potential changes in pain score. It was noted that some
residents would rather have pain atlevel 4 or 5 than take opiates; andaccount
for patient preference in pain management.
During follow-up, the developer explained it plans to examine the results
of this measure compared to those produced by independentmeasures solely
focused on cognitive status (i.e., Brief Interview of Mental Status [BIMS] or
resident ability to complete the MDS self-report pain assessment) during
testing.
The Committee voted to recommend these measures for time-limited
endorsement.
The measures meet the National Priority of Care
Coordination.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Although MAP encouraged continued development,
MAP members noted concerns about different versions of a measure being used
for the Nursing Home Quality Reporting Program and Nursing Home Quality
Initiative. MAP members noted that this measure raises an important issue
about the need to ensure vaccine information is transmitted between sites of
care to prevent patients from receiving multiple doses.
- Public comments received: 7
Rationale for measure provided by HHS
Influenza and pneumonia are
now reported as the fifth-leading cause of death among people aged 65 or older
in the United States (CMS, 2011). As of 2011, there are over 200,000
hospitalizations from influenza, on average, every year (CMS, 2011). An average
of 36,000 Americans die annually due to influenza and its complications and most
are people 65 years old and over (CMS, 2011). Vaccination can be cost-effective
and successful in preventing influenza. A study conducted in 2002 by Nichol and
Goodman found that vaccination of healthy elderly was associated with a 36%
reduction in hospitalization for pneumonia or influenza, an 18% reduction in
hospitalization for all respiratory conditions, and a 40% reduction in
mortality. (Nichol and Goodman, 2002) Influenza vaccination was also associated
with cost savings. (Nichol and Goodman, 2002). Influenza vaccination is
recommended for those over 65 years old and those with medical conditions, which
describes the population of post-acute care facilities, making it an appropriate
quality measure for skilled nursing facilities. By focusing on skilled nursing
facility residents during the influenza season, publicly reporting this measure
will increase vaccination during that time period and prevent influenza
outbreaks in skilled nursing facilities. References: 1. Centers for Medicare
& Medicaid Services (2011, May). Adult immunization: overview. Retrieved
from https://www.cms.gov/adultImmunizations/ 2. Nichol KL, Goodman M., Cost
effectiveness of influenza vaccination for healthy persons between ages 65 and
74 years. Vaccine. 2002 May 15;20(Suppl 2):S21-4.
Measure Specifications
- NQF Number (if applicable): 680
- Description: The measure reports the percentage of skilled nursing
facility residents who are assessed and appropriately given the seasonal
influenza vaccine. (The endorsed specifications of the measure are: The
measure reports the percentage of residents or patients who are assessed and
appropriately given the seasonal influenza vaccine.)This measure includes
residents or patients 180 days of age or older on target date of assessment in
the denominator. The measure is based on data from the Minimum Data Set (MDS)
3.0 assessments of nursing home residents, Inpatient Rehabilitation Facility
Patient Assessment Instrument (IRF-PAI) Version 1.2 assessments for Inpatient
Rehabilitation Facility (IRF) patients, and the Long-Term Care Hospital (LTCH)
Continuity Assessment Record & Evaluation (CARE) Data Set Version 2.01
assessments of LTCH patients.Data are collected in each of these three
settings using standardized items across the three assessment instruments. For
the nursing homes/skilled nursing facilities, the measure is limited to
short-stay residents, identified as residents who have had 100 or fewer days
of nursing facility care. For the LTCHs, this measure will include all
patients, irrespective of a patient’s length of stay. For IRFs, this measure
will include all Medicare Part A and Part C patients, irrespective of a
patient’s length of stay. This measure mirrors the NQF standard specifications
that were developed to achieve a uniform approach to data collection across
healthcare settings and populations by addressing who is included in and
excluded from the target denominator population, who is included in and
excluded from the numerator population, time window for measurement and time
window for vaccinations. National Quality Forum. (2008,
December).
- Numerator: The numerator is the number of skilled nursing facility
residents, during the numerator time window, who meet any of the following
criteria: (1) received the seasonal influenza vaccine during the most
recently-completed influenza vaccination season; (2) were offered but declined
the seasonal influenza vaccine; or (3) were ineligible due to
contraindication(s). The numerator time window coincides with the most
recently-completed seasonal influenza vaccination season (which begins on
October 1, or when the vaccine first becomes available, and ends on March 31
of the following year). (The endorsed specifications of the measure are:
The numerator is the number of residents or patients in the denominator sample
who, during the numerator time window, meet any of the following criteria: (1)
those who received the seasonal influenza vaccine during the most
recently-completed influenza vaccination season, either in the
facility/hospital or outside the facility/hospital; (2) those who were offered
but declined the seasonal influenza vaccine; or (3) those who were ineligible
due to contraindication(s). The numerator time window coincides with the most
recently-completed seasonal influenza vaccination season (which begins on
October 1, or when the vaccine first becomes available, and ends on March 31
of the following year).)Each criterion in the numerator is computed and
reported separately.
- Denominator: The denominator consists of skilled nursing facility
residents aged 180 days and older on target date of the assessment during the
denominator time window. The denominator time window is defined as the most
recently-completed influenza vaccination season, which begins on October 1 or
when the vaccine first becomes available, and ends on March 31 of the
following year.(The endorsed specifications of the measure are: The
denominator consists of patients or short-stay residents aged 180 days of age
and older on target date of assessment who were in the facility/hospital for
at least one day during the denominator time window. The denominator time
window is defined as the most recently-completed influenza vaccination season,
which begins on October 1 and ends on March 31 of the following year. This
measure is based on the NQF´s National Voluntary Standards for Influenza and
Pneumococcal Immunizations.Note: The IRF-PAI data are submitted for Medicare
patients only.)
- Exclusions: Residents whose age is 179 days or younger on target
date of the selected assessment are excluded.(The endorsed specifications
of the measure are: Residents or patients whose age is 179 days or less on
target date of selected influenza vaccination assessment are excluded.
Facilities with denominator counts of less than 20 residents/patients in the
sample will be excluded from public reporting owing to small sample
size.)
- HHS NQS Priority: Residents whose age is 179 days or younger on
target date of the selected assessment are excluded.(The endorsed
specifications of the measure are: Residents or patients whose age is 179 days
or less on target date of selected influenza vaccination assessment are
excluded. Facilities with denominator counts of less than 20
residents/patients in the sample will be excluded from public reporting owing
to small sample size.)
- HHS Data Source: Nursing Home Minimum Data Set (MDS) Version 3.0
- Measure Type: Process
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Endorsed; MUC same as endorsed version:
No
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has not been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2011; 2012
- Project for Most Recent Endorsement Review: 1) National Voluntary
Consensus Standards for Nursing Homes; 2) Ad-hoc Review: Expansion of
Settings
- Review for Importance: See CDP Recommendation]
- Review for Scientific Acceptability: See CDP
Recommendation]
- Review for Feasibility: See CDP Recommendation]
- Review for Usability: See CDP Recommendation]
- Review for Related and Competing Measures: See CDP
Recommendation]
- Endorsement Committee Recommendation: 1) 2011 report (reviewed with
NQF#681): Almost 60,000 deaths in 2004 were caused by influenza and pneumonia,
and more than 85 percent of those were among the elderly.14Frail elderly are
especially vulnerable and subject to complications of influenza. In the same
year, approximately 123,000 death certificates identified influenza and
pneumonia as a secondary cause of death. Further, the death rate from
influenza and pneumonia is nearly130 times higher among persons aged 85 and
older than among persons 45 to 54 years of age. The Committee unanimously
agreed thesetwo measures are important and have strong evidence to support
them. The Committee asked for and received assurance these measures are
harmonized with other NQFvaccination measures. Further discussion focused on
the definition of long-stay residents, the consequences of excluding missing
data, and a specified time frame for vaccination.The Committee placed
requirements on endorsement for this measure, requesting that for the
long-stay measure the denominator should include only residents whose stay in
the facility is longer than 100 days from the date of admission; the
short-stay measure denominator should include only patients whose stay is 100
days or fewer. Second, patients with missing data in the MDS 3.0 should be
counted as patients who did not receive the vaccine, rather than be
excluded.Third, the numerator and denominator should be clearly harmonized
with NQF’s previously endorsed vaccination measures. Finally, thetime frame
for the seasonal vaccination should be altered to harmonize with the standard
NQF influenza season definition. The steward agreed to meet these conditions
for both measures, so the Committee voted to recommend these measures for
endorsement. These measures meet the National Priority of Population Health.
2) 2012 (ad hoc review): The National
Quality Forum (NQF) Board of Directors has approved an expansion of settings
for two nursing home measures: #0680, Percent of Nursing Home Residents Who
Were Assessed and Appropriately Given the Seasonal Influenza Vaccine
(Short-Stay); and #0682, Percent of Residents Assessed and Appropriately Given
the Pneumococcal Vaccine (Short-Stay).The Centers for Medicare & Medicaid
Services, the measure steward, expanded the measures beyond the nursing home
setting to include inpatient rehabilitation facilities and long-term acute
care hospitals. The ad-hoc review request fell under the third NQF criterion
for justifying a review: material changes to a currently endorsed
measure.Technical experts were convened to assess the proposed measure changes
and agreed to recommend expansion of both measures given the following
reasons: the age range was expanded to reflect current evidence; the time
window was made consistent with standard specifications and harmonized with
other NQF-endorsed measures; data on the validity was provided; and the
measure submission form was modified to ensure that the documentation supports
the changes made.
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: Concerns were raised about potential
unintended consequences of these measures and noted the need for appropriate
risk adjustment. Members noted that facilities may decline complex patients if
these measures are not appropriately adjusted. MAP also raised concerns about
potential overlap between readmission measures and this may introduce multiple
penalties for the same readmission episode due to multiple measures. MAP
members asked for greater clarity about the definition of a potentially
preventable readmission. MAP also noted that patients seldom have only one
diagnosis and raised concerns about the challenges of separating out numerator
and denominators related to each diagnosis. MAP members raised particular
concerns about this measure for the home health setting, especially as the
patient may not be under the care of the home health agency immediately
post-discharge.
- Public comments received: 14
Rationale for measure provided by HHS
Hospital readmissions of
Medicare beneficiaries discharged from a hospital to a skilled nursing facility
(SNF) are prevalent and expensive, and prior studies suggest that a large
proportion of readmissions are preventable (Mor et al., 2010). According to Mor
et al., based an analysis of SNF data from 2006 Medicare claims merged with the
Minimum Data Set (MDS), 23.5 percent of SNF stays resulted in a
rehospitalization within 30 days of the initial hospital discharge. The average
Medicare payment for each readmission was $10,352 per hospitalization, for a
total of $4.34 billion. Of these rehospitalizations, 78 percent were deemed
potentially avoidable, and applying this figure to the aggregate cost indicates
that avoidable hospitalizations resulted in an excess cost of $3.39 billion (78
percent of $4.34 billion) to Medicare (Mor, Intrator, Feng, et al., 2010).
Several analyses of hospital readmissions of SNF patients suggest there is
opportunity for reducing hospital readmissions among SNF patients (Li et al.,
2012; Mor et al., 2010), and multiple studies suggest SNF structural and process
characteristics that impact readmission rates (Coleman et al., 2004; MedPAC
2011).
Measure Specifications
- NQF Number (if applicable):
- Description: All-condition risk-adjusted potentially preventable
hospital readmission rates
- Numerator: This measure does not have a simple form for the
numerator and denominator. The numerator is defined as the risk-adjusted
estimate of the number of unplanned, potentially preventable readmissions that
occurred within 30 days post discharge from SNF services. The numerator, as
defined, includes risk adjustment for patient characteristics and a
statistical estimate of the facility effect beyond patient mix.
- Denominator: The denominator is computed with the same model used
for the numerator. It is the model developed using all non-excluded stays in
the national data. The measure includes all stays in the measurement period
that are observed in national Medicare FFS data and do not fall into an
excluded category. For a particular facility, the model is applied to the
patient population, but the facility effect term is 0. In essence, it is the
number of unplanned potentially preventable readmissions that would be
expected for that patient population at the average facility.
(New
information provided by CMS on January 19, 2016) The denominator is
computed with the same model used for the numerator. It is the model developed
using all non-excluded SNF stays in the national data.
- Exclusions: 1. Patients who died during the SNF stay. 2. Patients
less than 18 years old. 3. Patients who were transferred to the same level of
care or the hospital at the end of their SNF stay. 4. Patients who were not
continuously enrolled in Part A FFS Medicare for the 12 months prior to the
SNF admissions, and at least 30 days after SNF discharge. 5. Patients who did
not have a short-term acute-care stay within 30 days prior to the SNF
admission date. 6. Patients who leave the SNF against medical advice; 7.
Patients for whom the prior short-term acute-care stay was for the nonsurgical
treatment of cancer. 8. Patients who were transferred to a federal hospital
from the SNF. 9. Patients who received care from a provider located outside
of the US, Puerto Rico, or a US territory. 10. SNF stays with data that are
problematic (e.g., anomalous records for hospital stays that overlap wholly or
in part or are otherwise erroneous or contradictory).
- HHS NQS Priority: 1. Patients who died during the SNF stay. 2.
Patients less than 18 years old. 3. Patients who were transferred to the same
level of care or the hospital at the end of their SNF stay. 4. Patients who
were not continuously enrolled in Part A FFS Medicare for the 12 months prior
to the SNF admissions, and at least 30 days after SNF discharge. 5. Patients
who did not have a short-term acute-care stay within 30 days prior to the SNF
admission date. 6. Patients who leave the SNF against medical advice; 7.
Patients for whom the prior short-term acute-care stay was for the nonsurgical
treatment of cancer. 8. Patients who were transferred to a federal hospital
from the SNF. 9. Patients who received care from a provider located outside
of the US, Puerto Rico, or a US territory. 10. SNF stays with data that are
problematic (e.g., anomalous records for hospital stays that overlap wholly or
in part or are otherwise erroneous or contradictory).
(New
information provided by CMS on January 19, 2016) 1. Patients who died
during the SNF stay. 2. Patients less than 18 years old. 3. Patients who were
transferred to the same level of care or the hospital at the end of their SNF
stay. 4. Patients who were not continuously enrolled in Part A FFS Medicare
for the 12 months prior to the SNF admissions, and at least 30 days after SNF
discharge. 5. Patients who did not have a short-term acute-care stay within
30 days prior to the SNF admission date. 6. Patients who leave the SNF
against medical advice. 7. Patients for whom the prior short-term acute-care
stay was for the nonsurgical treatment of cancer. 8. Patients who were
transferred to a federal hospital from the SNF. 9. Patients who received care
from a provider located outside of the US, Puerto Rico, or a US territory. 10.
SNF stays with data that are problematic (e.g., anomalous records for hospital
stays that overlap wholly or in part or are otherwise erroneous or
contradictory).
- HHS Data Source: Claims: This measure is based on Medicare claims
data for fee-for-service beneficiaries using SNFservices. Several variables
from the inpatient claims and SNF claims will be used including
admission/discharge dates and diagnostic/procedure information.
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Summary of Workgroup Deliberations
- Workgroup Recommendation: Encourage continued
development
- Workgroup Rationale: MAP members raised concerns about potential
negative unintended consequences if SNFs are hesitant to transfer patients to
the hospital to avoid penalties. Some MAP members noted the limited
actionability of this measure and that increased granularity could provide
information to improve care. However, other members stated that providers
should implement their own systems for tracking and identifying these issues
for quality improvement.CMS indicated that this measure would replace the
current all-cause readmission as soon as practical.
- Public comments received: 11
Rationale for measure provided by HHS
Hospital readmissions of
Medicare beneficiaries discharged from a hospital to a SNF are prevalent and
expensive, and prior studies suggest that a large proportion of readmissions are
preventable (Mor et al., 2010). According to Mor et al., based an analysis of
SNF data from 2006 Medicare claims merged with the Minimum Data Set (MDS), 23.5
percent of SNF stays resulted in a rehospitalization within 30 days of the
initial hospital discharge. The average Medicare payment for each readmission
was $10,352 per hospitalization, for a total of $4.34 billion. Of these
rehospitalizations, 78 percent were deemed potentially avoidable, and applying
this figure to the aggregate cost indicates that avoidable hospitalizations
resulted in an excess cost of $3.39 billion (78 percent of $4.34 billion) to
Medicare (Mor, Intrator, Feng, et al., 2010). Several analyses of hospital
readmissions of SNF patients suggest there is opportunity for reducing hospital
readmissions among SNF patients (Li et al., 2012; Mor et al., 2010), and
multiple studies suggest SNF structural and process characteristics that impact
readmission rates (Coleman et al., 2004; MedPAC 2011).
Measure Specifications
- NQF Number (if applicable):
- Description: All-condition risk-adjusted potentially preventable
hospital readmission rates (required under PAMA)
- Numerator: This measure does not have a simple form for the
numerator and denominator. The numerator is defined as the risk-adjusted
estimate of the number of unplanned, potentially preventable readmissions that
occurred within 30 days from discharge from the prior proximal acute
hospitalization. The numerator, as defined, includes risk adjustment for
patient characteristics and a statistical estimate of the facility effect
beyond patient mix.
- Denominator: The denominator is computed with the same model used
for the numerator. It is the model developed using all non-excluded stays in
the national data. The measure includes all stays in the measurement period
that are observed in national Medicare FFS data and do not fall into an
excluded category. For a particular facility, the model is applied to the
patient population, but the facility effect term is 0. In essence, it is the
number of unplanned potentially preventable readmissions that would be
expected for that patient population at the average facility.
(New
information provided by CMS on January 19, 2016) The denominator is
computed with the same model used for the numerator. It is the model developed
using all non-excluded SNF stays in the national data.
- Exclusions: The following are the sample exclusions: 1. SNF stays
where the patient had one or more intervening post-acute care (PAC) admissions
which occurred either between the prior proximal hospital discharge and SNF
admission or after the SNF discharge, within the 30-day risk window. Also
excluded are SNF admissions where the patient had multiple SNF admissions
after the prior proximal hospitalization, within the 30-day risk window. 2.
SNF stays with a gap of greater than 1 day between discharge from the prior
proximal hospitalization and the SNF admission. 3. SNF stays where the
patient did not have at least 12 months of FFS Medicare enrollment prior to
the proximal hospital discharge (measured as enrollment during the month of
proximal hospital discharge and the for 11 months prior to that discharge).
4. SNF stays in which the patient did not have FFS Medicare enrollment for the
entire risk period (measured as enrollment during the month of proximal
hospital discharge and the month following the month of discharge). 5. SNF
stays in which the principal diagnosis for the prior proximal hospitalization
was for the medical treatment of cancer. Patients with cancer whose principal
diagnosis from the prior proximal hospitalization was for other diagnoses or
for surgical treatment of their cancer remain in the measure. 6. SNF stays
where the patient was discharged from the SNF against medical advice. 7. SNF
stays in which the principal primary diagnosis for the prior proximal
hospitalization was for “rehabilitation care; fitting of prostheses and for
the adjustment of devices” 8. SNF stays in which the prior proximal
hospitalization was for pregnancy.
(New information provided by CMS
on January 19, 2016) The following are the sample exclusions: 1. SNF
stays where the patient had one or more intervening post-acute care (PAC)
admissions which occurred either between the prior proximal hospital discharge
and SNF admission or after the SNF discharge, within the 30-day risk window.
Also excluded are SNF admissions where the patient had multiple SNF admissions
after the prior proximal hospitalization, within the 30-day risk window. 2.
SNF stays with a gap of greater than 1 day between discharge from the prior
proximal hospitalization and the SNF admission. 3. SNF stays where the
patient did not have at least 12 months of FFS Medicare enrollment prior to
the proximal hospital discharge (measured as enrollment during the month of
proximal hospital discharge and the for 11 months prior to that discharge).
4. SNF stays in which the patient did not have FFS Medicare enrollment for the
entire risk period (measured as enrollment during the month of proximal
hospital discharge and the month following the month of discharge). 5. SNF
stays in which the principal diagnosis for the prior proximal hospitalization
was for the medical treatment of cancer. Patients with cancer whose principal
diagnosis from the prior proximal hospitalization was for other diagnoses or
for surgical treatment of their cancer remain in the measure. 6. SNF stays
where the patient was discharged from the SNF against medical advice. 7. SNF
stays in which the prior proximal hospitalization was for pregnancy.
- HHS NQS Priority: The following are the sample exclusions: 1. SNF
stays where the patient had one or more intervening post-acute care (PAC)
admissions which occurred either between the prior proximal hospital discharge
and SNF admission or after the SNF discharge, within the 30-day risk window.
Also excluded are SNF admissions where the patient had multiple SNF admissions
after the prior proximal hospitalization, within the 30-day risk window. 2.
SNF stays with a gap of greater than 1 day between discharge from the prior
proximal hospitalization and the SNF admission. 3. SNF stays where the
patient did not have at least 12 months of FFS Medicare enrollment prior to
the proximal hospital discharge (measured as enrollment during the month of
proximal hospital discharge and the for 11 months prior to that discharge).
4. SNF stays in which the patient did not have FFS Medicare enrollment for the
entire risk period (measured as enrollment during the month of proximal
hospital discharge and the month following the month of discharge). 5. SNF
stays in which the principal diagnosis for the prior proximal hospitalization
was for the medical treatment of cancer. Patients with cancer whose principal
diagnosis from the prior proximal hospitalization was for other diagnoses or
for surgical treatment of their cancer remain in the measure. 6. SNF stays
where the patient was discharged from the SNF against medical advice. 7. SNF
stays in which the principal primary diagnosis for the prior proximal
hospitalization was for “rehabilitation care; fitting of prostheses and for
the adjustment of devices” 8. SNF stays in which the prior proximal
hospitalization was for pregnancy.
(New information provided by CMS
on January 19, 2016) The following are the sample exclusions: 1. SNF
stays where the patient had one or more intervening post-acute care (PAC)
admissions which occurred either between the prior proximal hospital discharge
and SNF admission or after the SNF discharge, within the 30-day risk window.
Also excluded are SNF admissions where the patient had multiple SNF admissions
after the prior proximal hospitalization, within the 30-day risk window. 2.
SNF stays with a gap of greater than 1 day between discharge from the prior
proximal hospitalization and the SNF admission. 3. SNF stays where the
patient did not have at least 12 months of FFS Medicare enrollment prior to
the proximal hospital discharge (measured as enrollment during the month of
proximal hospital discharge and the for 11 months prior to that discharge).
4. SNF stays in which the patient did not have FFS Medicare enrollment for the
entire risk period (measured as enrollment during the month of proximal
hospital discharge and the month following the month of discharge). 5. SNF
stays in which the principal diagnosis for the prior proximal hospitalization
was for the medical treatment of cancer. Patients with cancer whose principal
diagnosis from the prior proximal hospitalization was for other diagnoses or
for surgical treatment of their cancer remain in the measure. 6. SNF stays
where the patient was discharged from the SNF against medical advice. 7. SNF
stays in which the prior proximal hospitalization was for pregnancy.
- HHS Data Source: Administrative claims
- Measure Type: Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Never Submitted
- Is the measure specified as an electronic clinical quality measure?
No
Appendix B: Program Summaries
The material in this
appendix was drawn from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program Index
Full Program Summaries
The material for this program was
drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: The Home Health Quality Reporting
Program (HH QRP) was established in accordance with section 1895
(b)(3)(B)(v)(II) of the Social Security Act. Home Health Agencies (HHAs) are
required by the Act to submit quality data for use in evaluating quality for
Home Health agencies. Section 1895(b) (3)(B)(v)(I) of the Act also requires that
HHAs that do not submit quality data to the Secretary be subject to a 2 percent
reduction in the annual payment update, effective in calendar year 2007 and
every subsequent year. Data sources for the HH QRP include the Outcome and
Assessment Information Set (OASIS) and Medicare FFS claims. Data is publically
reported on the Home Health Compare website. The HH QRP measure development and
selection activities take into account established national priorities and input
from multi-stakeholder groups.
Further, the Improving Medicare Post-Acute
Care Transformation (IMPACT Act of 2014, amends title XVIII (Medicare) of the
Social Security Act (the Act) to direct the Secretary of the Department of
Health and Human Services (HHS) to require Long-term Care Hospitals (LTCH),
Inpatient Rehabilitation Facilities (IRF), Skilled Nursing Facilities (SNF) and
Home Health Agencies (HHA) to report data on resource use and other measures and
standardized patient assessment data on quality measures and specified
assessment domains via the assessment instruments that are used to submit
assessment data to CMS by these post-acute care (PAC) providers; amending the
Social Security Act for each of the provider types to add such requirements
under the IMPACT Act. The IMPACT Act delineates the reporting of standardized
assessment data on quality measures in at least the following domains:
Functional status, cognitive function, and changes in function and cognitive
function; skin integrity and changes in skin integrity; medication
reconciliation; incidence of major falls; transfer of health information when
the individual transitions from the hospital/critical access hospital to PAC
provider or home, or from PAC provider to another settings. It also delineates
the implementation of resource use and other measures in at least these
following domains: Total estimated Medicare spending per beneficiary Discharge
to the community, all condition risk adjusted potentially presentable hospital
readmission rates. Further, the IMPACT Act requires the modification of such
assessment instruments to achieve the standardization of such data.
High Priority Domains for Future Measure Consideration: CMS
identified the following domains as high-priority for future measure
consideration:
- Patient and Family Engagement: Quality care in home health settings should
addressed not only assessing for what the patient/family desires, but also to
assess how well care is provided and what services are offered to meet an
individual’s care preferences.
- Patient and Family Engagement: Functional status and functional decline
are important to assess for individuals who reside in a home-based setting.
Individuals who receive care in home-based settings may have functional
limitations and may be at risk for further decline in function due to limited
mobility and ambulation. Therefore, measures to assess functional status are
in development.
- Making Care Safer: Safety for individuals in a home-based setting is an
important priority for the HH QRP as persons in home health settings are at
risk for major injury due to falls, new or worsened pressure ulcers, pain, and
functional decline. Therefore, these concepts will be considered for future
measure development.
- Making Care Affordable: An important consideration for the HH QRP is to
better assess medical costs based on PAC episodes of care. Therefore, CMS is
considering developing efficiency-based measures such as a Medicare Spending
per Beneficiary measure concept.
- Communication/Care Coordination: Assessing an individual’s care
transitions and rehospitalizations is important. Therefore, CMS is considering
developing measures that assesses discharge to the community and potentially
preventable readmissions.
- Communication/Care Coordination: Infrastructure and processes for care
coordination are important for the HH QRP. Therefore, a medication
reconciliation quality measure for individuals in a home health setting is
being considered for future quality measure development. Medication
reconciliation conceptually highlights care transitions and resident
follow-up.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The material for this program was
drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: The Hospice Quality Reporting
Program (HQRP) was established in accordance with section 1814(i) of the Social
Security Act, as amended by section 3004(c) of the Affordable Care Act. The HQRP
applies to all hospices, regardless of setting. Proposed data sources for future
HQRP measures include the Hospice Item Set and the Hospice Consumer Assessment
of Healthcare Providers and Systems (CAHPS) questionnaire. HQRP measure
development and selection activities take into account established national
priorities and input from multi-stakeholder groups. Beginning in FY 2014,
Hospices that fail to submit quality data will be subject to a 2.0 percentage
point reduction to their annual payment update.
High Priority Domains for Future Measure Consideration: CMS
identified the following domains as high-priority for Hospice QRP future measure
consideration:
- Overall goal HQRP: Symptom Management Outcome Measures. There is a lack of
tested and endorsed outcome measures for hospice across domains of hospice
care, including symptom management (e.g.; physical and other symptoms).
Developing and implementing outcome measures for hospice is important for
providers, patients and families, and other stakeholders because symptom
management is a central aspect of hospice care.
- Communication/Care Coordination and/or Patient and Family Engagement:
Patient preference for care is difficult to measure at end of life when
patients may or may not be able to state their preferences, and may have
changes in their preferences. However, a central tenet of hospice care is
responsiveness to patient and family care preferences; as much as possible,
patient preferences should be incorporated into new measure development.
- Patient and Family Engagement: Measurement of goal attainment is naturally
linked to determining patient/family preferences. Quality care in hospice
should address not only establishing what the patient/family desires but also
providing care and services in line with those preferences.
- Making Care Safer: Timeliness/responsiveness of care. While timeliness of
referral to hospice is not within a hospices’ control, hospice initiation of
treatment once a patient has elected the hospice benefit is under the control
of the hospice. Responsiveness of the hospice during times of patient or
family need is an important indicator about hospice services for consumers in
particular.
- Communication/Care Coordination: Measurement of care coordination is
integral to the provision of quality care and should be aligned across care
settings.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The material for
this program was drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: The Quality Reporting Program (QRP)
for Inpatient Rehabilitation Facilities (IRFs) was established in accordance
with section 1886(j) of the Social Security Act as amended by section 3004(b) of
the Affordable Care Act. The IRF QRP applies to all IRF facilities that receive
the IRF PPS (e.g., IRF hospitals, IRF units that are co-located with affiliated
acute care facilities, and IRF units affiliated with critical access hospitals
[CAHs]). Data sources for IRF QRP measures include Medicare FFS claims, the
Center for Disease Control’s National Health Safety Network (CDC NHSN) data
submissions, and Inpatient Rehabilitation Facility - Patient Assessment
instrument (IRF-PAI) records. The IRF QRP measure development and selection
activities take into account established national priorities and input from
multi-stakeholder groups. Beginning in FY 2014, IRFs that fail to submit data
will be subject to a 2.0 percentage point reduction of the applicable IRF
Prospective Payment System (PPS) payment update. Plans for future public
reporting of IRF QRP measures are under development.
Further, the Improving Medicare Post-Acute Care Transformation (IMPACT Act
of 2014, amends title XVIII (Medicare) of the Social Security Act (the Act) to
direct the Secretary of the Department of Health and Human Services (HHS) to
require Long-term Care Hospitals (LTCH), Inpatient Rehabilitation Facilities
(IRF), Skilled Nursing Facilities (SNF) and Home Health Agencies (HHA) to report
data on resource use and other measures and standardized patient assessment data
on quality measures and specified assessment domains via the assessment
instruments that are used to submit assessment data to CMS by these post-acute
care (PAC) providers; amending the Social Security Act for each of the provider
types to add such requirements under the IMPACT Act. The IMPACT Act delineates
the reporting of standardized assessment data on quality measures in at least
the following domains: Functional status, cognitive function, and changes in
function and cognitive function; skin integrity and changes in skin integrity;
medication reconciliation; incidence of major falls; transfer of health
information when the individual transitions from the hospital/critical access
hospital to PAC provider or home, or from PAC provider to another settings. It
also delineates the implementation of resource use and other measures in at
least these following domains: Total estimated Medicare spending per beneficiary
Discharge to the community, all condition risk adjusted potentially presentable
hospital readmission rates. Further, the IMPACT Act requires the modification of
such assessment instruments to achieve the standardization of such data.
High Priority Domains for Future Measure Consideration: CMS
identified the following four domains as high-priority for future measure
consideration:
- Making Care Safer (subdomains: hospital-acquired infections and
hospital-acquired conditions): Patient safety is an important priority domain
for the IRF QRP as IRF patients are at risk for injury due to falls, new or
worsened pressure ulcers and infections such as CAUTI, C. Diff. and MRSA.
- Patient and Family Engagement: A primary focus of IRF care is restoring
functional status. Metrics showing change in self-care and mobility function
and discharge self-care and mobility are under development. Metric for
achievement of functional status goals such as discharge to community. In
addition, the experiences of patients and caregivers are important to measure
and are important priority for the IRF QRP.
- Making Care Affordable: An important consideration for the IRF QRP is to
better assess medical costs based on PAC episodes of care. Therefore, CMS is
considering developing efficiency-based measures such as a Medicare Spending
per Beneficiary measure concept.
- Communication/Care Coordination: Assessing patient care transitions and
rehospitalizations are important. Therefore, CMS is considering developing
measures that assesses discharge to the community and potentially preventable
readmissions.
- Communication/Care Coordination: Infrastructure and processes for care
coordination are important for the IRF QRP. Therefore, a medication
reconciliation quality measure for IRF patients is being considered for future
quality measure development. Medication reconciliation conceptually highlights
care transitions and resident follow-up.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The material for this
program was drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: The Long-Term Care Hospital (LTCH)
Quality Reporting Program (QRP) was established in accordance with section
1886(m) of the Social Security Act, as amended by Section 3004(a) of the
Affordable Care Act. The LTCH QRP applies to all LTCHs facilities designated as
an LTCH under the Medicare program. Data sources for LTCH QRP measures include
Medicare FFS claims, the Center for Disease Control and Prevention’s National
Health Safety Network (CDC’s NHSN) data submissions, and the LTCH Continuity
Assessment Record and Evaluation Data Sets (LCDS). The LTCH QRP measure
development and selection activities take into account established national
priorities and input from multi-stakeholder groups. Beginning in FY 2014, LTCHs
that fail to submit data will be subject to a 2.0 percentage point reduction of
the applicable Prospective Payment System (PPS) increase factor.
Further, the Improving Medicare Post-Acute Care Transformation (IMPACT Act
of 2014, amends title XVIII (Medicare) of the Social Security Act (the Act) to
direct the Secretary of the Department of Health and Human Services (HHS) to
require Long-term Care Hospitals (LTCH), Inpatient Rehabilitation Facilities
(IRF), Skilled Nursing Facilities (SNF) and Home Health Agencies (HHA) to report
data on resource use and other measures and standardized patient assessment data
on quality measures and specified assessment domains via the assessment
instruments that are used to submit assessment data to CMS by these post-acute
care (PAC) providers; amending the Social Security Act for each of the provider
types to add such requirements under the IMPACT Act. The IMPACT Act delineates
the reporting of standardized assessment data on quality measures in at least
the following domains: Functional status, cognitive function, and changes in
function and cognitive function; skin integrity and changes in skin integrity;
medication reconciliation; incidence of major falls; transfer of health
information when the individual transitions from the hospital/critical access
hospital to PAC provider or home, or from PAC provider to another settings. It
also delineates the implementation of resource use and other measures in at
least these following domains: Total estimated Medicare spending per beneficiary
Discharge to the community, all condition risk adjusted potentially presentable
hospital readmission rates. Further, the IMPACT Act requires the modification of
such assessment instruments to achieve the standardization of such data.
High Priority Domains for Future Measure Consideration: CMS
identified the following domains as high-priority for LTCH QRP future measure
consideration:
- Effective Prevention and Treatment: Having measures related to ventilator
use, ventilator-associated event and ventilator weaning rate are a high
priority for CMS as prolonged mechanical ventilator use is quite common in
LTCHs and respiratory diagnosis with ventilator support for 96 or more hours
is the most frequently occurring diagnosis.
- Effective Prevention and Treatment (Aim: Healthy People/Healthy
Communities): In discussions with LTCH providers, it was noted that mental
health status is an important measure of care for LTCH patients. CMS is
considering a Depression Assessment & Management quality measure.
- Patient and Family Engagement: While rehabilitation and restoring
functional status are not the primary goals of patient care in the LTCH
setting, functional outcomes remain an important indicator of LTCH quality as
well as key to LTCH care trajectories. Providers must be able to provide
functional support to patients with impairments. Thus, metrics showing change
in self-care and mobility function are under development.
- Patient and Family Engagement: CMS would like to explore measures that
will evaluate the patient’s experiences of care as this is a high priority of
providers. Therefore, the HCAHPS and Care Transition quality measure (CTM)-3
is being considered.
- Making Care Affordable: An important consideration for the LTCH QRP is to
better assess medical costs based on PAC episodes of care. Therefore, CMS is
considering developing efficiency-based measures such as a Medicare Spending
per Beneficiary measure concept.
- Communication/Care Coordination: Assessing patient care transitions and
rehospitalizations are important. Therefore, CMS is considering developing
measures that assesses discharge to the community and potentially preventable
readmissions.
- Communication/Care Coordination: Infrastructure and processes for care
coordination are important for the LTCH QRP. Therefore, a medication
reconciliation quality measure for LTCH patients is being considered for
future quality measure development. Medication reconciliation conceptually
highlights care transitions and resident follow-up.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The material for this
program was drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: The Improving Medicare Post-Acute
Care Transitions Act of 2014 (The IMPACT Act) added Section 1899B to the Social
Security Act establishing the Skilled Nursing Facility (SNF) Quality Reporting
Program (QRP). Facilities that submit data under the SNF PPS are required to
participate in the SNF QRP, excluding units that are affiliated with critical
access hospitals (CAHs). Data sources for SNF QRP measures include Medicare FFS
claims as well as Minimum Data Set (MDS) assessment data. The SNF QRP measure
development and selection activities take into account established national
priorities and input from multi-stakeholder groups. Beginning in FY 2018,
providers that fail to submit required quality data to CMS will have their
annual updates reduced by 2.0 percentage points.
Further, the Improving
Medicare Post-Acute Care Transformation (IMPACT Act of 2014, amends title XVIII
(Medicare) of the Social Security Act (the Act) to direct the Secretary of the
Department of Health and Human Services (HHS) to require Long-term Care
Hospitals (LTCH), Inpatient Rehabilitation Facilities (IRF), Skilled Nursing
Facilities (SNF) and Home Health Agencies (HHA) to report data on resource use
and other measures and standardized patient assessment data on quality measures
and specified assessment domains via the assessment instruments that are used to
submit assessment data to CMS by these post-acute care (PAC) providers; amending
the Social Security Act for each of the provider types to add such requirements
under the IMPACT Act. The IMPACT Act delineates the reporting of standardized
assessment data on quality measures in at least the following domains:
Functional status, cognitive function, and changes in function and cognitive
function; skin integrity and changes in skin integrity; medication
reconciliation; incidence of major falls; transfer of health information when
the individual transitions from the hospital/critical access hospital to PAC
provider or home, or from PAC provider to another settings. It also delineates
the implementation of resource use and other measures in at least these
following domains: Total estimated Medicare spending per beneficiary Discharge
to the community, all condition risk adjusted potentially presentable hospital
readmission rates. Further, the IMPACT Act requires the modification of such
assessment instruments to achieve the standardization of such data.
High Priority Domains for Future Measure Consideration: CMS
identified the following four domains as high-priority for future measure
consideration:
- Patient and Family Engagement: Functional status and functional decline
are important to assess for residents in SNF settings. Residents who receive
care while in a SNF may have functional limitations and may be at risk for
further decline in function due to limited mobility and ambulation. Therefore,
measures to assess functional status are in development.
- Making Care Safer: Resident safety is an important priority domain for the
SNF QRP as persons in SNF settings are at risk for major injury due to falls,
new or worsened pressure ulcers, pain, and functional decline. Therefore,
these concepts will be considered for future measure development.
- Making Care Affordable: An important consideration for the SNF QRP is to
better assess medical costs based on PAC episodes of care. Therefore, CMS is
considering developing efficiency-based measures such as a Medicare Spending
per Beneficiary measure concept.
- Communication/Care Coordination: Assessing resident care transitions and
rehospitalizations are important. Therefore, CMS is considering developing
measures that assesses discharge to the community and potentially preventable
readmissions.
- Communication/Care Coordination: Infrastructure and processes for care
coordination are important for the SNF QRP. Therefore, a medication
reconciliation quality measure for SNF residents is being considered for
future quality measure development. Medication reconciliation conceptually
highlights care transitions and resident follow-up.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The
material for this program was drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: The Skilled Nursing Facility
Value-Based Purchasing (SNF-VBP) Program was established by Section 215 (b)of
the Protecting Access to Medicare Act of 2014. The facility adjusted Federal per
diem rate will be reduced by 2% and an incentive payment will then be applied to
facilities based upon readmission measure performance.
The legislation mandates that CMS will specify a SNF all-cause
all-condition hospital readmission measure by no later than October 1, 2015. It
further requires that a resource use measure that reflects resource use by
measuring all-condition risk-adjusted potentially preventable hospital
readmission rates for SNFs will be specified no later than October 1, 2016 and
replace the all-cause all-condition measure as soon as is practicable.
High Priority Domains for Future Measure Consideration: CMS
identified the following categories as high-priority for future measure
consideration:
- The sole measure requirement at this time is the specification of a
potentially preventable readmission measure. CMS lacks the authority to
implement additional measures beyond the two described in the
statute.
Measure Requirements: CMS applies criteria for measures that may
be considered for potential adoption in the SNF-VBP program. At a minimum, the
following requirements must be met for selection in the SNF-VBP
program:
- Must meet statutory requirements for all-condition potentially preventable
hospital readmissions measure for SNFs.
- Must provide documentation sufficient to complete MUC list required data
fields.
- Measures should be NQF endorsed, save where due consideration is given to
endorsed measures of the same specified area or medical topic.
- May incorporate Medicare claims and/or alternative data sources will be
considered dependent upon available infrastructure.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The material for this
program was drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: The Ambulatory Surgical Center (ASC)
Quality Reporting Program was established under the authority provided by
Section 109(b) of the Medicare Improvements and Extension Act of 2006, Division
B, Title I of the Tax Relief and Health Care Act (TRHCA) of 2006. The statute
provides the authority for requiring ASCs paid under the ASC fee schedule
(ASCFS) to report on process, structure, outcomes, patient experience of care,
efficiency, and costs of care measures. ASCs receive a 2.0 percentage point
payment penalty to their ASCFS annual payment update for not meeting program
requirements. CMS implemented this program so that payment determinations were
effective beginning with the Calendar Year (CY) 2014 payment update.
High Priority Domains for Future Measure Consideration: CMS
identified the following categories as high-priority for future measure
consideration:
- Making Care Safer
- Measures of infection rates
- Person and Family Engagement
- Measures that improve experience of care for patients, caregivers, and
families.
- Measures to promote patient self-management.
- Best Practice of Healthy Living
- Measures to increase appropriate use of screening and prevention
services.
- Measures which will improve the quality of care for patients with
multiple chronic conditions.
- Measures to improve behavioral health access and quality of
care.
- Effective Prevention and Treatment
- Surgical outcome measures
- Communication/Care Coordination
- Measures to embed best practice to manage transitions across practice
settings.
- Measures to enable effective health care system navigation.
- To reduce unexpected hospital/emergency visits and
admissions.
Measure Requirements: CMS applies criteria for measures that may
be considered for potential adoption in the ASCQR program.
At a minimum, the
following requirements will be considered in selecting measures for ASCQR
Program implementation:
- Measure must adhere to CMS statutory requirements.
- Measures are required to reflect consensus among affected parties, and
to the extent feasible, be endorsed by the national consensus entity with a
contract under Section 1890(a) of the Social Security Act
- The Secretary may select a measure in an area or topic in which a
feasible and practical measure has not been endorsed, by the entity with a
contract under Section 1890(a) of the Social Security Act, as long as
endorsed measures have been given due consideration
- Measure must address a NQS priority/CMS strategy goal, with preference for
measures addressing the high priority domains for future measure
consideration.
- Measure must address an important condition/topic for which there is
analytic evidence that a performance gap exists and that measure
implementation can lead to improvement in desired outcomes, costs, or resource
utilization.
- Measure must be field tested for the ASC clinical setting.
- Measure that is clinically useful.
- Reporting of measure limits data collection and submission burden since
many ASCs are small facilities with limited staffing.
- Measure must supply sufficient case numbers for differentiation of ASC
performance.
- Measure must promote alignment across HHS and CMS programs.
- Measure steward will provide CMS with technical assistance and
clarifications on the measure as needed.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The material for this
program was drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: For more than 30 years, monitoring
the quality of care provided to end-stage renal disease (ESRD) patients by
dialysis facilities has been an important component of the Medicare ESRD payment
system. The ESRD quality incentive program (QIP) is the most recent step in
fostering improved patient outcomes by establishing incentives for dialysis
facilities to meet or exceed performance standards established by CMS. The ESRD
QIP is authorized by section 1881(h) of the Social Security Act, which was added
by section 153(c) of Medicare Improvements for Patients and Providers (MIPPA)
Act (the Act). CMS established the ESRD QIP for Payment Year (PY) 2012, the
initial year of the program in which payment reductions were applied, in two
rules published in the Federal Register on August 12, 2010, and January 5, 2011
(75 FR 49030 and 76 FR 628, respectively). Subsequently, CMS published rules in
the Federal Register detailing the QIP requirements for PY 2013 through FY 2016.
Most recently, CMS published a rule on November 6, 2014 in the Federal Register
(79 FR 66119), providing the QIP requirements for PY2017 and PY 2018, with the
intention of providing an additional year between finalization of the rule and
implementation in future rules.
Section 1881(h) of the Act requires the
Secretary to establish an ESRD QIP by (i) selecting measures; (ii) establishing
the performance standards that apply to the individual measures; (iii)
specifying a performance period with respect to a year; (iv) developing a
methodology for assessing the total performance of each facility based on the
performance standards with respect to the measures for a performance period; and
(v) applying an appropriate payment reduction to facilities that do not meet or
exceed the established Total Performance Score (TPS).
High Priority Domains for Future Measure Consideration: CMS
identified the following 3 domains as high-priority for future measure
consideration:
- Care Coordination: ESRD patients constitute a vulnerable population that
depends on a large quantity and variety medication and frequent utilization of
multiple providers, suggesting medication reconciliation is a critical issue.
Dialysis facilities also play a substantial role in preparing dialysis
patients for kidney transplants, and coordination of dialysis-related services
among transient patients has consequences for a non-trivial proportion of the
ESRD dialysis population.
- Safety: ESRD patients are frequently immune-compromised, and experience
high rates of blood stream infections, vascular access-related infections, and
mortality. Additionally, some medications provided to treat ESRD patients may
cause harmful side effects such as heart disease and a dynamic bone disease.
Recently, oral-only medications were excluded from the bundle payment,
increasing need for quality measures that protect against overutilization of
oral-only medications.
- Patient- and Caregiver-Centered Experience of Care: Sustaining and
recovering patient quality of life was among the original goals of the
Medicare ESRD program. This includes such issues as physical function,
independence, and cognition. Quality of Life measures should also consider the
life goals of the particular patient where feasible, to the point of including
Patient-Reported Outcomes.
Measure Requirements:
- Measures for anemia management reflecting FDA labeling, as well as
measures for dialysis adequacy.
- Measure(s) of patient satisfaction, to the extent feasible.
- Measures of iron management, bone mineral metabolism, and vascular access,
to the extent feasible.
- Measures should be NQF endorsed, save where due consideration is given to
endorsed measures of the same specified area or medical topic.
- Must include measures considering unique treatment needs of children and
young adults.
- May incorporate Medicare claims and/or CROWNWeb data, alternative data
sources will be considered dependent upon available
infrastructure.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The material for this program was
drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: Section 3008 of the Patient
Protection and Affordable Care Act of 2010 (ACA) established the
Hospital-Acquired Condition (HAC) Reduction Program (HAC Reduction Program).
Created under Section 1886(p) of the Social Security Act (the Act), the HAC
Reduction Program provides an incentive for hospitals to reduce the number of
HACs. Effective Fiscal Year (FY) 2014 and beyond, the HAC Reduction Program
requires the Secretary to make payment adjustments to applicable hospitals that
rank in the top quartile of all subsection (d) hospitals relative to a national
average of HACs acquired during an applicable hospital stay. HACs include a
condition identified in subsection 1886(d)(4)(D)(iv) of the Act and any other
condition determined appropriate by the Secretary. Section 1886(p)(6)(C) of the
Act requires the HAC information be posted on the Hospital Compare
website.
CMS finalized in the FY 2014 IPPS/LTCH PPS final rule that
hospitals will be scored using a Total HAC Score based on measures categorized
into two (2) domains of care, each with a different set of measures. Domain 1
consists of Agency for Healthcare Research and Quality (AHRQ) Patient Safety
Indicators (PSI), and Domain 2 consists of Hospital Associated Infections (HAI)
as collected by the Centers for Disease Control and Prevention (CDC) National
Healthcare Safety Network (NHSN). Both domains of the HAC Reduction Program are
categorized under the National Quality Strategy (NQS) priority of “Making Care
Safer”. Measures in each domain are assigned points so that each domain has a
score. In the FY 2016 IPPS/LTCH PPS proposed rule, we are proposing that the
weighting of the domain scores be changed as follows for the FY 2017 program:
(1) Domain 1 weight would be decreased from 25% to 15%; and (2) Domain 2 weight
would be increased from 75% to 85%. The Total HAC Score is the sum of the two
weighted domain scores.
High Priority Domains for Future Measure Consideration: For FY
2017 federal rulemaking, CMS may propose the adoption, removal, and/or
suspension of measures for fiscal years 2018 and beyond of the HAC Reduction
Program. CMS identified the following topics as areas within the NQS priority of
“Making Care Safer” for future measure consideration:
- Making Care Safer:
- Adverse Drug Events
- Ventilator Associated Events
- Additional Surgical Site Infection Locations
- Outcome Risk-Adjusted Measures
Measure Requirements: CMS applies criteria for measures that may
be considered for potential adoption in the HAC Reduction Program. At a minimum,
the following requirements must be met for consideration in the HAC Reduction
Program:
- Measures must be identified as a HAC under Section 1886(d)(4)(D) or be a
condition identified by the Secretary.
- Measures must address high cost or high volume conditions.
- Measures must be easily preventable by using evidence-based
guidelines.
- Measures must not require additional system infrastructure for date
submission and collection.
- Measures must be risk adjusted.
- Measure steward will provide CMS with technical assistance and
clarifications on the measure as needed.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The material for
this program was drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: The Hospital Inpatient Quality
Reporting (IQR) Program was established by Section 501(b) of the Medicare
Prescription Drug, Improvement, and Modernization Act (MMA) of 2003 and later
amended by the Deficit Reduction Act (DRA) of 2005. The program requires
hospitals paid under the Inpatient Prospective Payment System (IPPS) to report
on process, structure, outcomes, patient perspectives on care, efficiency, and
costs of care measures. Hospitals receive a quarter of the applicable percentage
point of the annual market basket (the measure of inflation in costs of goods
and services used by hospitals in treating Medicare patients) payment update.
Hospitals who choose non-participation in the program receive a reduction by
that same amount. Performance of quality measures are publicly reported on the
CMS Hospital Compare website.
The American Recovery and Reinvestment Act
of 2009 (ARRA) (Pub. L. 111-5) amended Titles XVIII and XIX of the Social
Security Act (the Act) to authorize incentive payments to eligible hospitals
(EHs) and Critical Access Hospitals (CAHs) and other groups eligible to
participate in the EHR Incentive Program, to promote the adoption and
meaningful use of certified electronic health record (EHR) technology (CEHRT).
EHs and CAHs are required to report on electronically specified clinical quality
measures (eCQMs) using CEHRT in order to qualify for incentive payments under
the Medicare and Medicaid EHR Incentive. All EHR Incentive Program requirements
related to eCQM reporting will be addressed in IQR Program rulemaking
including, but not limited to, new program requirements, reporting requirements,
reporting and submission periods, reporting methods, and information regarding
the eCQMs.
High Priority Domains for Future Measure Consideration: CMS
identified the following categories as high-priority for future measure
consideration:
- Patient and Family Engagement:
- Measures that foster the engagement of patients and families as partners
in their care.
- Best Practices of Healthy Living:
- Measures that promote best practices to enable healthy living.
- Making Care Affordable:
- Measures that effectuate changes in efficiency and reward value over
volume.
CMS identified the following topics/areas as high-priority for future measure
consideration:
- Adverse Drug Events
- Cancer
- Palliative and End of Life Care
- Behavioral Health
- Care Transitions
- Medication Reconciliation
Measure Requirements: CMS applies criteria for measures that may
be considered for potential adoption in the IQR program. At a minimum, the
following criteria will be considered in selecting measures for IQR program
implementation:
- Measure must adhere to CMS statutory requirements.
- Measures are required to reflect consensus among affected parties, and
to the extent feasible, be endorsed by the national consensus entity with a
contract under Section 1890(a) of the Social Security Act; currently the
National Quality Forum (NQF)
- The Secretary may select a measure in an area or topic in which a
feasible and practical measure has not been endorsed, by the entity with a
contract under Section 1890(a) of the Social Security Act, as long as
endorsed measures have been given due consideration
- Measure must be claims-based or an electronically specified clinical
quality measure (eCQM).
- A Measure Authoring Tool (MAT) number must be provided for all eCQMs,
created in the HQMF format
- eCQMs must undergo reliability and validity testing including review of
the logic and value sets by the CMS partners, including, but not limited to,
MITRE and the National Library of Medicine
- eCQMs must have successfully passed feasibility testing
- Measure may not require reporting to a proprietary registry.
- Measure must address an important condition/topic for which there is
analytic evidence that a performance gap exists and that measure
implementation can lead to improvement in desired outcomes, costs, or resource
utilization.
- Measure must be fully developed, tested, and validated in the acute
inpatient setting.
- Measure must address a NQS priority/CMS strategy goal, with preference for
measures addressing the high priority domains and/or measurement gaps for
future measure consideration.
- Measure must promote alignment across HHS and CMS programs.
- Measure steward will provide CMS with technical assistance and
clarifications on the measure as needed.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The material for this program was
drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: The Hospital Outpatient Quality
Reporting (OQR) Program was established by Section 109 of the Tax Relief and
Health Care Act (TRHCA) of 2006. The program requires subsection (d) hospitals
providing outpatient services paid under the Outpatient Prospective Payment
System (OPPS) to report on process, structure, outcomes, efficiency, costs of
care, and patient experience of care. Hospitals receive a 2.0 percentage point
reduction of their annual payment update (APU) under the Outpatient Prospective
Payment System (OPPS) for non-participation in the program. Performance on
quality measures is publicly reported on the CMS Hospital Compare website.
High Priority Domains for Future Measure Consideration: CMS
identified the following categories as high-priority for future measure
consideration:
- Making Care Safer:
- Measures that address processes and outcomes designed to reduce risk in
the delivery of health care, e.g., emergency department overcrowding and
wait times.
- Best Practices of Healthy Living:
- Measures that focus on primary prevention of disease or general
screening for early detection of disease unrelated to a current or prior
condition.
- Patient and Family Engagement:
- Measures that address engaging both the person and their family in their
care.
- Measures that address cultural sensitivity, patient decision-making
support or care that reflects patient preferences.
- Communication/Care Coordination:
- Measures to embed best practices to manage transitions across practice
settings.
- Measures to enable effective health care system navigation.
- Measures to reduce unexpected hospital/emergency visits and
admissions.
Measure Requirements: CMS applies criteria for measures that may
be considered for potential adoption in the HOQR program. At a minimum, the
following criteria will be considered in selecting measures for HOQR program
implementation:
- Measure must adhere to CMS statutory requirements.
- Measures are required to reflect consensus among affected parties, and
to the extent feasible, be endorsed by the national consensus entity with a
contract under Section 1890(a) of the Social Security Act
- The Secretary may select a measure in an area or topic in which a
feasible and practical measure has not been endorsed, by the entity with a
contract under Section 1890(a) of the Social Security Act, as long as
endorsed measures have been given due consideration
- Measure must address a NQS priority/CMS strategy goal, with preference for
measures addressing the high priority domains for future measure
consideration.
- Measure must address an important condition/topic for which there is
analytic evidence that a performance gap exists and that measure
implementation can lead to improvement in desired outcomes, costs, or resource
utilization.
- Measure must be fully developed, tested, and validated in the hospital
outpatient setting.
- Measure must promote alignment across HHS and CMS programs.
- Feasibility of Implementation: An evaluation of feasibility is based on
factors including, but not limited to
- The level of burden associated with validating measure data, both for
CMS and for the end user.
- Whether the identified CMS system for data collection is prepared to
accommodate the proposed measure(s) and timeline for collection.
- The availability and practicability of measure specifications, e.g.,
measure specifications in the public domain.
- The level of burden the data collection system or methodology poses for
an end user.
- Measure steward will provide CMS with technical assistance and
clarifications on the measure as needed.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The material for this program was
drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: Section 3025 of the Patient
Protection and Affordable Care Act of 2010 (ACA) established the Hospital
Readmissions Reduction Program (HRRP). Codified under Section 1886(q) of the
Social Security Act (the Act), the HRRP provides an incentive for hospitals to
reduce the number of excess readmissions that occur in their settings. Effective
Fiscal Year (FY) 2012 and beyond, the HRRP requires the Secretary to establish
readmission measures for applicable conditions and to calculate an excess
readmission ratio for each applicable condition, which will be used to determine
a payment adjustment to those hospitals with excess readmissions. A readmission
is defined as an admission to an acute care hospital within 30 days of a
discharge from the same or another acute care hospital. A hospital’s excess
readmission ratio measures a hospital’s readmission performance compared to the
national average for the hospital’s set of patients with that applicable
condition. Applicable conditions in the HRRP program currently include measures
for acute myocardial infarction, heart failure, pneumonia, chronic obstructive
pulmonary disease, and elective total knee and total hip arthroplasty.
Readmission following coronary artery bypass graft surgery has been finalized as
an applicable condition beginning with the FY 2017 payment determination.
Planned readmissions are excluded from the excess readmission calculation.
High Priority Domains for Future Measure Consideration: For FY
2017 federal rulemaking, CMS may propose the adoption, removal, refinement, and
or suspension of measures for fiscal year 2018 and subsequent years of the HRRP.
CMS continues to emphasize the importance of the NQS priority of
“Communication/Care Coordination” for this program.
- Care Coordination
- Measures that address high impact conditions identified by the Medicare
Payment Advisory Commission or the Agency for Healthcare Research and
Quality (AHRQ) Healthcare Cost and Utilization Project (HCUP)
reports.
Measure Requirements: CMS applies criteria for measures that may
be considered for potential adoption in the HRRP program. At a minimum, the
following criteria and requirements must be met for consideration in the HRRP
program:
- CMS is statutorily required to select measures for applicable conditions,
which are defined as conditions or procedures selected by the Secretary in
which readmissions are high volume or high expenditure.
- Measures selected must be endorsed by the consensus-based entity with a
contract under Section 1890 of the Act. However, the Secretary can select
measures which are feasible and practical in a specified area or medical topic
determined to be appropriate by the Secretary, that have not been endorsed by
the entity with a contract under Section 1890 of the Act, as long as endorsed
measures have been given due consideration.
- Measure methodology must be consistent with other readmissions measures
currently implemented or proposed in the HRRP program.
- Measure steward will provide CMS with technical assistance and
clarifications on the measure as needed.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The material for this program was
drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: The Hospital Value-Based Purchasing
(VBP) Program was established by Section 3001(a) of the Affordable Care Act,
under which value-based incentive payments are made in a fiscal year to
hospitals meeting performance standards established for a performance period for
such fiscal year. The Secretary shall select measures, other than measures of
readmissions, for purposes of the Program. However, measures of five conditions
(acute myocardial infarction, pneumonia, heart failure, surgeries, and
healthcare-associated infections), the Hospital Consumer Assessment of
Healthcare Providers and Systems (HCAHPS) survey, and efficiency measures must
be included. Measures are eligible for adoption in the Hospital VBP Program
based on the statutory requirements, including specification under the Hospital
IQR Program and posting dates on the Hospital Compare Web site.
High Priority Domains for Future Measure Consideration: CMS
identified the following categories as high-priority for future measure
consideration:
- Patient and Family Engagement:
- Measures that foster the engagement of patients and families as partners
in their care.
- Best Practices of Healthy Living:
- Measures that promote best practices to enable healthy living.
- Making Care Affordable:
- Measures that effectuate changes in efficiency and reward value over
volume.
CMS identified the following topics/areas as high-priority for future measure
consideration:
- Adverse Drug Events
- Cancer
- Palliative and End of Life Care
- Behavioral Health
- Care Transitions
- Medication Reconciliation
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The material for
this program was drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: The Inpatient Psychiatric Facility
Quality Reporting (IPFQR) Program was established by Section 1886(s)(4) of the
Social Security Act, as added by sections 3401(f)(4) and 10322(a) of the Patient
Protection and Affordable Care Act (the Affordable Care Act). Under current
regulations, the program requires participating inpatient psychiatric facilities
(IPFs) to report on 10 quality measures or face a 2.0 percentage point reduction
to their annual update. Reporting on these measures apply to payment
determinations for Fiscal Year (FY) 2016 and beyond. The reporting period for
the FY 2016 payment determination was CY 2014, with the exception of the
Follow-Up After Hospitalization for Mental Illness measure which was July 1,
2013 – June 30, 2014. Four measures were added for the FY 2017 payment
determination, two with reporting periods of October 1, 2015 - March 31, 2016
and two with reporting periods of CY 2015.
High Priority Domains for Future Measure Consideration: CMS
identified the following categories as high-priority for future measure
consideration:
- Patient and Family Engagement
- Patient experience of care
- Effective Prevention and Treatment
- Inpatient psychiatric treatment and quality of care of geriatric
patients and other adults, adolescents, and children
- Quality of prescribing for antipsychotics and antidepressants
- Communication/Care Coordination
- Readmissions and re-hospitalizations
- Best Practices of Healthy Living
- Screening and treatment for non-psychiatric comorbid conditions for
which patients with mental or substance use disorders are at higher
risk
- Access to care
- Making Care Affordable
- Measures which effectuate changes in efficiency and that reward value
over volume.
Measure Requirements: CMS applies criteria for measures that may
be considered for potential adoption in the IPFQR program. At a minimum, the
following criteria will be considered in selecting measures for IPFQR program
implementation:
- Measure must adhere to CMS statutory requirements.
- Measures are required to reflect consensus among affected parties, and
to the extent feasible, be endorsed by the national consensus entity with a
contract under Section 1890(a) of the Social Security Act
- The Secretary may select a measure in an area or topic in which a
feasible and practical measure has not been endorsed, by the entity with a
contract under Section 1890(a) of the Social Security Act, as long as
endorsed measures have been given due consideration
- Measure must address an important condition/topic for which there is
analytic evidence that a performance gap exists and that measure
implementation can lead to improvement in desired outcomes, costs, or resource
utilization.
- The measure assesses meaningful performance differences between
facilities.
- The measure addresses an aspect of care affecting a significant proportion
of IPF patients.
- Measure must be fully developed, tested, and validated in the acute
inpatient setting.
- Measure must address a NQS priority/CMS strategy goal, with preference for
measures addressing the high priority domains for future measure
consideration.
- Measure must promote alignment across HHS and CMS programs.
- Measure steward will provide CMS with technical assistance and
clarifications on the measure as needed.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The material for this program was drawn directly from
the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: Section 3005 of the Affordable Care
Act added new subsections (a)(1)(W) and (k) to section 1866 of the Social
Security Act (the Act). Section 1866(k) of the Act establishes a quality
reporting program for hospitals described in section 1886(d)(1)(B)(v) of the Act
(referred to as a “PPS-Exempt Cancer Hospital” or “PCH”). Section 1866(k)(1) of
the Act states that, for FY 2014 and each subsequent fiscal year, a PCH shall
submit data to the Secretary in accordance with section 1866(k)(2) of the Act
with respect to such a fiscal year. In FY 2014 and each subsequent fiscal year,
each hospital described in section 1886(d)(1)(B)(v) of the Act shall submit data
to the Secretary on quality measures (QMs) specified under section 1866(k)(3) of
the Act in a form and manner, and at a time, specified by the Secretary.
The program requires PCHs to submit data for selected QMs to CMS. PCHQR is a
voluntary quality reporting program, in which data will be publicly reported on
a CMS website. In the FY 2012 IPPS rule, five NQF endorsed measures were adopted
and finalized for the FY 2014 reporting period, which was the first year of the
PCHQR program. In the FY 2013 IPPS rule, one additional measure was adopted.
Twelve new measures were adopted in the FY 2014 IPPS rule and one measure was
adopted in the FY 2015 IPPS rule. Data collection for the FY 2016 and FY 2017
reporting periods is underway. We published the FY 2014 measure rates on
HospitalCompare.gov on October 1, 2014 after a 30-day preview period.
High Priority Domains for Future Measure Consideration: CMS
identified the following categories as high-priority for future measure
consideration:
- Communication and Care Coordination
- Measures regarding care coordination with other facilities and
outpatient settings, such as hospice care.
- Measures of the patient’s functional status, quality of life, and end of
life.
- Making Care Affordable
- Measures related to efficiency, appropriateness, and utilization
(over/under-utilization) of cancer treatment modalities such as
chemotherapy, radiation therapy, and imaging treatments.
- Person and Family Engagement
- Measures related to patient-centered care planning, shared
decision-making, and quality of life outcomes.
Measure Requirements: The following requirements will be
considered by CMS when selecting measures for program implementation:
- Measure is responsive to specific program goals and statutory
requirements.
- Measures are required to reflect consensus among stakeholders, and to
the extent feasible, be endorsed by the national consensus entity with a
contract under Section 1890(a) of the Social Security Act; currently the
National Quality Forum (NQF)
- The Secretary may select a measure in an area or topic in which a
feasible and practical measure has not been endorsed, by the entity with a
contract under Section 1890(a) of the Social Security Act, as long as
endorsed measures have been given due consideration
- Measure specifications must be publicly available.
- Measure steward will provide CMS with technical assistance and
clarifications on the measure as needed.
- Promote alignment with specific program attributes and across CMS and HHS
programs. Measure alignment should support the measurement across the
patient’s episode of care, demonstrated by assessment of the person’s
trajectory across providers and settings.
- Potential use of the measure in a program does not result in negative
unintended consequences (e.g., inappropriate reduced lengths of stay, overuse
or inappropriate use of care or treatment, limiting access to care).
- Measures must be fully developed and tested, preferably in the PCH
environment.
- Measures must be feasible to implement across PCHs, e.g., calculation, and
reporting.
- Measure addresses an important condition/topic with a performance gap and
has a strong scientific evidence base to demonstrate that the measure when
implemented can lead to the desired outcomes and/or more appropriate
costs.
- CMS has the resources to operationalize and maintain the
measure.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
The material for this program was
drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: Section 3022 of the Affordable Care
Act (ACA) requires the Centers for Medicare & Medicaid Services (CMS) to
establish a Shared Savings Program that promotes accountability for a patient
population, coordinates items and services under Medicare Parts A and B, and
encourages investment in infrastructure and redesigned care processes for
high-quality and efficient service delivery. The Medicare Shared Savings Program
(Shared Savings Program) was designed to facilitate coordination and cooperation
among providers to improve the quality of care for Medicare Fee-For-Service
(FFS) beneficiaries and reduce the rate of growth in health care costs. Eligible
providers, hospitals, and suppliers may participate in the Shared Savings
Program by creating or participating in an Accountable Care Organization (ACO).
If ACOs meet program requirements and the ACO quality performance standard, they
are eligible to share in savings, if earned. There are two shared savings
options: 1) one-sided risk model (sharing of savings only for the first two
years, and sharing of savings and losses in the third year) and 2) two-sided
risk model (sharing of savings and losses for all three years).
Current Program Measure Information: The Affordable Care Act
specifies appropriate measures of clinical processes and outcomes; patient, and,
wherever practicable, caregiver experience of care; and utilization (such as
rates of hospital admission for ambulatory sensitive conditions) and that an ACO
may include the following types of groups of providers and suppliers of
Medicare-covered services:
- ACO professionals (i.e., physicians and hospitals meeting the statutory
definition) in group practice arrangements,
- Networks of individual practices of ACO professionals,
- Partnerships or joint ventures arrangements between hospitals and ACO
professionals, or
- Hospitals employing ACO professionals, and
- Other Medicare providers and suppliers as determined by the
Secretary.
The Shared Savings Program quality reporting
requirements are aligned with PQRS. Quality measure data for the Shared Savings
Program is collected via claims and administrative data, CG-CAHPS, and the PQRS
GPRO web interface.
Measure Requirements: Specific measure requirements
include:
- Outcome measures that address conditions that are high-cost and affect a
high volume of Medicare patients.
- Measures that are targeted to the needs and gaps in care of Medicare
fee-for-service patients and their caregivers.
- Measures that align with CMS quality reporting initiatives, such as PQRS
and the VM.
- Measures that support improved individual and population
health.
Current Measures: NQF staff have compiled the 2016
MSSP measures in a spreadsheet organized according to concepts.
The material for this program was
drawn directly from the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: The Merit-Based Incentive Payment
System (MIPS) is established by H.R. 2 Medicare Access and CHIP Reauthorization
Act of 2015 (MACRA), which repeals the Medicare sustainable growth rate (SGR)
and improves Medicare payment for physician services. The MACRA consolidates the
current programs of the Physician Quality Reporting System (PQRS), The
Value-Based Modifier (VM), and the Electronic Health Records (EHR) Incentive
Program into one program (MIPS) that streamlines and improves on the three
distinct incentive programs. MIPS will apply to doctors of medicine or
osteopathy, doctors of dental surgery or dental medicine, doctors of podiatric
medicine, doctors of optometry, chiropractors, physician assistants, nurse
practitioners, clinical nurse specialists, and certified registered nurse
anesthetists beginning in 2019. Other professionals paid under the physician fee
schedule may be included in the MIPS beginning in 2021, provided there are
viable performance metrics available. Positive and negative adjustments will be
applied to items and services furnished beginning January 1, 2019 based on
providers meeting a performance threshold four performance categories: quality,
resource use, clinical practice improvement activities, and meaningful use of
certified EHR technology. Adjustments will be capped at 4 percent in 2019; 5
percent in 2020; 7 percent in 2021; and 9 percent in 2022 and future years.
High Priority Domains for Future Measure Consideration: In the CY
2016 PFS Rule, CMS will not propose the implementation of measures that do not
meet the MIPS criteria of performance and measure set gaps. MIPS has a priority
focus on outcome measures and
15
measures that are relevant for specialty
providers. CMS identifies the following domains as high-priority for future
measure consideration:
- Person and caregiver-centered Experience and Outcomes
- CMS wants to specifically focus on patient reported outcome measures
(PROMs)
- Communication and Care Coordination
- Measures addressing coordination of care and treatment with other
providers
- Appropriate Use and Resource Use
Measure Requirements: CMS applies criteria for measures that may be
considered for potential inclusion in the MIPS. At a minimum, the following
criteria and requirements must be met for selection in the MIPS:
CMS is
statutorily required to select measures that reflect consensus among affected
parties, and to the extent feasible, include measures set forth by one or more
national consensus building entities.
To the extent practicable, quality
measures selected for inclusion on the final list will address at least one of
the following quality domains: clinical care, safety, care coordination, patient
and caregiver experience, and population health and prevention.
- Measures implemented in MIPS may be available for public reporting on
Physician Compare.
- Preference will be given to electronically specified measures
(eCQMs)
- eCQMs must meet EHR system infrastructure requirements, as defined by the
future MIPS regulation.
- The data collection mechanisms must be able to transmit and receive
requirements as identified in future MIPS regulation. For example, eCQMs
must meet QRDA standards.
- Measures must be fully developed and tested.
- Reliability and validity testing must be conducted for measures.
- Feasibility testing must be conducted for eCQMs.
- Measures should not duplicate other measures currently in the MIPS.
Duplicative measures are assessed to see which would be the better measure for
the MIPS measure set.
- Measure performance and evidence should identify opportunities for
improvement. CMS does not intend to implement measures in which evidence
identifies high levels of performance with little variation or opportunity for
improvement, e.g. measures that are “topped out.”
Current Measures: NQF staff have compiled the 2016
MIPS measures in a spreadsheet organized according to concepts.
The material for this program was drawn directly from
the CMS
Program Specific Measure Priorities and Needs document, which was released
in May 2015.
Program History and Structure: Section 10331 of the 2010 Patient
Protection & Affordable Care Act (ACA) requires CMS to establish the
Physician Compare website to publicly report physician performance data. The
goal of the Physician Compare website is to provide reliable information for
consumers to encourage informed health care decisions; and to create explicit
incentives for physicians to maximize performance. To meet the statutory
mandate, CMS repurposed the Medicare.gov Healthcare Provider Directory into
Physician Compare. On December 30, 2010, CMS officially launched the Physician
Compare website using the Medicare Provider Enrollment, Chain, and Ownership
System (PECOS) as its underlying data source. Based on stakeholder feedback and
understanding the Affordable Care Act (ACA) requirements for the site, CMS
redesigned Physician Compare in June 2013. Since that time, CMS has been working
continually to enhance the site and its functionality, improve the information
available, and include more and increasingly useful information about the
physicians and other health care professionals who are on the website.
The 2012 Physician Fee Schedule final rule indicated that the first measures
available for public reporting on Physician Compare would be a sub-set of the
2012 Physician Quality Reporting System (PQRS) Group Practice Reporting Option
(GPRO) measures collected via the Web Interface. CMS publicly reported this
first set of measure data in February 2014 for the 66 group practices and 141
ACOs. In December 2014, the next phase of public reporting was accomplished with
the posting of a sub-set of the 2013 PQRS GPRO Diabetes Mellitus (DM) and
Coronary Artery Disease (CAD) measures collected via the Web Interface for 139
group practices and 214 Shared Savings Program and 23 Pioneer ACOS. In addition,
CAHPS for ACO summary survey measures were added to Physician Compare. The
following quality measures were publicly reported in December 2014:
2013
PQRS GPRO and ACO measures
- A sub-set of 3 DM and 1 CAD Web Interface measures.
- Diabetes: High Blood Pressure Control
- Diabetes: Hemoglobin A1c Control (<8%)
- Diabetes: Daily Aspirin or Antiplatelet Medication Use for Patients with
Diabetes and Ischemic Vascular Disease
- Coronary Artery Disease (CAD): ACE-I/ARB Therapy – Diabetes or
LVSD
2013 CAHPS for ACOs measures
- 4 CAHPS for ACOs summary survey measures.
- Getting timely care, appointments, and information
- How well providers Communicate
- Patient’s Rating of Provider
- Health Promotion & Education
For 2014 data, all PQRS
GPRO measures collected via the Web Interface, as well as a sub-set of measures
reported via registry and EHR are available for public reporting on Physician
Compare. All measures reported by Shared Savings Program and Pioneer ACOs are
also available for public reporting. CMS will continue to publicly report 2014
CAHPS for ACOs and will publish the first set of CAHPS for PQRS measures for
groups of 100 or more EPs who participate in PQRS GPRO and for group practices
of 25-99 EPs reporting via a certified CAHPS vendor. In addition, twenty
individual measures reported by EPs under the 2014 PQRS via claims, EHR, or
registry are available for public reporting. All 2014 data are targeted for
publication in late 2015.
For 2015 data, at the group practice level,
all 2015 PQRS GPRO measures reported via the Web Interface, registry, or EHR are
available for public reporting. In addition, the 12 summary survey 2015 CAHPS
for PQRS and CAHPS for ACO measures are available for public reporting for group
practices of 2 or more EPs and ACOs reporting via a CMS-approved certified
survey vendor. At the individual EP level, all 2015 PQRS measures reported via
registry, EHR, or claims are available for public reporting. In addition,
individual EP-level 2015 Qualified Clinical Data Registry (QCDR) measures,
which include PQRS and non-PQRS data, will be available for public reporting on
Physician Compare in late 2016.
Current Program Measure Information: Table 1 below provides the
number of quality measures under each domain of measurement from the National
Quality Strategy (NQS) priorities that were finalized in the 2012, 2013, 2014
and 2015 PFS final rules as available for public reporting. Only those measures
that are comparable, valid, reliable, and suitable for public reporting will be
publicly reported on Physician Compare (see “Measure Requirements”
below).
Table 1: Quality Measures Finalized for Public Reporting by
the 2012, 2013, 2014, & 2015 PFS Final Rules
NQS Priority
Domains
|
Number of Measures Finalized
for Potential Reporting on Physician Compare
|
2012 PFS Final
Rule
|
2013 PFS Final
Rule
|
2014 PFS Final
Rule
|
2015 PFS Final
Rule
|
Groups
|
ACOs
|
Groups
|
ACOs
|
EPs
|
Groups
|
ACOs
|
EPs
|
Groups
|
ACOs
|
Effective Clinical Care
|
27
|
20
|
20
|
20
|
13
|
14
|
14
|
110
|
138
|
8
|
Patient Safety
|
1
|
1
|
1
|
1
|
2
|
2
|
2
|
26
|
34
|
2
|
Communication/Care Coordination
|
1
|
1
|
1
|
1
|
0
|
0
|
|
29
|
37
|
0
|
Community/Population Health
|
0
|
0
|
0
|
0
|
5
|
5
|
5
|
14
|
15
|
5
|
Efficiency and Cost Reduction
|
0
|
0
|
0
|
0
|
0
|
0
|
0
|
15
|
16
|
0
|
Person and Caregiver Centered Experience and
Outcomes
|
0
|
0
|
25
|
35
|
0
|
12
|
12
|
12
|
14
|
12
|
High Priority Domains for Future Measure Consideration: As we move
more toward expanded public reporting, it is critical to include
consumer-friendly measures. This means that measure development needs to focus
on creating measures that look at the types of information consumers need to
know to make informed health care decisions. PQRS was originally a
pay-for-reporting program without explicit intent to publicly report quality
measures. However, starting with 2015 data, all PQRS measures are available for
public reporting on Physician Compare. Based on this expansion of public
reporting and the changing use of PQRS measures, it is critical to consider
public reporting and the consumer perspective during measure development. CMS
identified the key areas to consider when developing consumer-friendly
measures.
- Outcome measures
- Composite measures
- Risk adjusted measures
Consumer testing has also shown that
users prefer outcome measures over process measures. In order for quality
measures to be meaningful to consumers, they must resonate with consumers. We
often hear that consumers do not think process measures are useful. They want to
understand if patients like them better or if a procedure was successful. This
is the information that will help them make informed decisions.
Composite
measures can help consumers accurately interpret measures in a way that is
meaningful to them while also removing the burden of interpretation from them.
Composite measures help make data more digestible. It is much easier for a
consumer to understand that a doctor is good at diabetes care, for instance,
than it is to understand why it is important for a doctor to perform well across
a series of technical measures about glucose levels and treatment best
practices. Similarly, risk adjustment can ensure that consumers are more
accurately comparing health care professionals and group practices.
Consumers can provide valuable feedback when engaged early in the measure
development process. They can determine if measures are understandable and
useful in decision making. We understand that all measures are not intended for
public reporting. However, the continued growth of public reporting makes the
consumer perspective increasingly important. Moving towards more
consumer-friendly measures, specifically outcome measures, composite measures,
and risk-adjusted measures, will be instrumental toward achieving Physician
Compare’s goal, as defined by the Affordable Care Act, of providing consumers
useful quality data to inform health care decisions.
Measure Requirements: Although CMS has finalized the quality
measures listed in Table 1 for public reporting, not all of these quality
measures may ultimately be suitable for public reporting. Only comparable,
valid, reliable, and accurate data will be publicly reported. For example, the
performance results for certain measures may not be statistically reliable if
the total number of patients reported on is low. Hence, to select a sub-set of
quality measures finalized for public reporting, CMS will need to analyze the
actual measure performance results collected for each program year. At minimum,
any quality measures selected for public reporting must meet the following
criteria:
- As statutorily mandated, quality measures must be statistically valid and
reliable, and risk adjustment should be considered for outcome measures as
appropriate.
- They must be readily comprehensible to users so that users can leverage
the performance information to inform their health care decisions.
- They should enable users to make meaningful and valid comparisons of
performance results across health care professionals and group practices by
having the following properties:
- There should be sufficient variation in the performance rates, since
comparisons would be difficult if the majority of providers are clustered at
one or two performance rates.
- There should be room for improvement in the measure performance.
- There should be a sufficient number of cases in the measure denominator,
since performance rates that are based only on a handful of cases may result
in unreliable rates and make statistically valid comparisons difficult.
- There should be a sufficient number of health care professionals or
group practices in each peer group comparison.
In addition,
CMS will not publish any measures that are in their first year and only those
measures that prove to resonate with consumers and are deemed to be relevant to
consumers will be included on the profile pages of the website. All other
comparable, valid, reliable, and accurate measures would be included in a
publicly available downloadable database, similar to the databases currently
available on data.medicare.gov.
Current Measures: The measures for Physician Compare are drawn from
PQRS/MIPS, and NQF staff compiled the 2016
MIPS measures in a spreadsheet.
Index of Measures (by Program)
All measures are included in the
index, even if there were not any public comments about that measure for that
program.
General Comments
Ambulatory Surgical Center Quality Reporting Program
End-Stage Renal Disease Quality Incentive Program
Hospital Acquired Condition Reduction Program
Home Health Quality Reporting Program
Hospital Inpatient Quality Reporting and EHR Incentive Program
Hospital Outpatient Quality Reporting Program
Hospice Quality Reporting Program
Hospital Value-Based Purchasing Program
Inpatient Psychiatric Facility Quality Reporting Program
Inpatient Rehabilitation Facility Quality Reporting Program
Long-Term Care Hospital Quality Reporting Program
Merit-Based Incentive Payment System (MIPS)
Medicare Shared Savings Program
Prospective Payment System-Exempt Cancer Hospital Quality Reporting
Program
Skilled Nursing Facility Quality Reporting System
Skilled Nursing Facility Value-Based Purchasing Program
Full Comments (Listed by Measure)
- We agree with MAP's support of this measure. (Submitted by:
Medtronic)
- Novo Nordisk supports MAP’s identified gap areas for federal clinician
programs Novo Nordisk applauds MAP for driving a future vision for federal
clinician programs, including the MIPS program, through the identification of
gap areas for these programs. MAP recognizes that, while gaps have been
addressed in clinician programs in recent years, there is still a need to
identify the right measures to hold physicians accountable. In particular,
Novo Nordisk supports MAP’s assertion that additional (or updated) measures
are needed to better address patient preferences and needs. As MAP notes, more
measures are needed to reflect the outcomes of care that are of most important
to patients (including patient-reported outcomes). This is especially true for
chronic conditions, including diabetes, where treatment success could be
defined from a patient’s perspective in addition to clinical quality.
(Submitted by: Novo Nordisk)
- Novo Nordisk supports MAP’s recommendations around the expanded public
reporting of quality data through Physician Compare. Specifically, Novo
Nordisk agrees with MAP’s discussion around the need to identify measures that
are most important to patients for public reporting, emphasizing the need to
involve patients early on in the measure development process. In addition,
Novo Nordisk supports MAP’s discussion regarding the need to improve the
usability of public reporting sites, including Physician Compare, for
consumers to support consumer decision making. Tools such as these will only
become more relevant as patients continue to have access to decision-making
regarding the care they receive. (Submitted by: Novo Nordisk)
- We recognize that this measure has been created in response to the USPSTF
recommendations against PSA screening regardless of age. This recommendation
conflicts with the current recommendations released by the American Urological
Association in 2013, which emphasizes that an individual’s values and
preferences must be taken into account and for this reason the recommendation
focuses on shared decision-making between the physician and patient. In
addition, the USPSTF released a draft research plan on prostate cancer
screening for public comment in October 2015 to update the current set of
recommendations. We are concerned that this measure as currently specified
could negatively impact the physician-patient relationship and support the MAP
recommendation to not encourage further consideration of the measure. A
measure addressing this important area should not be considered until the
discrepancy between the guideline recommendations are addressed. (Submitted
by: American Medical Association)
- Key Program Needs Page 6 The American Academy of Dermatology agrees with
the gap areas described in the report, particularly the need for measures for
specialty care, appropriate use of resources and communication and care
coordination. Dermatology measures under consideration address these areas and
we encourage your support. We also recognize the need for outcome measures,
including patient reported outcomes, and continue our long term efforts to
promote research on assessment tools, develop clinical guidelines and to
develop and test outcome measures. (Submitted by: American Academy of
Dermatology)
- In general, we support NQF's MAP recommendations. We have concerns
however with the proposed CMS merit payment system particularly as they relate
to individuals with disabilities. We wanted to share our comments previously
submitted to CMS with the MAP team: SPAN & Family Voices-New Jersey
comments on the Request for Information Regarding Implementation of the
Merit-Based Incentive Payment System, Promotion of Alternative Payment Models,
and Incentive Payments for Participation in Eligible Alternative Payment
Models November 2, 2015 Thank you for the opportunity to comment on the RFI
regarding proposed rule regarding Merit-Based Incentive Payment System (MIPS)
and the Alternative Payment Models (APM). The Statewide Parent Advocacy
Network (SPAN) is NJ’s federally designated Parent Training and Information
Center. Family Voices (FV) is a national network that works to “keep families
at the center of children’s healthcare.” The NJ State Affiliate Organization
for FV is housed at SPAN, which is also the home of the Family-to-Family
Health Information Center and chapter of the Federation of Families for
Children’s Mental Health. Our comments follow. SUMMARY: SUPPLEMENTARY
INFORMATION: I. Background We understand that Section 101 of the Medicare
Access and CHIP Reauthorization Act of 2015 (MACRA)…establishes a new
methodology that ties annual PFS [physician fee schedule] payment adjustments
to value through a Merit-Based Incentive Payment System (MIPS) for MIPS
eligible professionals (MIPS EPs). Section 101 of the MACRA also creates an
incentive program to encourage participation by eligible professionals (EPs)
in Alternative Payment Models (APMs).” A. The Merit-Based Incentive Payment
System (MIPS) We understand that the “Secretary is required to: (1) develop a
methodology for assessing the total performance… (2)…provide for a composite
performance score…and (3) use the composite performance score…for a year to
determine…a MIPS adjustment factor.” We also understand that the “composite
performance score is determined using four performance categories: quality,
resource use, clinical practice improvement activities, and meaningful use of
certified EHR technology (CEHRT).” B. Alternative Payment Models We understand
that this rule “(1) creates a payment incentive program that applies to EPs
who are qualifying APM participants (QPs) for years from 2019 through 2024;
(2)…process for stakeholders to propose PFPMs to an independent
“Physician-Focused Payment Model Technical Advisory Committee” (the
Committee).” We also understand that comment is sought on “(1) requirements
to be considered an eligible alternative payment entity and QP; (2) the
relationship between APMs and the MIPS; and (3) criteria for the Committee to
use to provide comments and recommendations on PFPMs.” C. Technical Assistance
to Small Practices and Practices in Health Professional Shortage Areas In
addition, we understand that this rule allows “the Secretary to enter into
contracts or agreements with appropriate entities…to offer guidance and
assistance to MIPS EPs in practices of 15 or fewer professionals.” II.
Solicitation of Comments A. The Merit-Based Incentive Payment System (MIPS) 1.
MIPS EP Identifier and Exclusions We understand this rule includes definitions
for “a physician (as defined in section 1861(r) of the Act), a physician
assistant (PA), nurse practitioner (NP) and clinical nurse specialist (CNS)
(as those are defined in section 1861(aa) (5) of the Act), a certified
registered nurse anesthetist (CRNA).” We further understand this will
“include all the types of professionals identified for the first 2 years. It
also gives the Secretary discretion to specify additional Eps…which could
include a certified nurse midwife…clinical social worker…clinical
psychologist…registered dietician or nutrition professional, a physical or
occupational therapist, a qualified speech-language pathologist, or a
qualified audiologist.” We comprehend that comment is sought on “specific
identifier(s)…used to appropriately identify MIPS EPs for purposes of
determining eligibility, participation, and performance under the MIPS
performance categories.” We understand that comments are needed on using
“MIPS EP’s TIN, NPI or a combination” or to “create a distinct MIPS
Identifier” and the advantages/ disadvantages of these. Although it seems
simpler to use existing identifiers, for the purposes of this rule a separate
MIPS identifier is preferable. If used for an individual rather than group,
this would also address the confusion of providers participating in multiple
practices as well as calculating “performance for MIPS EPs that practice under
multiple TINs.” We also agree that “practitioners in a virtual group…have a
unique virtual…identifier.” We think that “EP or group practice [should}
update any such identifier(s)” annually. Again, we think that using
individual rather than group identifiers will create “safeguards …to ensure
that MIPS EPs do not switch identifiers if they are considered
‘poor-performing” and prevent other unintended consequences. 2. Virtual
Groups We understand that “The virtual group option under the MIPS allows a
group’s performance to be tied together even if the EPs in the group do not
share the same TIN.” We understand that comment is sought on “eligibility,
participation, and performance” and how “remaining members of the TIN be
treated under the MIPS” if TINs are “split”. Again, this is why we think
individual providers using specific identifiers works best. We don’t think
there needs to be a “maximum or a minimum size for virtual groups” although we
need more clarification on the “limit placed on the number of virtual group
elections that can be made for a particular performance period for a year as
this provision is rolled out.” If there are limitations on elections, we
agree that this should be on a first-come, first-served basis.” We are unsure
as to “what type of information should be required in order to make the
election for a performance period for a year.” We agree that “a virtual group
may be based on appropriate classifications of providers, such as by specialty
designations or by geographic areas.” We do not think, however, that there
needs to be a distance limit on a virtual group. 3. Quality Performance
Category We understand that the rule seeks to “establish the list of quality
measures from which MIPS EPs may choose for purposes of assessment for a
performance period for a year.” a. Reporting Mechanisms Available for
Quality Performance Category We acknowledge that “There are two ways EPs can
report under the PQRS, as either an individual EP or as part of a group
practice, and…there are collectively 7 available
mechanisms…claims-based…qualified registry…QCDR [qualified clinical data
registries] …direct EHR products; EHR data submission…Consumer Assessment of
Healthcare Providers and Systems (CAHPS) … GPRO Web Interface.” We think that
the most effective mechanisms are claims-based, use of EHR, and CAHPS. We
agree that there should be “similar reporting criteria under MIPS as under the
PQRS.” We also agree with maintaining “the policy that measures cover a
specified number of National Quality Strategy domains.” We agree that “a
minimum number of measures [should] be outcomes-based.” We strongly agree
with the “ability to stratify the data by demographic characteristics such as
race, ethnicity, and gender” as this will address health disparities. Again,
we strongly support that “For the CAHPS for PQRS reporting option
specifically” it could be used for both “the quality performance category or
as part of the clinical practice improvement.” We are unsure how to “apply
the quality performance category to MIPS EPs that are in specialties that may
not have enough measures to meet our defined criteria” as data needs to be
statistically significant and are also uncertain of “potential barriers to
successfully meeting the MIPS quality performance category.” b. Data Accuracy
We acknowledge that “Some potential data quality issues….include: inaccurate
TIN and/or NPI, inaccurate or incomplete calculations of quality measures,
missing data elements, etc.” We are unsure as to what should be required “in
terms of testing of the qualified registry, QCDR, or direct EHR product, or
EHR data submission vendor product.” However, we do agree that “registries
and qualified clinical data registries [should] be required to submit data to
CMS using certain standards, such as the Quality Reporting Document
Architecture (QRDA) standard, which certified EHRs are required to support” as
this will aid in consistency. We think that “qualified registries, QCDRs, and
health IT systems [should] undergo review and qualification by CMS” for this
reason. Feedback regarding patterns of data inconsistency such as those
mentioned above would be most beneficial to stakeholders. We would defer
decisions regarding “thresholds for data integrity” to the CMS Data Analytics
and Systems Group. We are uncertain how CMS should assess a quality
performance category score when “the MIPS EP (participating as an individual
EP or as part of a group practice or virtual group) has used a data reporting
mechanism that does not meet our data integrity standards.” c. Use of
Certified EHR Technology (CEHRT) Under the Quality Performance Category
Although we are unable to ascertain “what should constitute use of CEHRT for
purposes of reporting quality data,” we would recommend actual data
transmission in lieu of using “the EHR to capture and/or calculate the quality
data.” 4. Resource Use Performance Category We understand that “Currently…we
use the following cost measures: (1) Total Per Capita Costs for All Attributed
Beneficiaries measure; (2) Total Per Capita Costs for Beneficiaries with
Specific Conditions…and (3) Medicare Spending per Beneficiary (MSPB) measure.”
We would agree with measures “associated with services that are potentially
harmful or over-used” particularly as they relate to health disparities. We
are uncertain how to “apply the resource use category to MIPS EPs for whom
there may not be applicable resource use measures.” We think that
“episode-based costs… play in calculating resource use and/or providing
feedback reports to MIPS EPs” especially as they relate to preventable medical
errors or avoidable rehospitalization. We would suggest caution in analysis of
hospitalization diagnosis as these could be changed to another condition to
avoid the appearance of a 30 day readmission. We are unsure how to “consider
aligning measures used under the MIPS resource use performance category with
resource use based measures used in other parts of the Medicare program” or
how to “incorporation Part D drug costs” as with the exception of dual
eligibles transitioning from pediatric to adult care, most of our experience
is with the Medicaid population. Other than utilizing the medical home
concept, we have no additional suggestions regarding which “peer groups or
benchmarks should be used when assessing performance under the resource use
performance category.” We are unsure of how to implement but agree with
aligning “resource use measures with clinical quality measures.” 5. Clinical
Practice Improvement Activities Performance Category We understand that
“measures and activities for the clinical practice improvement activities
performance category must include at least the following subcategories of
activities: expanded practice access, population management, care
coordination, beneficiary engagement, patient safety and practice assessment,
and participation in an APM.” Regarding “clinical practice improvement
activities,” we strongly agree with a “subcategory of Promoting Health Equity
and Continuity, including (a) serving Medicaid beneficiaries, including
individuals dually eligible…(b) accepting new Medicaid beneficiaries, (c)
participating in the network of plans in the Federally facilitated Marketplace
or state exchanges, and (d) maintaining adequate equipment and other
accommodations.” One of the barriers in our state after the implementation of
mandatory managed care under Medicaid for people with disabilities was that
the offices, exam tables, and equipment weren’t accessible. We are still
finding network adequacy as an issue, particularly for specialists, and
provider directories are outdated or do not indicate that providers are not
accepting new patients. We would also strongly agree with a “subcategory of
Social and Community Involvement, such as measuring completed referrals to
community and social services or evidence of partnerships and collaboration
with the community and social services.” Indeed, community based resources
were the most common information request in our medical home project. We
strongly support a “subcategory of Achieving Health Equity…for EPs that
achieve high quality for underserved populations, including persons with
behavioral health conditions, racial and ethnic minorities, sexual and gender
minorities, people with disabilities, and people living in rural areas, and
people in HPSAs.” We also strongly support a “subcategory of emergency
preparedness and response” but this must include people with disabilities.
Further, we strongly support an “integration of primary care and behavioral
health” as we have seen success in our pilot project using child psychiatrists
in a consultative model in NJ which is expanding statewide. We think that
the most effective way or reporting should require “EPs…to attest directly to
CMS through a registration system, web portal or other means…rather than
having “qualified registries, QCDRs, EHRs, or other health IT systems be able
to transmit results of the activities to CMS.” We would again defer the
decisions on information regarding “quality checks and/or data validation” to
the CMS Data Analytics and Systems Group.” We think that providers should
“report or attest that they have met the required activities” annually.
Regarding assessment on “performance on the clinical practice improvement
activities category,” we think that the “quantity of activities” could be
measured either using the “number of clinical practice improvement activities,
or…a specific number of hours.” We think that subcategories regarding
outcomes and health disparities should be “weighted more than others.” We are
uncertain as to how to “define the subcategory of participation in an APM.”
We would suggest for EPs “practicing in these types of small practices or
rural areas” that they be included but only if the sample size doesn’t affect
the validity of results which can be accomplished by performing a sample size
calculation. We do not agree, however with a “lower performance threshold”
because then the minimum becomes the “new maximum” and expectations as well as
outcomes are lowered. We agree that the “15 or less” number will
“appropriately identify these practices.” We think that “best practices should
be considered to develop flexible and adaptable clinical practice improvement
activities based on the needs of the community and its population” which are
based on the unique needs of that community, including cultural and linguistic
competency. 6. Meaningful Use of Certified HER Technology Performance
Category We understand that the “Secretary estimates that the proportion of
eligible professionals who are meaningful EHR users is 75 percent or greater”
and that comments are not being solicited on “Medicare and Medicaid EHR
Incentive Programs.” We think that the “performance score for this category
be based be based solely on full achievement of meaningful use.” We agree
that CMS should “use a tiered methodology for determining levels of
achievement in this performance category that would allow EPs to receive a
higher or lower score based on their performance relative to the thresholds
established in the Medicare EHR Incentive program’s meaningful use objectives
and measures.” We agree that the scoring should “be based on an EP’s
performance relative to the performance of his or her peers.” An alternate
methodology could include a practice growth type model using longitudinal data
on improvement strategies for the practice. We do not agree that there should
be “hardship exemptions” except in extreme cases which would prevent a
practice from progressing such as natural disaster etc. 7. Other Measures We
understand that this rule “allows the Secretary to use measures that are used
for a payment system other than the PFS, such as measures for inpatient
hospitals…except in the case of items and services furnished by emergency.”
We agree that outcomes and population based measures will best suit this
purpose and also help identify areas of health disparities. We would agree
with using “measures that are used under the Hospital Inpatient Quality
Reporting Program, the Hospital Value-Based Purchasing Program, or other
quality reporting” but are uncertain on how it could be leveraged. We think
“this option [should] be available to all EPs.” We are unable to ascertain
how “CMS [should] link an EP to a facility in order to use measures from other
payment Systems.” We agree that “global and population-based measures should
be included” and again would recommend those based on outcomes and health
disparities. We are unaware of “what data sources are available” so would
defer this decision to CMS Data Analytics. We would agree that there should
be some measure of providers “that do not involve face-to-face interaction
with patients…such pathologists and certain types of radiologists.” This
could be defined as those professionals that, although they may not have
direct interaction, affect patient outcomes, and would exclude telemedicine.
It could be possible to use “specialty codes in PECOS [Provider Enrollment,
Chain, and Ownership System], use encounter codes that are billed to Medicare”
but could also include claims or encounter date from Medicaid. The same four
categories (quality, resource use, clinical practice improvement activities,
and meaningful use of certified HER) should be applied equally to
“non-patient-facing Eps.” Practice improvement activities could still include
error reduction in actual data and also transmission of data. 8. Development
of Performance Standards We agree with the use of “historical performance
standards” as well as for “the clinical practice improvement activities
performance category…historical data sources” which could include outcomes and
CAHPS results. Continued improvement isn’t just based on cost-savings, which
often results in denial or lack of access to care. Rather evidence based
outcomes such as the medical home model should be utilized. The scoring
system must be outcomes based in order to be effective. We think that once
baseline data is established, practices who achieve this will not be penalized
if targets are reasonable and achievable for continuous improvement
activities. We agree that CMS should use “the same approach for assessing
improvement as is used for the Hospital Value-Based Purchasing Program,” in
which “hospitals are paid… for the quality of care, not just quantity of the
services they provide.” We think it is preferable for CMS to “consider
improvement at the measure level…rather than “at the composite performance
score level” which will target areas in need of improvement. We strongly
agree that “improvements in health equity and the reductions of health
disparities [should] be considered in the definition of improvement,”
particularly in light of a recent report on health disparities and people with
developmental disabilities. We agree with public reporting using “Physician
Compare” and would support “using this methodology for determining the MIPS
performance standards for one or more performance categories.” 9. Flexibility
in Weighting Performance Categories We cannot think of an example in which
there are “situations where certain EPs could not be assessed at all for
purposes of a particular performance category.” Therefore we do not agree
that “the weight for a given performance category should be modified or should
not apply to an EP” if “there are not sufficient measures and activities
applicable and available to types of EPs.” We would recommend a “case minimum
threshold” as stated above in which the sample size would not affect validity
by utilizing a sample size calculation beforehand. This will ensure the most
accurate statistical significance. 10. MIPS Composite Performance Score and
Performance Threshold We understand that this rule “requires the Secretary to
develop a methodology for assessing the total performance of each MIPS EP
based on performance standards with respect to applicable measures and
activities in each of the four performance categories.” Again, we would
suggest assessing “performance on each of the 4 performance categories”
separately rather than “combine the assessments to determine a composite
performance score.” We would agree with using “a methodology (for example,
equal weighting of quality and resource use measures across National Quality
Strategy domains).” We would agree with using “existing data on quality
measures and resource use measures to translate the data into a performance
threshold for the first two years of the program” by establishing baseline
data and achievable targets, with an opportunity to examine longitudinally if
the base threshold needs to be revised. Again, “minimum case size thresholds”
would need to consider sample size calculation not affecting validity.
Again, we think that performance must be linked “under one category” rather
than as a composite score. 11. Public Reporting We think that “publicly
reporting MIPS measures and activities for all of the MIPS performance
categories on the Physician Compare website” should be done annually. We
understand that CMS “will continue using a minimum 20 patient threshold for
public reporting through Physician Compare of quality measures (in addition to
assessing the reliability, validity and accuracy of the measures).” Once
again, we strongly agree that CMS should “include individual EP and group
practice-level quality measure data stratified by race, ethnicity and gender
in public reporting” to address disparities in underserved populations. 12.
Feedback Reports We agree that CMS should “make available timely confidential
feedback to MIPS EPs on their performance.” We think that performance by
category would be the most beneficial to practices. We agree that it would “be
beneficial for EPs to receive feedback information related to the clinical
practice improvement activities and meaningful use of certified EHR technology
performance categories” and there also must be consideration to health
literacy as the single largest barrier to healthcare access. We agree that
the current use of “feedback reports for the PQRS, VM, and the Physician
Feedback Program through a web-based portal” is sufficient. We think that in
addition to the “authorized group practice representative” that “an
organization providing MIPS-focused technical assistance, another provider
participating in the same virtual group, or a third party data intermediary
who is submits data to CMS on behalf of the EP, group practice, or virtual
group” should be able to access data as long as individual health privacy
information is protected and reporting is done in the aggregate. Feedback
should be given, at minimum, at least annually. We strongly support that
reports should “include data that is stratified by race, ethnicity and gender
to monitor trends and address gaps towards health equity” to address
disparities. We seek clarification about what “types of information about
items and services furnished to the EP’s patients by other providers would be
useful.” B. Alternative Payment Models 1. Information Regarding APMs We
understand that “an EAPM [eligible alternative payment entity] entity is an
entity that: (1) participates…use certified EHR technology … and (2) either
bears financial risk for monetary losses under the APM that are in excess of a
nominal amount or is a medical home . We understand that “For the years
2019 through 2024, EPs who are QPs for a given year will receive an incentive
payment equal to 5 percent of the estimated aggregate Part B Medicare payment
amounts for covered professional services for the preceding year.” a. QPs and
Partial Qualifying APM Participants (Partial QPs) We understand that “an EP
may be determined to be a QP through: (1) beginning for 2019, a Medicare
payment threshold option that assesses the percent of Medicare Part B
payments… services furnished through an EAPM entity; or (2) beginning for
2021, either a Medicare payment threshold option or a combination all-payer
and Medicare payment threshold option.” We further understand that “The
combination all-payer and Medicare payment threshold option assesses both: (1)
the percent of Medicare payments…furnished through an EAPM entity; and (2) the
percent of the combined Part B Medicare payments for covered professional
services attributable to an EAPM entity.” We also understand that “These
arrangements must be arrangements in which: (1) quality measures comparable to
those used under the MIPS apply; (2) certified EHR technology is used, and (3)
either the entity bears more than nominal financial risk…or the entity is a
medical home.” We comprehend that “For 2019 and 2020, the Medicare-only
payment threshold requires that at least 25 percent of all Medicare payments
be attributable to services furnished through an EAPM entity. This threshold
increases to 50 percent for 2021 and 2022, and 75 percent for 2023 and later
years.” In addition, we acknowledge that “The combination all-payer and
Medicare payment threshold option is available beginning in 2021. The combined
all-payer and Medicare payment thresholds are, respectively, 50 percent of
all-payer payments and 25 percent of Medicare payments in 2021 and 2022, and
75 percent of all-payer payments and 25 percent of Medicare payments in 2023
and later years.” We understand that similarly for “partial QPs, the
Medicare-only payment thresholds are 20 percent (instead of 25 percent) for
2019 and 2020, 40 percent (instead of 50 percent) for 2021 and 2022, and 50
percent (instead of 75 percent) for 2023 and later years. For partial QPs, the
combination all-payer and Medicare payment thresholds are, respectively, 40
percent (instead of 50 percent) all-payer and 20 percent (instead of 25
percent) Medicare in 2021 and 2022, and 50 percent (instead of 75 percent)
all-payer and 20 percent (instead of 25 percent) Medicare in 2023 and later
years.” b. Payment Incentive for APM Participation We are unsure how CMS
should define “services furnished under this part through an EAPM entity” and
how to reconcile “calculating incentive payments for APM participation when
the prior period payments were made to an EAPM entity rather than directly to
a QP.” We think that the Secretary should “consider…aggregate payment amounts
when payments are made on a basis other than fee-for-service…if payments were
made on a capitated basis)” although capitation was supposed to improve on the
traditional fee-for-service model, there are drawbacks. Some providers are
seeing low rather than competitive reimbursement rates while others may be
incentivized to provide less care or lower cost medications. Due to this, we
would suggest possible carve out of some services to fee for service. We
cannot ascertain how “EPs submit to CMS for purposes of determining whether
they meet the non-Medicare share of the Combination All-Payer and Medicare
Payment Threshold.” c. Patient Approach We understand that “the Secretary
can use percentages of patient counts in lieu of percentages of payments to
determine whether an EP is a QP or partial QP.” However we are unaware of
“examples of methodologies for attributing and counting patients in lieu of
using payments to determine whether an EP is a QP or partial QP” so cannot
determine if “this option [should] be used in all or only some circumstances.”
d. Nominal Financial Risk Although we are aware of different types of
“financial risk,” we are unsure how to define “in excess of a nominal amount”
or “more than nominal financial risk if actual aggregate expenditures exceed
expected aggregate expenditures” thus are unable to provide reference points.
e. Medicaid Medical Homes or Other APMs Available Under State Medicaid
Programs It would be difficult to “determine “comparability of state Medicaid
medical home models to medical home models expanded under section 1115A(c) of
the Act” due to state differences in Medicaid models. Therefore we are unsure
“Which states’ Medicaid medical home models might meet criteria.” We would
not suggest “alternative payment models – besides Medicaid medical homes” as
we think that the patient-centered medical home is the best model of care both
in terms of cost effectiveness and best outcomes. f. Regarding EAPM Entity
Requirements Again, we understand that “An EAPM entity is defined as an entity
that (1) participates in…certified EHR technology …and (2) bears financial
risk for monetary losses…or is a medical home.” (1) Definition We are unsure
“What entities should be considered EAPM entities.” (2) Quality Measures
Although we are also unable to determine “’comparability’ to MIPS of quality
measures used to identify an EAPM entity,” we would support the inclusion of
“recommended data sources for Measures” to include patients as well as family
caregivers. (3) Use of Certified EHR Technology We agree that “APM
participants [should] be required to use the same certified EHR technology
currently required for the Medicare and Medicaid HER Incentive Programs.” We
think that the “core health IT functions that providers need to manage patient
populations, coordinate care, engage patients and monitor and report quality”
would include appropriate chronic care and case management utilizing shared
decision-making. We think that the “APM [should] require participants to
report quality measures to all payers using certified EHR technology.” 2.
Information Regarding Physician-Focused Payment Models We support the section
“Increasing the Transparency of Physician-Focused Payment Models” which
“establishes an independent “Physician-focused Payment Model Technical
Advisory Committee” (the Committee).” We understand that “PFPMs are not
required by the MACRA to meet the criteria to be considered APMs…or to involve
an EAPM entity.” We agree that there should be the opportunity for “EPs…to
become QPs and receive incentive payments.” a. Definition of
Physician-Focused Payment Models Although we are unsure how “physician-
focused payment model” should be defined, we strongly support the
establishment of an independent committee. b. Criteria for Physician-Focused
Payment Models We seek more clarification on the intention to “establish
criteria that promote robust and well-developed proposals to facilitate
implementation of PFPMs.” As we do not have details, we are unable to comment
on which “criteria should be used by the Committee for assessing PFPM
proposals” or “additional or different criteria that the Committee should use
for assessing PFPMs that are specialist models.” We would suggest caution
using “existing criteria, procedures, or standards are currently used by
private or public insurance plans” as these have a vested interest in cutting
costs and decreasing health care utilization. c. Required Information on
Context of Model Within Delivery System Reform We would support “models tested
through the Center for Medicare and Medicaid Innovation Inclusion of
participants in their design who have not had the opportunity to participate
in another PFPM with CMS because such a model has not been designed to include
their specialty” but would not make this a primary focus. We agree that
proposals should state why the “model should be given priority… include a
framework for the proposed payment methodology…. If a similar model has been
tested or researched previously, [and] directly solve a current issue in
payment policy that CMS is not already addressing.” d. Required Information
on Model Design. Again we agree that the proposals should “include the same
information that would be required for any model tested through the Innovation
Center.” We would suggest that a target population should be underserved and
related to health disparities. We canno (Submitted by: Statewide Parent
Advocacy Network/Family Voices NJ)
- After reviewing the measures up for consideration for use in MIPS and the
preliminary recommendations, the American College of Rheumatology proposes
adding more specialty specific measures. Adding specialty specific measures
will add value to the measure set and encourage additional participation in
MIPS. It is important for physicians to have a variety of measures from which
to choose when participating in CMS programs. The ACR would like to stress the
importance of specialty measures as MIPS continues to develop. (Submitted by:
American College of Rheumatology)
- Dear Drs. Isham and McGlynn: The Association of American Medical Colleges
(AAMC or Association) welcomes this opportunity to comment on the National
Quality Forum (NQF) Measure Applications Partnership (MAP)’s 2016
Considerations for Implementing Measures in Federal Programs draft report. The
AAMC is a not-for-profit association representing all 145 accredited U.S.
allopathic medical schools; nearly 400 major teaching hospitals and health
systems, including 51 Department of Veterans Affairs medical centers; and
nearly 90 academic and scientific societies. Through these institutions and
organizations, the AAMC represents 148,000 faculty members, 83,000 medical
students, and 115,000 resident physicians.
The AAMC appreciates the MAP Workgroups’
thoughtful review and discussion of the measures under consideration (MUC).
The following are the AAMC’s high-level comments on the preliminary MAP
recommendations for both hospitals and clinicians: Regarding the physician
measures under consideration, the AAMC recommends that the MAP emphasize the
importance of having measures available to physicians to report that are
meaningful. Certain types of measures might be more appropriate for certain
physicians than others, and some specialties have very few measures available
to report. Therefore, we are pleased to see that CMS and the MAP are
continuing to address measurement gaps and to improve the existing set of
measures. As physicians transition to the MIPS program and alternative payment
models, CMS should take steps to limit administrative burden associated with
reporting quality measures under these programs. Reducing burden in
measurement reporting and documentation requirements will enable physicians to
focus on high quality patient care. Finally, the AAMC believes that the MAP
Workgroups should review measures in the Medicare programs holistically in
order to ensure that new measures add value, are useful for consumers, and
promote alignment, while also considering the burden to reporting these
measures for providers. While only new or revised measures are reviewed by the
MAP, a comprehensive review can only occur when the committee considers the
data collection burden imposed by existing measures. The draft MAP report,
titled “Considerations for Implementing Measures in Federal Programs” reviews
the Clinician Workgroup discussion regarding the measures under consideration
for the Merit-Based Incentive Payment System (MIPS) and the Medicare Shared
Savings Program. MIPS will consolidate the Physician Quality Reporting System
(PQRS), the Value-Modifier (VM) and the Medicare Electronic Health Record
(EHR) incentive program into one program that will adjust Medicare payments
based on performance. As part of the transition to the consolidated MIPS
program, clinician level measures under consideration were proposed by CMS for
potential implementation in 2017 and discussed extensively during the
Clinician MAP meeting. CMS identified key program needs and priorities for the
MIPS program, including outcome measures, measures relevant to specialty
providers, domains of person and caregiver experience and outcomes,
communication and care coordination and appropriate use and resource use.
Address Challenges Related to Outcome Measures in the Draft Report Outcome
measures have been identified as a priority, and CMS addressed this priority
through the inclusion of twenty-four outcome measures on the MUC list for
discussion during the MAP Clinician Workgroup meeting. We support the
development of valid and reliable outcome measures that could potentially lead
to more direct measures of quality and encourage their development. It is
also important to acknowledge that process measures that are evidence-based
can be integral to improved outcomes. Outcome measures at the physician level
can be particularly challenging when used in quality programs due to small
sample sizes, risk adjustment, attribution, and the impact of factors outside
of the physician’s control. Holding physicians accountable for factors
outside of their direct control would be unfair to physicians and misleading
to consumers. The AAMC recommends that these challenges be acknowledged in
the draft report and addressed in the future. Appropriate Use and Overuse
Measures Should be Based on Solid Evidence The MAP expressed an interest in
measures of appropriate use or overuse and acknowledged that this remains a
gap area and a priority for future development. The report states that many of
the MAP members suggested looking at the Choosing Wisely Campaign for guidance
and pairing overuse measures with measures of quality for a better
understanding of value. AAMC supports the use by physicians of evidence-based
clinical support systems to guide their treatment for particular patients. The
Choosing Wisely Campaign’s purpose is to promote conversations between
patients and their providers around potentially unnecessary tests, treatments,
and procedures. The Choosing Wisely guidelines and not intended to be
absolute. We recommend that any measures of overuse based on “Choosing Wisely”
guidelines be implemented after the specialty that provides the service have
chosen to use the guidelines to create applicable measures that are based on
solid evidence, and developed through a process that is inclusive of all
specialties that provide the service in question. In the interim, physicians
who follow the Choosing Wisely guidelines should be given credit in MIPS under
the Clinical Practice Improvement Category. AAMC Supports Team-Based Care
Measures AAMC supports the recognition in the draft report of the importance
of developing measures of team-based care. Given the complexity of patient
care, it is common for multiple clinicians to provide care to the same patient
as part of a team with the goal of the best possible care. Each clinician
relies upon information and action from other members of the team. A high
performing team is an essential tool for a patient centered, coordinated and
effective health care delivery system. In the future, it will be important to
measure how a team performs on health care quality, costs, and health
outcomes. CMS Should Ensure that Publicly Reported Data is Valid, Reliable,
Accurate, and Meaningful CMS has continued to expand clinical quality
information that is publicly reported on its Physician Compare website. CMS
intends to continue public reporting of performance results through the
Physician Compare website based on measures in the MIPS program through either
the clinician web page or through a downloadable spreadsheet. The Clinician
MAP workgroup provided input regarding which measures would be appropriate to
publicly report on the clinician web page under the MIPS program. The AAMC
recommends that in the initial years of the MIPS program, CMS include data
indicating whether an EP satisfied the reporting requirements for the quality
measure. However, calculating and displaying performance data on the public
website in the early years of the program would be premature. There are too
many challenges with measures related to risk adjustment, attribution,
sociodemogaphic factors to publicly report performance data at this early
stage. CMS should only report measures that are valid, reliable, and
accurate, and are meaningful to consumers and providers. (Submitted by:
AAMC)
- January 12, 2016 Elizabeth McGlynn, PhD, MPP and Harold Pincus, MD
Coordinating Committee Co-Chairs Measures Application Partnership 1030 15th
Street, NW Washington, DC 20005 Dear Drs. McGlynn and Pincus: On behalf of
the American Osteopathic Association (AOA) and the more than 122,000
osteopathic physicians and osteopathic medical students we represent, thank
you for the opportunity to respond to the Measures Application Partnership
(MAP) 2015-2016 Considerations for Implementing Measures in Federal Programs
draft report. The osteopathic profession strongly supported passage of the
Medicare Access and CHIP Reauthorization Act (MACRA), and remains optimistic
as we move towards a system that aligns well with the osteopathic philosophy
of care – treating the whole person with a strong focus on prevention,
wellness, and quality. During the law’s development, the AOA was especially
supportive of MACRA’s focus on the value of care provided over volume. As
defined in MACRA statute, the Merit-based Incentive Payment Systems (MIPS)
creates a new framework for assigning value to care. The MAP is strongly
positioned to favorably shape the implementation of the MIPS program and we
are pleased to provide the following comments to the MAP as it undertakes this
effort: 1. We support efforts to promote alignment of measures across federal
programs and between public- and private-sector initiatives. The proliferation
of measures in recent years from both public and private payers has created an
overwhelming volume of measures for physicians to track and report. As each
program has different measures or different definitions and/or methodologies
for given measures, physicians face challenges in tracking and reporting
applicable measures for each program. This obstacle limits physicians’
ability to participate in multiple payer programs, as each new program brings
with it additional measures and administrative burdens. While we understand
the intent of measure development and reporting is to improve health care
quality, we are concerned that the current volume and disparity of measures
requires significant and increasing time for physicians and their staffs to
track and report which detracts from health care quality. This time incurs
both financial cost for the additional staff time required to manage
appropriate tracking and reporting, but also opportunity cost for the time the
physician is occupied with tracking and reporting rather than direct care of
patients. The 2015 passage of the MACRA and introduction MIPS underscores
the need to streamline measures across programs. MIPS bridges three existing
federal measures programs: Physician Quality Reporting System (PQRS),
Value-based Payment Modifier (VBPM) and EHR Incentive programs, and adds a
fourth measures program, the Clinical Practice Improvement Activity Program.
We support streamlining and alignment across the four components of MIPS to
ensure synchronicity and lack of duplication across the programs. This
approach will support physicians’ ability to track and report relevant
measures, while maximizing their time with patients. The recognition of
alternative payment models (APMs) to meet MACRA requirements will provide yet
another opportunity to align measures between MIPS and APMs. 2. We caution
against public reporting of measures on Physician Compare. As the above-stated
issues with measure tracking and reporting are challenging for physicians,
robust measure reporting which is engrained into the workflow in health care
practices is limited. While physicians make their best efforts to comply with
required reporting, and public and private payers continue to refine and
streamline their measures programs, we support measure reports to be available
only to participating health care providers. We are concerned that present
challenges may skew the results of measure reporting, especially for small and
rural practices who face additional limitations in resources. The potential
publication of these skewed results would not only have a detrimental impact
for these physicians, but also be a disservice to the public users of this
information who would lack the context expressed in this letter as they review
the information. We believe that measure programs should be aligned with
appropriately meaningful measures, and sufficient time should be provided to
physicians to align workflow with the tracking and reporting of these measures
in advance of any consideration about publically sharing reported measure
information. 3. We support efforts to address measure gaps and to ensure
measures reflect real world clinical practice in a meaningful way. Current
measures address some elements of clinical care, but other important and
meaningful aspects of patient care are not addressed in current measures. As
payers are increasingly mandating measure reporting and incentivizing
physician performance on measures, it is important that physicians have
meaningful measures in adequate numbers to meet reporting requirements. As
such, sufficient measures for all practices, especially specialty practices,
are needed to ensure physicians have the necessary tools to successfully
participate in these programs. The osteopathic approach to medicine supports
high-quality care in which patient-centeredness and coordination across
members of the care team are hallmarks. These fundamental aspects of high
quality care should be recognized through appropriate care measures. As such,
we support the inclusion of care coordination measures, team-based care
measures, and patient-centered care measures that reflect this model of care.
4. We support a collaborative, transparent, and timely process for measure
development and evaluation that will maximize efficiencies and shared
knowledge across stakeholders. Though current measures are numerous, disparate
measure development has resulted in redundancies that should be streamlined.
Collaborative measure development which includes relevant stakeholders will
enable future measures to be better aligned with existing measure gaps and
without duplication of efforts or products. As such, it is vital that measure
development and evaluation be a transparent process to which relevant
stakeholders are invited. In addition, timely evaluation and endorsement of
measures by NQF is necessary to ensure measures are prepared in advance of
CMS’s annual rulemaking. As CMS will annually adopt measures for use in the
following year for the MIPS program, it is important that NQF processes and
timelines dovetail with the CMS rulemaking schedule to ensure efficiencies
between measurement development, endorsement, and adoption in federal
programs. Please do not hesitate to call on the AOA for insight as you
complete this report. To do so, or for additional information, please contact
Ray Quintero, Senior Vice President for Public Policy, at
rquintero@osteopathic.org, or (202) 349-8753. Sincerely, John W. Becher,
DO President (Submitted by: American Osteopathic Association)
- • PhRMA appreciates MAP’s attention to issues related to implementation of
the new MIPS program. In light of stakeholder concerns with the current
value-based modifier (VBM) methodology and, in particular, the resource use
measures, we note that MIPS provides an opportunity for CMS to evaluate and
revisit reporting requirements established under its clinician reporting
programs and to ensure that the new MIPS program is structured to reward
continuous improvements in quality. Quality measures adopted for MIPS should
be comprehensive, meaningful, and reflect stakeholder consensus. MAP review
of the MIPS measure set and its associated opportunities for stakeholder
feedback are essential to this purpose. (Submitted by: PhRMA)
- • Quality improvement is a central goal of CMS’ measurement programs, and
PhRMA believes that quality improvement should be a primary focus of
measurement efforts. To that end, we urge the MAP work groups to give
particular attention to whether or not measures under consideration are
actionable for health care providers. We note that MAP considered several
composite measures this year, such as the Agency for Healthcare Research and
Quality Prevention Quality Indicators (MUC ID: 15-576 and MUC ID 15-577).
Composite measures are summary indicators that generally include multiple
component measures. While composite measures allow for the reporting of a
single measure score, performance scores on each indicator are also
instructive to identifying specific areas in need of improvement. In
considering composite measures, we encourage MAP to give due consideration to
the intended use of the measure, how it will be implemented, and the extent to
which the information will be actionable by providers. (Submitted by:
PhRMA)
- • PhRMA supports MAPs recommendation to encourage continued development of
measure concepts that show promise but where there continue to be unresolved
questions about the clinical appropriateness of measure specifications and/or
the rigor of the measure. Measures should undergo review for their clinical
evidence base, validity, and reliability and achieve stakeholder consensus
(such as through NQF endorsement) prior to their use in federal programs. For
example, PhRMA supports MAP’s recommendation to encourage continued
development of a measure of potential opioid overuse (MUC ID: 15-1169) for
inclusion in the MIPS program. PhRMA shares MAP’s view that this measure
needs to be further refined and tested in order to ensure it is not creating a
disincentive for appropriate use of opioids, including in subgroups of
patients who need higher doses to manage their pain, such as patients with
cancer and those in palliative care. We also note that CMS recently
recommended a similarly cautious approach to measurement in this area in its
Part C and Part D Star Ratings Program. (Submitted by: PhRMA)
- AAPM&R commends NQF for evolving its work to understand how measures
are being developed and implemented across settings and how they impact
payment reform. This is a huge endeavor that AAPM&R stands behind in
concept. However, AAPM&R cautions NQF to ensure their processes and
review of measures are adequately reported back to CMS and other rule-making
entities to ensure the NQF’s measurement expertise is realized in rule making.
AAPM&R believes there are currently too many unresolved problems related
to risk adjustment, attribution, appropriate sample sizes, and even the
ongoing lack of relevant measures for certain specialties. While the
development of many of the measures recommended are aimed at filling the gap
identified for specific specialties, the issue of risk adjustment has not been
solved. AAPM&R urges NQF to continue researching risk adjustment and
working with rule makers to understand the importance of understanding risk
adjustment before making sweeping payment reforms tied to data from measures
in their infancy. Disparities represent a significant quality problem; and
current data collection efforts are inadequate to identify and address
disparities; quality performance measures should be stratified by demographic
factors such as race, ethnicity, education, and gender. Data stratification is
important because adjustment for demographic factors should be considered to
reflect the known effects on morbidity and mortality and to ensure equivalent
quality and access to care among diverse patient populations. For example,
physiatrists practice in large urban areas as well as in small rural areas
where the population of patients may be similar but the amount of resources
available may vary. Making comparisons across these practice settings without
risk adjusting for factors not in the provider’s control inappropriate
(Submitted by: American Academy of Physical Medicine and
Rehabilitation)
- Specificity vs. generalizability in measurement (Page 7) We appreciate
that the Clinician Workgroup initiated a discussion on specific vs general
measures. While we agree in general that "...there is a need for balance on
this issue," a deeper dialogue is needed to sort out how to define and
operationalize "parsimony and alignment" in the context of measuring the full
scope of care, especially specialized services. This is a critical topic and
we urge a broader discussion among CMS, NQF and medical specialties. In the
MAP Clinician Workgroup, the discussion was triggered by the review of the
measures for biopsy reporting times for non-melanoma skin cancer (NMSC) and it
highlights both knowledge gaps and MAP process problems. To address
knowledge gaps, we encourage MAP to include clinical expertise for the
measures under review. In this case, MAP would benefit by adding a
Dermatologist to the Workgroup. In terms of process, CMS should adapt the
Call for Measures to seek information on the rationale for general versus
specific measures and other contextual information about the nature of the
specialized care. Finally, the MAP process should add mechanisms to facilitate
dialogue and information exchange between the work group and the measure
developers. To illustrate some of the considerations in developing measures,
context and rationale for the NMSC biopsy measures follows. First, the vast
majority of skin biopsies performed by clinicians will be to evaluate for skin
cancer. While the focus on NMSC might appear narrow, in reality this measure
is broad in its reach as skin biopsies for skin cancer are performed by a
range of providers - dermatologists and others. Therefore its impact will be
far reaching and this measure will be broadly applicable across different
providers and clinical settings. Second , the focus on NMSC biopsies limits
the reporting burden on clinicians. Until clinical data registry reporting is
streamlined and manual input of individual case information is no longer
required for reporting, we need to design measures that use denominators that
are representative of a clinician’s performance - this is very similar to a
research project in which a sample population is chosen and is deemed
representative of the entire population as it is not always practical or
useful to evaluate the entire population. Third, melanoma reporting was
excluded as, unlike NMSC (specifically, Basal Cell Carcinoma and Squamous Cell
Carcinoma as specified in the measure) where a second opinion, special
staining, or advanced treatment planning is rarely needed, melanoma biopsies
frequently need additional work-up/reviewers and multidisciplinary review;
thus potentially delaying reporting time to the patient. As such, creating a
time restriction may inadvertently negatively impact diagnostic accuracy and
treatment planning for a high-risk disease. (Submitted by: American Academy of
Dermatology)
- *AAHPM also supports the inclusion of the hospice exemption in the
following measures: • MUC15-414: Discharge to Community-Post Acute Care (PAC)
Long-Term Care Hospital Quality Reporting Program • MUC15-462: Discharge to
Community-Post Acute Care (PAC) Skilled Nursing Facility Quality Reporting
Program • MUC15-523: Discharge to Community-Post Acute Care (PAC) Home Health
Quality Reporting Program • MUC15-527: Application of IRF Functional Outcome
Measure: Change in Mobility Score for Medical Rehabilitation Patients •
MUC15-528: Application of IRF Functional Outcome Measure: Discharge Self-Care
Score for Medical Rehabilitation Patients • MUC15-529: Application of IRF
Functional Outcome Measure: Discharge Mobility Score for Medical
Rehabilitation Patients (Submitted by: American Academy of Hospice and
Palliative Medicine)
- In general, we support the workgroup recommendations and commend the
workgroup for taking significant steps forward in areas like outcome measures,
sociodemographic adjustment of those outcome measures, and measures developed
by, and apprpriate for, medical or sugical subspecialties. We have the
following general comments and suggestions: 1. We support the use of
patient-reported outcome measures and generally support those that are
included in the list of recommended measures. We observe, though, that these
measures do not come without a significant cost of data collection. Their
wide adoption and use will depend on some kind of sustainable funding
mechanism when they are not part of routine patient care. 2. We are
encouraged by the explict inclusion of sociodemographic risk adjustment in the
parameters for several proposed measures. We support the recommendations of
the NQF Expert Panel on SES adjustment, and look forward to the development,
testing, and refinement of risk models that include sociodemographic factors,
when appropriate. 3. We support the development and eventual use of measures
developed by, and used for, medical and surgical subspecialties. The absence
of apprpriate measures for many specialties and subspecialties is a
significant problem in the PQRS measure set now, and presumably will continue
to be a problem in MIPS going forward. Although any one provider or provider
group should not be burdened with too many performance measures to report, a
very large and diverse set of measures is necessary to allow specialties and
subspecialties to have appropriate, relevant, informative quality measures. 4.
We do not support the continued development and use of multiple, overlapping
measures of hospital readmission, under the concept of "shared
accountability". We would rather see the MAP and NQF bring forward much more
specific, defined measures of either processes or outcomes that relate to
readmission, but reflect a specific role that the measured entity should play
in the prevention of readmission. There may be half a dozen or more specific
providers or entities involved in some way when a readmission occurs, but not
all of them do the same things or contribute to the same degree (or at all) to
a readmission. Holding them all accountable for the outcome without
differentiation of role and degree of responsibility will not necessarily lead
to coordination and collaboration - it may instead lead to frustration,
helplessness, and avoidance of high-risk cases. Better to focus measurement
on the processes or outcomes more directly under the control of each provider,
reflecting the specific roles or responsibilities of each provider. 5.
Similarly, we do not support proposed measures that reflect a very broad and
essentially unlimited scope of responsibility for hospitals that include
domains of traditional public or community health. For example, holding
hospitals accountable for a community-level smoking rate seems to ask far more
of hospitals than they are licensed, or paid, or expected by the community to
do. It seems to us misguided to ask hospitals to function as public health
agencies when there are so many crucial issues of quality in the unique
domains of hospital care (e.g., central line infections) that merit focused
attention and improvement. (Submitted by: Henry Ford Health
System)
- The three documents for “Considerations” broadly cover the many facets of
process and substance in this arduous task to align/ harmonize measures. We
believe that measurement should endeavor to adhere to several principles: (A)
Frugality, (B) Harmonization, (C) Meaningful outcomes and (D) Clarity of
purpose and (E) Priority on patient-centric care. In this spirit, however, we
need to demonstrate that we measure “what matters” NOT just that we measure
“lots of things”. Additionally, as AMGA has alluded over the past five
years, we also need to be mindful of the frame of reference or context in
which care is being given (i.e., The Delivery System Matters). “The
confluence of context influences the quality of content.” Two general
points/suggestions follow. 1. In that regard of context appropriating content
measured, we propose that consideration and recommendation be given to the
real-time implementation of the MIPS measures in the settings of medical
groups or organized systems of care. In these specific venues, given the
diverse variance in the presence of primary through tertiary specialties, it
would make good common and practical sense to permit medical groups to select
a set number of measures that actually reflect the kinds of practices they
maintain. This option would allow such venues to more directly focus their
energies on improving targeted/actual care units being provided at the
facility rather than trying to adapt to a “cookie-cutter, one-size-fits –all”
compilation of measures that have been imagined to be relevant from afar.
Furthermore, clinical justification of a medical group’s selection of its
relevant measures would be required as part of the group’s transparency and
accountability. Permitting this option would help align the defined measures
more harmoniously with relevant /actual patient processes and outcomes. 2. A
particular processing issue, specifically involving the internal MAP process
from Workgroup through Coordinating Committee deals with the need for expert
clinical presence at the meetings of both levels. The process used by ABIM
to establish its “Choosing Wisely” Program could be replicated in the
selection and justification of MAP measures. Ergo, specialty societies
would be asked to contribute a listing of the (e.g.,) ten most common ailments
seen by that specialty. Then, an independent practice of that specialty
would develop and justify these ten MAP measures for the appropriate MAP
Workgroup. When the Workgroups and the Coordinating Committee meet,
representatives of both the specialty society and the developer would be
physically present to advise and explain the measures. This approach would
alleviate the ‘sole source bias’ that currently exists because of the lack of
diversity of opinions from one sole source expertise. We have confidence that
specialty societies have the best perspective on “what matters” as reflected
in the most common patient presentations in the societies’ categorical area of
expertise. Thank you for considering these suggestions. ***** (Submitted by:
American Medical Group Association -KF)
- • PhRMA appreciates the Measure Application Partnership’s (MAP) ongoing
work to review and prioritize measures for inclusion in federal health care
programs. As the Centers for Medicare and Medicaid Services (CMS) implements
new quality reporting requirements, such as the IMPACT Act and the Merit Based
Incentive Payment System (MIPS), the MAP process provides an important
opportunity for stakeholder input into the measures under consideration as
well as CMS’ programmatic goals and needs. We are particularly pleased to see
that CMS plans to leverage the MAP as it selects measures for the MIPS. PhRMA
encourages MAP to continue to identify ways to bring stakeholders, including
the pharmaceutical research sector, together to advance national performance
measurement goals. (Submitted by: PhRMA)
- • PhRMA appreciates acknowledgement by the MAP work groups that patient
centered measures are critical to assessing quality of care, driving quality
improvement, and generating actionable data for health care providers and
patients and so must continue to be a priority. Yet, as the MAP work groups
noted in their deliberations, significant gaps persist in the availability of
patient-centered measures, including patient-reported outcomes, functional
status, care coordination, and measures that incorporate patient values and
preferences. Identifying these gaps and working with measure developers and
other stakeholders to address them must continue to be a high priority.
(Submitted by: PhRMA)
- In general, we request that CMS and the MAP keep in mind the unique nature
of assessing “quality” care among those with serious and advanced illnesses,
as well as those at the end of life. The dimensions of quality for these
individuals differ fundamentally from those in most other areas of medicine,
in which mortality rates, functional status, and processes of care are
crucial. Those with chronic, progressive, and often fatal illnesses have
widely-variant goals and preferences for their care, and these goals and
preferences cannot be assumed reliably by their health care providers.
Decisions regarding medical treatment in these circumstances depend on each
individual’s preferences about both the quality and quantity of life,
requiring health care providers to go beyond knowledge of the disease
trajectory, and the impact of various treatment approaches on survival and
function, and to approach each patient as an individual with specific needs,
preferences, and expectations. Indeed, quality of care in the context of
hospice and palliative care can only be understood in terms of what matters
most to each patient; therefore, reliable and valid measures of quality must
include assessments of the patient’s own subjective experience. The patient’s
experience is the key “outcome.” Communication and individualized shared
decision-making are also crucial to both defining and achieving quality of
care for each patient. (Submitted by: American Academy of Hospice and
Palliative Medicine)
- On behalf of our nearly 5,000 member hospitals, health systems and other
health care organizations, and our 43,000 individual members, the American
Hospital Association (AHA) appreciates the opportunity to comment on the
Measure Applications Partnership’s (MAP) December 2015 pre-rulemaking draft
report. This letter provides overarching comments about the MAP process; we
have submitted comments separately on specific measures under review using the
National Quality Forum (NQF’s) online commenting tool. The AHA continues to
believe the MAP’s best opportunity to promote broad improvement in health care
is to identify a discrete set of actionable quality improvement priorities for
the health care field. For this reason, we urge the MAP to use the recent
recommendations in the National Academy of Medicine’s (NAM) Vital Signs as a
foundation for identifying these system-wide priorities. The MAP’s
multi-stakeholder composition and mandate to review nearly all quality
measures being considered for Centers for Medicare & Medicaid Services
(CMS) programs affords it a unique opportunity to look across programs and
measures. In theory, this perspective also should enable the MAP to hone in on
a limited number of effective, reliable, care-setting appropriate measures for
each part of the health care continuum that work together to promote
improvement and optimal outcomes for patients and communities. As the AHA and
others have noted since the MAP’s inception, identifying such “measures that
matter” for federal programs is urgently needed. The NAM report notes that
progress in improving the quality of health care has been stymied by
discordant, uncoordinated measurement requirements from CMS and others. The
existing measures provide limited insight into several critical questions: •
Are patient outcomes improving? • Is care getting safer? • Are patients more
engaged in their health and treatment decisions? • Are we driving out
unnecessary expenditures? We believe that Congress created the MAP precisely
so that the Department of Health and Human Services would get
multi-stakeholder input on what matters and how best to measure progress in
improving those priorities. Unfortunately, the MAP process to date has not yet
realized the promise of identifying “measures that matter.” The AHA believes
this is in large part because the MAP’s work has not yet been rooted in a set
of specific, actionable, cross-continuum priorities for national quality
improvement. By law, the MAP must make recommendations on potentially hundreds
of measures in a highly compressed timeframe. Without identified priorities,
it is difficult to know whether the measures under consideration address
important issues that meaningfully improve patient care. The NAM Vital Signs
report provides an important uniting framework that will help make all
stakeholders be more accountable and engaged in measurement and improvement.
The report recommends 15 “Core Measure” areas, with 39 associated priority
measures. Each stakeholder would be measured on the areas most relevant to
their role in achieving common goals and objectives. Using input from our
membership, the AHA has developed a list of measurement areas that we believe
represent the key contributions hospitals can make toward improving the NAM’s
15 core areas. A mapping of the NAM core measure areas and AHA priority list
is provided in the table below. Mapping of Vital Signs Core Measure Areas and
AHA Priority Measures Blue = NAM Core Measure Area Red = AHA Priority Measure
The recent collaboration of America’s hospitals and CMS in the Hospital
Engagement Network (HEN) program shows the great potential for a focused,
deliberate approach to quality measurement and improvement. Indeed, the HEN
program prevented an estimated 92,000 instances of harm and saved an estimated
$988 million. We look forward to continuing our engagement with the MAP and
thank you for the opportunity to comment. If you have any questions, please
feel free to contact me or Akin Demehin, senior associate director, policy, at
(202) 626-2365 or ademehin@aha.org. Sincerely, /s/ Ashley Thompson Senior
Vice President Public Policy Analysis and Development (Submitted by: American
Hospital Association (AHA))
- (Early public comment)The AAFP urges the MAP to be aware and
cognizant of the efforts of the multi-stakeholder Core Quality Measures
Collaborative while reviewing measures for inclusion for federal programs.
This effort works to ensure alignment, harmonization, and the avoidance of
competing quality measures among payers. These sets contain a variety of
measure types targeting both resource use, quality, and patient satisfaction.
The AAFP has a general concern that many of these measures are currently
under development, or are in field testing. Because of this, there is no clear
way of knowing if they will measure what they intend to measure, or if there
are unintended consequence that have yet been uncovered. We propose to include
only fully develop measured in this year’s rule making. (Submitted by:
American Academy of Family Physicians )
- (Early public comment)On behalf of Adventist Health System (AHS), I
wish to provide the following overall comments. The timeframe of this comment
opportunity is too short to provide substantive comments about the potential
of these Measures under Consideration to add value, improve outcomes, create
undue data collection burden or access whether a better measure exists. We
urge the Measure Applications Partnership (MAP) to ensure that the measures
that the Centers for Medicare and Medicaid Services (CMS) is considering for
use in federal programs are fully developed, tested and vetted to ensure
reliability and validity. We believe that the National Quality Forum (NQF)
should not offer support or even “conditional” support for any measures that
have not received NQF endorsement. In addition, the MAP should assess all
Measures under Consideration for alignment with measures currently in use in
federal programs. This assessment should ensure that measures are unique and
well-correlated with outcomes that are meaningful to patients. Priority should
be given to the most valid, reliable and meaningful measures. Any
recommendation for a new measure that competes with a measure currently in use
in a federal program should include a condition that the competing measure be
removed from the federal program or a condition that the two measures be
harmonized prior to the adoption of the new measure. (Submitted by: Adventist
Health System)
- (Early public comment)Thank you for the opportunity to review and
provide comment on the Measures Under Consideration. The AAN continues to have
a concern over the lack of neurology specific measures available through the
different CMS programs especially given the growing population of aging
adults. With the prevalence of chronic neurologic disease continuing to grow
in the aging population and the relative number of available neurologists
decreasing we must do something to assist treating physicians participate in
applicable programs. The AAN believes that expanding the list of measures to
be more inclusive of specialties will only serve to benefit of populations
with neurological needs. (Submitted by: American Academy of
Neurology)
- Dear Drs. Isham and McGlynn: The Association of American Medical Colleges
(AAMC or Association) welcomes this opportunity to comment on the National
Quality Forum (NQF) Measure Applications Partnership (MAP)’s 2016
Considerations for Implementing Measures in Federal Programs draft report. The
AAMC is a not-for-profit association representing all 145 accredited U.S.
allopathic medical schools; nearly 400 major teaching hospitals and health
systems, including 51 Department of Veterans Affairs medical centers; and
nearly 90 academic and scientific societies. Through these institutions and
organizations, the AAMC represents 148,000 faculty members, 83,000 medical
students, and 115,000 resident physicians. The AAMC appreciates the MAP
Workgroups’ thoughtful review and discussion of the measures under
consideration (MUC). The following are the AAMC’s high-level comments on the
preliminary MAP recommendations for both hospitals and clinicians: For the
hospital measures, the AAMC strongly believes that certain accountability
measures must be adjusted for sociodemographic status (SDS) before being
included in the Medicare quality reporting programs, be NQF-endorsed prior to
MAP review, and be included in the Inpatient Quality Reporting (IQR) program
for at least one year before being considered in a performance program by the
Workgroup. Finally, the AAMC believes that the MAP Workgroups should review
measures in the Medicare programs holistically in order to ensure that new
measures add value, are useful for consumers, and promote alignment, while
also considering the burden to reporting these measures for providers. While
only new or revised measures are reviewed by the MAP, a comprehensive review
can only occur when the committee considers the data collection burden imposed
by existing measures. Accountability Measures Should Be Adjusted for
Sociodemographic Status (SDS) The AAMC has long advocated for appropriate
adjustment for sociodemographic status (SDS) factors for certain outcome
measures. The AAMC agrees with the Workgroup’s preliminary recommendations
that the pneumonia episode-of-care payment and excess days in acute care after
hospitalization measures should undergo review in the SDS trial period to
determine whether there is a conceptual and empirical relationship between
outcomes and SDS factors prior to inclusion in the IQR program. The
Association also strongly believes that other approved Hospital MAP Workgroup
measures, including hospital visits within 7 days after hospital outpatient
surgery and CABG mortality, should be submitted for review in the SDS trial
period. The AAMC strongly supports a robust and transparent SDS trial period.
The Association is very concerned that the issues and concerns regarding SDS
raised by relevant steering committees, who are tasked with reviewing these
measures, are not being sufficiently addressed. We ask that the SDS trial
period be a priority for the MAP, NQF, and CMS in 2016. The AAMC also notes
that there are several measures in the current performance programs which have
not been SDS adjusted. We ask that MAP include a recommendation regarding the
need to adjust the existing measures, and have the opportunity to review all
measures for appropriateness in the performance programs after the SDS trial
period has concluded. All Measures Reviewed by the MAP Hospital Workgroup
Should be NQF Endorsed NQF endorsement demonstrates that a measure has been
tested, is reliable, and can be used in a specific setting. With the volume of
measures the MAP has to review, the Workgroups and Coordinating Committee rely
heavily on NQF endorsement to ensure the measure is sound. Since hospital
measures are typically not re-reviewed by the Workgroup, it is essential that
these measures be NQF-endorsed at the time of consideration so that members
are fully informed as to the measure’s appropriateness for the Medicare
reporting and performance programs. Hospital Performance Program Measures
Should be Publicly Reported Prior to MAP Review In this year’s MUC list, CMS
included new or revised measures for possible inclusion in Medicare hospital
quality performance programs. The AAMC remains concerned that several of the
measures brought forward for Workgroup review had not been publicly reported,
which limits the public’s ability to provide feedback. Publicly reporting
measures in the IQR Program allows MAP Workgroup stakeholders to be fully
informed regarding any complications in submitting the measures, and allows
time to identify errors, unintended consequences, or other concerns with the
measure’s methodology. Thank you for consideration of these comments. For
questions regarding the Clinician MAP comments, please contact Gayle Lee
(galee@aamc.org, 202-741-6429), and for questions regarding the Hospital MAP
comments, please contact Scott Wetzel (swetzel@aamc.org, 202-828-0495).
(Submitted by: Association of American Medical Colleges (AAMC))
- PhRMA is concerned that in identifying drug costs as a measure gap for the
Inpatient Quality Reporting Program (IQR), the MAP work group is taking an
overly narrow view that obscures broader gaps in resource use measurement and
conflicts with established MAP positions on these measures. PhRMA agrees
that the development, endorsement, and use of appropriate, validated resource
use measures is needed to better assess efficiency and value in health care.
However, resource use measures must be constructed carefully so as not to
conflict with the goal of improved patient care and to ensure alignment with
the broader, well-recognized opportunities for avoiding waste and promoting
improved efficiency in the inpatient setting. For resource use measures to
facilitate the goal of improving efficiency, they must take a holistic view of
health care costs rather than narrowing in on the cost of a specific item or
service. Cost measures that take a narrow, more short-sighted view run the
risk of encouraging reductions in discrete costs in the short-term at the
expense of realizing broader opportunities for efficient delivery of care.
This is particularly true with respect to prescription drugs, in light of
evidence that appropriate medication use can improve patient outcomes and
reduce use of other expensive services, such as emergency department visits
and hospitalizations. We recommend that the final report be amended to remove
the language on measures related to drug costs and to reflect that resource
use measures in general continue to be a measure gap in the IQR. We also note
that the MAP Hospital Work Group considered and recommended against use of a
large number of resource use measures this year, including several measures
under consideration for use in the IQR. In making these recommendations, MAP
cited its long-standing position that the cost of a service is not indicative
of the quality of care. PhRMA supports MAP’s position that appropriate,
validated resource use measures must be paired with relevant measures of
quality, and appreciates MAP’s continued attention to the challenges of
resource use measurement. (Submitted by: PhRMA)
- PhRMA commends MAP for generally supporting measures that have attained
stakeholder consensus (such as NQF-endorsement). Measures implemented in
federal programs should be reviewed for their clinical evidence base,
validity, and reliability and achieve this standard. Endorsement by a
consensus based organization like NQF provides evidence of the rigor of the
measure. However, we note that MAP gave conditional support to a measure of
Admissions and Emergency Department Visits for Patients Receiving Outpatient
Chemotherapy (MUC ID: 15-951), which has not been submitted for endorsement.
This measure should be reviewed and endorsed with particular consideration
given to the exclusions and risk-adjustment for the measures prior to its
implementation in federal programs. For example, patients with hematologic
malignancies other than leukemia, such as lymphoma and multiple myeloma, are
also at increased risk for many of these complications as compared to patients
with solid tumors. As a result, alternative measurement approaches may be
more appropriate for these patients. (Submitted by: PhRMA)
- January 12, 2016 National Quality Forum 1030 15th Street NW Suite 800
Washington DC 20005 Dear Colleague(s), The Children’s Hospital Association
(CHA) appreciates the opportunity to comment on the Measures Under
Consideration (MUC) list that is being reviewed as part of the National
Quality Forum (NQF) Hospital Measure Applications Partnership (MAP) 2015/16
Project. We understand that this hospital workgroup provides input to the
Coordinating Committee MAP on the selection of measures for hospitals,
including inpatient acute, outpatient, cancer, and psychiatric hospitals. The
MAP, as a whole, is a multi-stakeholder partnership that guides the U.S.
Department of Health and Human Services (HHS) on the selection of performance
measures for federal health programs. We also understand the importance of
what HHS selects for use in their federal programs and the signal that sends
to policy and decision makers, other payers, and the entire measurement
enterprise. CHA applauds the thorough review and careful deliberations of the
NQF Hospital MAP committee members. In general, and with few exceptions, CHA
supports the MAP Preliminary Decisions about the applicability of the measures
for each of the programs. Our individual measure comments were submitted as
instructed on the NQF Web Portal; this letter does not imply agreement with
all the MAP measure decisions. In this letter, we highlight some key issues
with the use of measures for the purposes of accountability. 1. Clear
communication about the intended use and for what applications the measure is
being approved. While we realize that the purpose of the NQF MAP is to provide
guidance to HHS about the appropriateness of performance measures for specific
federal health programs, we understand that selected measures are often
subsequently used for similar non-federal programs, and even within different
populations (e.g., adults in a commercial MCO). Because the selection of
measures may signal, whether right or wrong, the acceptability of a measure
for broader use than for which was deliberated, or even intended, we encourage
all reports and communications about the measures to be articulate that these
recommendations do not include assessing measures for other program uses. For
example, measures selected for the CMS Value Based Program (VBP) may not be
appropriate for all VBP programs, especially for pediatrics. HHS should
encourage users to fully vet and test measures for validity in other programs.
2. Lack of testing or experience within other payer data and populations: We
encourage CMS and other measure developer to test measures more broadly during
their development. This includes testing in other payers, delivery systems
(e.g., managed care, accountable care organizations), and populations (e.g.,
children), as appropriate. When this is not possible, similar to comment one,
it is critical that HHS and NQF clearly articulate this limitation and the
implications of using measures selected for the federal programs into
seemingly similar programs that have not been fully tested for broader uses.
CHA understands the lack of data availability for testing, in particular for
pediatrics; we encourage HHS to continue to play a leadership role in removing
barriers to data for measure developers. 3. Risk adjustment. NQF recommends
that outcome measures be adjusted for clinical severity because it affects
outcomes; however, as Kulthau et al. point out, many characteristics make
children special, and hence, measures used in pediatric populations require
different (than adults) risk adjustment algorithms. Specifically, children
have relatively low mortality and morbidity rates; often require specialized
pediatric services; often use providers and institutions outside the
traditional health care delivery system (e.g., their school clinic); and need
familial or adult help. We request that users of measures with risk adjustment
are careful to consider the applicability of any risk adjustment model to
pediatric populations and delivery systems. This may have implications for
ESRD program measures as well. 4. Social determinant factors. We support much
of the MAPs comments calling for a better understanding of how these factors
impact hospital performance. While we do not want to mask performance
differences that may be a result of provider biases against or in favor of any
particular patient characteristic (social determinant factors), we do want to
measure hospital’s based on what they have or could have control of to
improve. We agree that for comparative performance assessment,
sociodemographic adjustment is appropriate (under certain conditions), and to
stratify results so that any disparities are made visible. When measures are
being included in accountability programs for children, these factors should
also include those to which children are particularly vulnerable (e.g.,
community or school characteristics). 5. Attribution of measures to hospitals
for the purposes of any accountability application: As the MAP currently does,
it is critical that all MAP deliberations include scrutiny for which level of
attribution a measure is valid. This includes both face and statistical
validity. Examples of questions that need to be discussed: Has the measure
been tested and shown to be valid for performance attributed to individual
hospitals/institutions? Does the measure make sense for use in an
accountability program for hospitals? If so, is it appropriate for this
accountable program (e.g., VBP)? Further, we encourage increased articulation
about when a measure is not intended or tested for other populations (e.g.,
children). Because what measures CMS is using in their programs is a signal to
the entire measurement enterprise, including Medicaid and commercial payers,
clearly articulating this information, or lack of information about the
measure, within source documents is critical. 6. Multiple rewards or
penalties for the same event or patient encounter. We encourage the MAP and
CMS to continue to drive toward parsimony set of measures, within and across
programs. Not only does this support the call to “measure what matters,” and
not more, it reduces rewards or penalties for the same event or patient across
programs. In addition, we would like to emphasize some of our
measure-specific comments. Specifically: Patient Safety and Adverse Events
Composite: While patient safety and adverse events are critical areas to
measure and drive improvement, little is known about how the measure’s changes
and refinements will alter hospital performance. We request that absolute and
relative performance changes be reviewed and understood prior to using this
measure for payment purposes. Adult Local Current Smoking Prevalence: While
this measure is currently endorsed, it is endorsed for measurement at the
state level. We do not support attributing a state/county-level surveillance
type measure to hospitals for the purposes of accountability. While hospitals
may play a role in reducing smoking prevalence in their community, attributing
the prevalence rate for all residents in a state or county to the hospital not
only includes people that the hospital has not ‘touched,’ but it misses other
important care settings and strategies (e.g., tobacco tax) that may be more
effective at reducing the prevalence of smoking. National Healthcare Safety
Network (NHSN) Antimicrobial Use Measure: Antimicrobial use is an important
topic and will support antibiotic stewardship quality improvement efforts.
However, as the measure is currently specified, and because the lack of
experience with this measure, it is not ready for hospital accountability.
Some issues with this measure for use as a hospital accountability measure
include: lack of risk adjustment; hospital with higher acuity will likely
have more patients that need to be on antibiotics; and lack of clarity on how
publicly reporting this will inform the public at this point. Further, the
measure developer has stated that the measure needs to be used for several
years before publicly reported; we support the developers input on its
immediate use. The lack of risk-adjustment is particularly challenging for
children’s hospitals, which often are caring for the sickest of children, who
may medically require antibiotics. citation: Kulthhau et al., Risk
Adjustment for Pediatric Quality Indicators. Web accessed 1/05/2016:
http://pediatrics.aappublications.org/content/pediatrics/113/Supplement_1/210.full.pdf
Thank you once again for the opportunity to provide our input; we appreciate
all the hard work put forth by NQF, HHS, and the MAP committee members.
Sincerely, Sally E. Turbyville, MA, MS, DrPH Senior Fellow Quality Policy and
Research CHILDREN'S HOSPITAL ASSOCIATION
Sally.turbyville@childrenshositals.org (Submitted by: Children's Hospital
Association)
- The Federation of American Hospitals (FAH) encourages NQF to include
greater specificity about the work group deliberations in the final report to
the Secretary of HHS. The draft report, beyond the summary of action on each
of the measures, does not appropriately capture the rich discussion at the
work group level. In particular, for hospital measures, the FAH would like to
see a specific acute care hospital section that reflects the rich discussion
of the need to proceed more deliberately and quickly on the consideration of
socio-demographic status adjustment. The FAH also would like the final report
to reflect the concerns of the work that many of the cost-related/efficiency
measures had not been tested or even fully specified, thus making it
challenging for the work group to make a sound recommendation on the possible
use of the measure in future rule making. Thank you. (Submitted by:
Federation of American Hospitals)
- On behalf of the 90,000 physical therapist, physical therapist assistant,
and students of physical therapy members of the American Physical Therapy
Association (APTA), I would like to submit the following comments in response
to the MAP 2015-2016 Preliminary Recommendations for Post-Acute Care and
Long-Term Care. Physical therapy is an integral service provided to Medicare
beneficiaries all post-acute care settings. Physical therapists furnish
medically necessary services to patients to improve their overall health,
function and to optimize their quality of life. Across the post-acute care
settings, physical therapists provide physical therapy services to patients
through a plan of care to engage and optimize the patient’s participation in
achieving shared goals of improved functional performance, reduced risk of
injurious falls, and reduced risk of acute hospitalization thereby promoting
long-term health and wellness. APTA has submitted comments to CMS and NQF
regrading new measures developed for the post-acute care settings including
potentially preventable readmissions, discharge to community and patient
function and self-care. APTA supports the 2016 recommendations of the MAP
PAC/LTC and submits the following additional comments: 1. “Encourage
continued development” for the Discharge to Community measure (MUC15-408, 414,
462, and 523). APTA believes that a patient’s level of function does impact
a patients ability to transition successfully back to the community. Recent
evidence indicates that patient function is associated with increased risk of
30-day all-cause hospital readmissions and may be an important factor in
preventing readmissions for Medicare seniors that is not currently accounted
for in measure methodologies (Greysen SR, et al. JAMA Intern Med.
2015;175(4):559-565). We believe that readmissions and discharge to community
are closely related measures and that patient function may also be an
important risk adjustment variable for discharge to community. 2. “Encourage
continued development” for the IRF Functional Outcome measures (MUC15- 236,
527, 528, 529). APTA would strongly suggest the inclusion of wheelchair
mobility items in the two mobility measures (NQF # 2634 and #2636) as some
patients in this setting may use a wheelchair as a primary method of mobility.
Without items that assess wheelchair mobility, these measures may not
accurately reflect the mobility of patients who use a wheelchair as a primary
method of mobility in the skilled nursing facility setting. APTA is concerned
about the inclusion of these measures in the skilled nursing setting as the
measures are yet to be implemented in the IRF setting. APTA encourages CMS to
continue to examine data from these measures during the implementation phase,
as well as considering measure modifications as the data warrants.
Additionally, APTA echoes the concerns about the duplicity in data collection
that these measures introduce and the burden of data collection for the
providers given the current data collection tools in the PAC settings,
specifically MDS in the skilled nursing facility setting. 3. “Encourage
continued development” for the Potentially Preventable 30-Day Post-Discharge
Readmission measures (MUC15- 234, 495, 496, 498). APTA believes that a
patient’s level of function does impact the potential for readmissions.
Recent evidence indicates that patient function is associated with increased
risk of 30-day all-cause hospital readmissions and may be an important factor
in preventing readmissions for Medicare seniors that is not currently
accounted for in measure methodologies (Greysen SR, et al. JAMA Intern Med.
2015;175(4):559-565). We would encourage measure developers to include this
as a risk adjustment variable in all readmissions measures. APTA appreciates
that CMS has strict deadlines for the implementation of measures under the
IMPACT act and we recognize that the overall goal of IMPACT is for PAC
providers (HH, IRF, SNF and LTCH) to collect and report standardized and
interoperable patient assessment data, quality and resource use measures,
however, we would encourage ongoing testing of these measures prior to
inclusion in the quality reporting programs of the respective post-acute care
settings. (Submitted by: American Physical Therapy Association)
- The Alliance strongly supports the recommendations of the PAC/LTC
workgroup. There is a need in home health care to have a streamlined, more
parsimonious measure set to enable focused quality improvement efforts. The
recommendations and findings in the PAC/LTC workgroup draft report capture
this issue. The Alliance thanks the members of the PAC/LTC workgroup for its
thoughtful efforts and analysis. (Submitted by: Alliance for Home Health
Quality and Innovation)
- January 12, 2016 Christine K. Cassel, MD President and Chief Executive
Officer National Quality Forum 15th Street, NW Suite 800 Washington, DC
20005 RE: Draft Measures Application Partnership Pre-Rulemaking Input Report
Dear Dr. Cassel: On behalf of the American Society of Nephrology (ASN), we
thank you for the opportunity to provide comments on the National Quality
Forum (NQF) Measures Application Partnership (MAP) Rulemaking Input Report.
ASN is the world’s leading organization of kidney health professionals,
representing more than 15,000 physicians, scientists, nurses, and health
professionals who strive to improve the lives of patients with kidney disease
every day. ASN and the professionals it represents are committed to
maintaining patient access to optimal patient-centered quality care,
regardless of socioeconomic status, geographic location, or demographic
characteristics. ASN appreciates the efforts of NQF, as well as those of the
MAP, to identify the best available healthcare performance measures for use in
specific applications. ASN would continue to encourage development and
validation of meaningful outcome measures for people affected by kidney
disease. ASN recommends that NQF continue to work with the greater kidney
community in developing patient focused outcome measures that would benefit
patient’s lives. The society submits the following comments on the proposed
end-stage renal disease-related measures for your consideration. End Stage
Renal Disease Quality Incentive Program: Standardized Hospitalization Ratio
(SHR) – Modified Standardized Mortality Ratio (SMR) – Modified ASN supports
both the SMR and SHR measure in concept; however ASN has several concerns with
the current version. One major area of concern is related to CMS’ Five Star
program. In this context, it is important to view metrics in the manner in
which they are currently being applied rather than as theoretical constructs.
As of now, the SMR is used as a rigid point estimate without any accounting
for potential variance. When a metric is used before endorsement, we have an
interesting opportunity to comment on whether the current use is appropriate;
in this case, endorsement of this metric would de facto endorse the current
improper use of this particular measure as a rigid ordinal ranking system,
which is counter to its design and its statistical qualities. Secondly, ASN
would like to see some refinement of the denominator (expected) adjustments.
Currently, the 1st stage model is adjusted for age, race, ethnicity, sex,
diabetes, duration of ESRD, nursing home status, patient comorbidities at
incidence, calendar year and body mass index (BMI) at incidence. This should
be updated to look at claims with a lag as is likely being done with more
recently developed measures. This would also have the benefit of encouraging
parsimony in measure methodology. Until these changes are made, ASN continues
to have concerns with the measures as proposed. If these measures are
endorsed, ASN urges NQF to comment on the appropriate use of these measures
and the inappropriate use of ordinal ranking without accounting for
statistical variance. Standardized Readmission Ratio (SRR) for dialysis
facilities ASN supports the concept of the proposed SRR for dialysis
facilities and believes this measure has great potential for improving patient
care. ASN is pleased to see that the steward has attempted to look at real
time data in order to adjust the expected number of patients being readmitted
in the denominator. However, the society has several questions and concerns
regarding implementation of the proposed SRR measure and believes these
concerns must be clarified before the measure is finalized. Of greatest
concern is defining the denominator by the number of discharges rather than by
the total number of beneficiaries. • Denominator Total ASN believes that the
number of discharges should not be the determinant of the denominator, but
rather that the number of readmissions should be based on the total number of
patients treated in a facility. The society believes that this structure
would be far more representative of overall quality of care and far less
vulnerable to the effect that one or two complex patients could have on the
SRR of an otherwise outstanding facility. Critically, as the ASN has outlined
in detail in previous position statements, the SRR cannot be conceptualized
independent of the SHR, reflecting that a small number of patients frequently
readmitted can result in a facility appearing to be poor performing if that
facility has a very low overall hospitalization rate. This point was made by
the chairperson of the TEP charged with developing this measure when he
withdrew his support for the measure. Avoidance of Utilization of High
Ultrafiltration Rate (= 13 ml/kg/hour) ASN strongly supports this concept, but
would recommend that NQF support the KCQA measures over the current CMS
measure. While there are limitations with both of these measures, ASN feels
that it is an important start to addressing one of the most important elements
of dialysis care, volume management. As discussed by CMS in the 2015 ESRD
Final Rule, we agree that gathering these data and understanding this measure
are important prior to its inclusion as a performance measure attached to the
QIP. Proportion of Patients with Hypercalcemia (NQF #1454) The society
strongly opposes this measure and points out that there are sufficient data to
show that it is not a valid performance measure (the EVOLVE trial assessed
cinacalcet versus placebo in people with high normal and high serum calcium
levels and found no significant difference in hard clinical outcomes in
intention to treat analyses) and there are no data to show that it is a safety
measure aside from trying to fit something into a safety measure column.
Currently this measure is a weak measure of drivers of calcium levels (e.g.,
phosphate binder efficacy, dialysate calcium concentration, etc) and
specifically supports the use of an expensive medication, cinacalcet, which
has substantial gastrointestinal side effects, major cost implications and
limited evidence supporting a benefit in hard outcomes. Given the exclusion
of this agent from the bundle, dialysis facilities have no economic
disincentive to the prescription of this agent, and therefore there is no
cogent role for including a measure that financially disincentivizes
cinacalcet non-use. Accordingly, NQF 1454 is not a patient-centered measure
as it encourages us to prescribe an agent that may be poorly tolerated, with
twice as many participants in the cinacalcet group noting nausea and vomiting.
We posit that cinacalcet will not be under prescribed regardless of the
presence of this measure and therefore emphasize that a measure pushing
cinacalcet prescription (as is described in the 2015 final rule as
justification for its inclusion in the QIP) is unwarranted. ESRD
Vaccination: Full-Season Influenza Vaccination ASN supports this measure and
thanks NQF for including it in this year’s MAP. Measurement of Phosphorus
Concentration ASN supports this measure and thanks NQF for including it in
this year’s MAP. ASN supports parsimony in measures. ASN believes that it is
necessary and beneficial to have evidence-based metrics on important
indicators of care quality for the non-dialysis chronic kidney disease
population and the ESRD population. However, ASN also believes that redundant
or discrepant measures, as well as measures that are not validated or do not
address a care gap, may actually serve to threaten quality of care. Again,
thank you. If you have any questions about this letter or ASN’s
recommendations, please feel free to contact ASN Policy Associate, Mark
Lukaszewski at 202-640-4635 or mlukaszewski@asn-online.org Sincerely, Raymond
C. Harris MD, FASN President (Submitted by: American Society of Nephrology
(ASN))
- The MAP Coordinating Committee is tasked with providing input to
Department of Health and Human Services on which measures are appropriate for
implementation into various federal quality programs. As an over-arching
group above the individual MAP advisory workgroups, the Coordinating Committee
is designed to seek synchronization between workgroups. As such, we urge the
Committee to undertake a comparison between the measures that were recently
reviewed by the PAC/LTC workgroup (specifically their stage of development),
and the stage of development for other measures in other advisory workgroups,
focusing on their degree of “readiness” for application. We believe that
many of the measures considered and ultimately approved by the PAC/LTC
workgroup, particularly the various Medicare Spending Per Beneficiary (MSPB)
measures for PAC providers and the Within-Stay Potentially Preventable
Readmissions measure for inpatient rehabilitation facilities (IRFS), are both
not as far along in their design specification as measures that other advisory
workgroups typically review. Indeed, during the PAC/LTC workgroup meeting on
December 14-15, NQF staff noted multiple times that the measures that the
PAC/LTC workgroup members were asked to vote on were atypical in how
preliminary the specifications were. Faced with only these “preliminary
specifications,” many workgroup members highlighted the issue of premature
review, both directly and indirectly, by asking important questions that were
not covered in the preliminary specifications. Specifically, the MSPB measure
is still in a conceptual phase, and the Technical Expert Panel arranged by the
Centers for Medicare and Medicaid Services was never given any particular
specifications on the measure, nor settled on important conceptual contours of
the measure’s design. Further, there is no data or information showing that
MSPB, a pure cost measure, is a valid indicator for actual quality of care.
The lack of a nexus between pure MSPB and quality is a concern considering
that the National Quality Forum’s MAP is designed to consider whether measures
in fact are appropriate for use in federal quality programs. In addition, the
IRF Within-Stay Potentially Preventable Readmission measure does not indicate
when it would begin to capture readmissions during a the IRF stay, thus
resulting in a present ambiguity as to whether the 3-day admission review
period, a unique IRF payment system feature, is covered in the measure’s
timeframe. The absence of these type of details in the measure specifications
indicate that members of the PAC/LTC workgroup were making recommendations
based only on preliminary information that may change before the measures are
proposed for adoption. Based on the PAC/LTC Workgroup’s preliminary decision
that all of these measures should have “Encouraged Continued Development,” we
believe the MAP should not recommend these measures for implementation into
the IRF QRP until such development and subsequent NQF endorsement occurs.
(Submitted by: HealthSouth)
- MAP reviewed and recommended continued development of a measure of drug
regimen review (MUC ID 15-1127 through MUC ID 15-1130) in the post-acute care
setting. PhRMA supports MAP’s recommendation, given that this measure is in a
very early stage of development. At the same time, we would like to emphasize
the importance of measuring drug regimen review to ensure that patients are
receiving an appropriate medication regimen and that a patient’s regimen is
being regularly assessed and modified if needed in the post-acute period.
While medication recognition is an important step in drug regimen review, we
appreciate that CMS is looking more broadly than medication reconciliation in
developing this measure. (Submitted by: PhRMA)
- AAPM&R commends NQF for evolving its work to understand how measures
are being developed and implemented across settings and how they impact
payment reform. This is a huge endeavor that AAPM&R stands behind in
concept. However, AAPM&R cautions NQF to ensure their processes and
review of measures are adequately reported back to CMS and other rule-making
entities to ensure the NQF’s measurement expertise is realized in rule making.
Uniform and current data need to be collected across a variety of PAC
settings with a major emphasis on appropriate quality standards and risk
adjustment to protect patients against underservice . Risk adjustment is
critical to ensure that PAC settings that typically treat patients with
comorbidities and complex conditions are not penalized for admitting such
patients, even if their conditions worsen and they are readmitted to the acute
care hospital. If risk adjusters are not sufficiently accurate and robust to
counteract this strong incentive to avoid difficult or challenging patients,
then the most vulnerable Medicare beneficiaries will be at greater risk of
underservice than under the current Medicare payment systems. AAPM&R
believes that the skillset of the staff who will be conducting these
assessments needs to be studied. It is unknown if staff will have proper
training on the rating scales used to score a patient’s level of independence.
Different staff may use rating scales. Additionally, functional measures are
not a “black and white.” Measures should account for the quality of life for
patients with these extreme conditions . (Submitted by: American Academy of
Physical Medicine and Rehabilitation )
(Program: Hospital Inpatient Quality Reporting
and EHR Incentive Program; MUC ID: MUC15-1013) |
- This is an extremely important measure for endorsement by NQF. There is
substantial evidence that by reducing smoking rates healthcare costs will be
reduced and quality of life will be improved. Increasingly, healthcare
organizations are advocating for policies that can reduce smoking rates and
are engaged in other population-based initiatives to reduce smoking rates.
(Submitted by: Public Health Foundation)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Baylor Scott &
White Health)
- The AHA agrees that a designation of “encourage further development” is
appropriate for this measure. Nevertheless, we foresee significant practical
and conceptual limitations to this measure concept that may render it
infeasible and potentially misguided for future use in the IQR program.
Hospitals clearly have an interest in helping their communities address
significant public health issues. Tobacco smoking leads to significant
morbidity and mortality, and as a result, it is understandable that patients
and communities would want to know their locality’s smoking prevalence rates
to understand whether there is an opportunity for interventions. However, we
question how practical it is to ascribe local smoking prevalence to particular
hospitals. This measure is being proposed for a hospital-level accountability
program, rather than a measure of the public health system writ large. As a
result, the measure should say something meaningful about the contribution of
the hospitals being measured to the outcome. Yet, it is not clear how
performance would be attributed to one provider or another -- would all the
hospitals in the same city or county share the same performance? What if the
county a hospital is in does not represent where most of its patients come
from? Furthermore, we believe a locality’s smoking rates are driven by a
multiplicity of factors, and not just clinical interventions by hospitals or
any other healthcare providers. These factors may include: o Access to
affordable cessation medications and other counseling programs. o Laws that
discourage the use of tobacco in public areas – many localities have adopted
such laws, but some have not o Excise taxes on tobacco products – these vary
from city to city, state to state. o Differentiation in the cost of health
insurance for smokers versus non-smokers As a result, it may be misguided to
use this measure in a provider accountability application like the IQR, as it
may hold hospitals accountable for issues that are beyond their control. In
addition, any outcome measures like this one needs evidence suggesting there
are effective steps the providers being measure can take to impact measure
performance. Yet, the most compelling evidence for tobacco use treatment is
from the outpatient setting, not inpatient care. This finding is perhaps not
surprising since primary care physicians have more established relationships
with patients than hospitals, whose care is generally offered on an episodic
basis. (Submitted by: American Hospital Association (AHA))
- While we do not disagree with the importance of tracking smoking
prevalence, it is not appropriate to include this measure in a hospital
program since tracking prevalence in the absence of quality measures does not
demonstrate a hospital-community collaboration. The smoking cessation measures
were removed from the IQR program a number of years ago because they were
topped out. Any new measures added to the IQR program should be focused on
topics that need greater attention and can help to drive improvement in the
overall delivery of patient care. (Submitted by: Federation of American
Hospitals)
- While this measure is currently endorsed, it is endorsed for measurement
at the state level. We do not support attributing a state/county-level
surveillance type measure to hospitals for the purposes of accountability.
While hospitals may play a role in reducing smoking prevalence in their
community, attributing the prevalence rate for all residents in a state or
county to the hospital not only includes people that the hospital has not
‘touched,’ but it misses other important care settings and strategies (e.g.,
tobacco tax) that may be more effective at reducing the prevalence of smoking.
This type of measure is beyond the scope of hospitals' responsibility; not
sure that any impact on the measure can be attributed to the hospital; there
is evidence to show that strategies such as tax on cigarettes are more
effective. (Submitted by: Children's Hospital Association)
- The Joint Commission agrees that smoking is an ongoing public health issue
and development of an adult community-based measure is an important step for
hospital collaboration; however, we are concerned about developing a new
measure which only addresses “smoking” status. Tobacco use status (which
includes both smokeless tobacco and smoked tobacco products use) should be the
focus of a new community-based measure. The Joint Commission’s TOB-1: Tobacco
Use Status already addresses this. The entire Tobacco Treatment (TOB) measure
set is currently being retooled into eCQMs under a contract with the Centers
for Medicare and Medicaid Services (CMS). CMS may propose to add requirements
to report the eCQM versions of the TOB measures in a future HIQR program.
Expansion of the proposed smoking prevalence measure will “muddy” the waters,
since hospitals will have to report on tobacco use in two different ways. The
Joint Commission has received numerous complaints from hospitals respecting
the need to report smoking status for Meaningful Use (MU) based on the ONC
values which are different than the tobacco use status reporting requirements
for TOB-1. The Joint Commission does not recommend inclusion of this measure
in the HIQR program for the above reasons. (Submitted by: The Joint
Commission)
- While we support this concept as a population health measure; hospitals
are unable to collect and report this measure and have little ability to
improve upon the measure. The MAP recommendations should explicitly state that
this measure should not be used in HIQR. (Submitted by: Premier)
- The ACS does not support the concept of "adult local current smoking
prevalence" as a hospital accountability measure because of the various
sociodemographic (SDS) factors that exist on the local level which are very
difficult to account for and track. We agree that hospitals are an important
partner in reducing smoking prevalence, but hospitals should not be penalized
based on smoking prevalence in their community. (Submitted by: American
College of Surgeons)
- (Early public comment)The proposed measure supports CMS’ effort to
create a paradigm shift towards population health, acknowledging role
hospitals and health systems have in community prevention. We applaud this
emphasis on population health as we have found it can save money, save lives,
and reduce demand on healthcare services which by its nature also improves
quality of life and reduce inequities. Adding a measure on adult local
current smoking prevalence is a valuable first step towards population health
and can encourage the development of strategic and purposeful partnerships to
pursue the Triple Aim as it relates to the leading cause of preventable death,
tobacco. The measure would also financially incentivize hospitals to improve
the quality and reach of their services and activities addressing tobacco
prevention and control such as evidence-informed recommendations for tobacco
use treatment, establish smoke free worksites, and support for tobacco free
living throughout its entire service area. The measure does not create undue
data collection or reporting burden as the data is collected annually by the
Behavioral Risk Factor Surveillance Survey. While the measure is proposed for
the HIQR program only, it should be considered among all CMS value-based
payment programs to promote alignment with the National Prevention Strategy
and Healthy People 2020. (Submitted by: Prevention Institute)
- (Early public comment)We are strongly supportive of the inclusion
of this measure in the Hospital Inpatient Quality Reporting System (HIQR).
This is not only because of the gravity of the public health threat it
addresses, but also because of the important recognition that healthcare
providers should be engaged in promoting health beyond the four walls of their
facility. While a number of clinical interventions have contributed to an
overall decline in smoking over the past few decades, community-based policy
interventions are vital to reducing smoking. Hospitals have the potential to
influence tobacco cessation among patients whom they treat, both though
clinical interventions and through community-based policies that create an
environment that further supports patients smoking cessation efforts and
prevent youth from initiating smoking. This measure reflects the proportion of
adults within a given geographic area who are current smokers. As a first
step, by creating this reporting requirement within HIQR, CMS will be
encouraging hospitals to become more aware of the prevalence of smoking in the
surrounding community. In future stages, when the measure is incorporated
into payment amounts, hospitals will have an incentive to reach out into the
community to reduce the prevalence of smoking – not only among their current
patient panels, but at a population level. This one measure – listed not as
“process” or “outcome” but, appropriately, as “Structure” – represents an
important step in CMS prioritizing population-level health. The vast majority
of what makes people sick or healthy occurs outside of a clinical setting, and
this measure is a move toward recognizing that healthcare providers should be
helping address those systemic factors. (Submitted by: Trust for America's
Health)
- (Early public comment)While we support this concept as a population
health measure; hospitals are unable to collect and report this measure and
have little ability to improve upon the measure. (Submitted by:
Premier)
(Program:
Hospital Inpatient Quality Reporting and EHR Incentive Program; MUC ID:
MUC15-1015) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Academy of Managed
Care Pharmacy)
- This measure seems useful and the hospice exclusion is very reasonable.
(Submitted by: American Academy of Hospice and Palliative
Medicine)
- Due to limited information available to hospitals of post discharge INR
monitoring, we support this as a ACO or PQRS measure only. (Submitted by:
Baylor Scott & White Health)
- SHM agrees with the MAP position that not all hospitals may be able to
meet performance on this measure due to limitations with vendors. SHM would
add that, since this measure is proposed as a hospital-level measure, it may
be more appropriate to assess items actionable at the hospital-level. To
adjust, the measure specifications could be changed to evaluate whether INR
monitoring was ordered or arranged. (Submitted by: Society of Hospital
Medicine)
- FAH has several concerns with this measure as currently specified. As
discussed at the Hospital Workgroup meeting, most hospitals continue to
struggle with collecting and reporting data via electronic health record
systems (EHRs). This measure adds an additional burden of requiring
interoperability functions to enable the assessment of monitoring
post-discharge. It is unclear whether issues with technology may misrepresent
the quality of care provided. In addition, we are concerned that the
accountability of INR monitoring following discharge may be misdirected at the
hospital. This measure would be better suited for the ambulatory care
setting. An alternative would also be to have complimentary measures for
physicians and hospitals that would allow both groups to collaborate on
improving the coordination and quality of care provided to these patients.
(Submitted by: Federation of American Hospitals)
- GNYHA has concerns about this measure and does not support its adoption
because hospitals should not be held entirely accountable for activities
outside of their control. Once a patient is discharged from the hospital, the
hospital has little control of whether and how a patient follows discharge
instructions. Furthermore, INR levels are often managed by a patient’s
primary care physician. If a new measure related to INR management is to be
considered, we would recommend holding hospitals responsible only for actions
over which they have control like the last INR level prior to discharge and
there being a post- discharge INR test ordered. (Submitted by: Greater New
York Hospital Association)
- (Early public comment)This measure is better for ACO or individual
physician measurement; hospitals are unable to track INR monitoring as it
frequently occurs on an outpatient basis. (Submitted by: Premier)
- (Early public comment)The denominator should be "the number of
patients discharged on warfarin with a non-therapeutic INR". I don't feel that
we need to make an exception for patients being bridged with Lovenox since the
INR still needs to be checked in this fairly broad time period. This data will
be hard to collect a hospital level as a performance measure. It would be
captured by the outpatient providers who may be on another EMR system and as
such the entire denominator may not be covered. The denominator will become "
the number of patients cared for a by a specific provider who are discharged
on warfarin with a non-therapeutic INR." (Submitted by: Society of
Interventional Radiology)
(Program: Merit-Based Incentive Payment System
(MIPS); MUC ID: MUC15-1019) |
- The AUA agrees with the MAP Clinician Workgroup’s decision, do not
recommend further consideration, for the non-recommended PSA-based screening
measure. As expressed in numerous comments submitted during the public
comment period, this measure has the potential to negatively impact patient
care. The AUA advocates for shared decision making to allow for a detailed
discussion about risks and benefits of PSA screening with an emphasis on
patient preferences. Additionally, the measure does not exclude high risk
patients, including African Americans and those with a family history of
prostate cancer. This oversight would be extremely detrimental to this
patient population. PSA screening is a highly controversial issue and, with
the USPSTF currently in the process of updating this specific recommendation,
the AUA urges the MAP against further consideration of this measure.
(Submitted by: American Urological Association)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- The Oncology Nursing Society (ONS) is a professional association of more
than 37,000 members committed to promoting excellence in oncology nursing. ONS
supports the MAPs recommendation that further work on this measure be
discouraged. We agree with the MAP comments that measure of "overutilization"
is not well supported in the evidence and inhibits discussion and
decision-making between provider and patient. (Submitted by: Oncology Nursing
Society)
- The MAP draft report describes the extensive discussion on measure
MUC15-1019, Non-Recommended PSA-Based Screening, which is intended to reduce
the use of prostate-specific antigen (PSA)-based screening for prostate
cancer. This measure was based on a 2012 recommendation from the United States
Preventive Services Task Force (USPSTF) that discouraged the use of PSA
screening due to a lack of evidence supporting its benefits, giving the
service a grade D recommendation. The USPSTF recommendation has been
controversial and heavily criticized by the urology community citing concerns
for patients. The AAMC believes that it is premature to establish a quality
measure that will eventually be linked to payment based on a recommendation
that is involved in widespread medical controversy and for which the standard
of care in the community is not clearly established. In addition, the measure
is currently being reexamined by USPSTF. We support the MAPs recommendation to
wait until the controversy over general PSA screening has been resolved and an
evidence-based standard established. MAP noted that overtreatment in this
area is a legitimate concern and that measurement could address more narrow
aspects of screening or treatment specifically until the controversy over
general PSA screening has been resolved and an evidence-based standard of care
is established. (Submitted by: Association of American Medical Colleges
(AAMC))
- (Early public comment)The proposed “Non-Recommended PSA-Based
Screening” measure discourages PSA screening in all men over age 18,
regardless of age or risk factors. The proposed measure could potentially be
used in all of Medicare’s quality reporting programs, which would financially
penalize physicians or other providers who order a PSA screening test. The
measure is based on the flawed PSA screening recommendation of the U.S.
Preventive Services Task Force and contradicts practice guidance by the AUA,
the National Comprehensive Cancer Network, the American Society of Clinical
Oncology, the American College of Physicians-American Society of Internal
Medicine and the American Cancer Society. (Submitted by: Kansas City Urology
Care)
- (Early public comment)Dear CMMS: I am a recent graduate of the Fox
Chase Cancer Center Urologic Oncology Fellowship program. As a surgeon who
did extra training in order to understand the unique challenges and
opportunities to improve cancer of urological cancer patients, and as someone
who regularly sees prostate cancer patients, I strongly disagree with this
proposed measure. By penalizing physicians for PSA screening patients, this
measure will in essence take revoke the right of patients to make informed
decisions about their care. While I believe that overdiagnosis and
overtreatment have been a problem in the past, there is clear evidence that
those trends are being reversed as primary care providers and urologists in
particular become more educated about prostate cancer treatment in the context
of at-risk populations. It is unfair to penalize future patients for the
overtreatment of past patients; cancer care specialists were treating the
disease based on the best available information at the time, prior to an era
when anyone knew that active surveillance was an option for patients with low
risk disease. In the absence of knowledge about what to do, those physicians
were trying to make the best decisions for their patients. Now that we have a
deeper understanding of the natural history of low risk prostate cancer,
physicians are again making the best decisions they can based on the
information at hand, including active surveillance and/or watchful waiting of
these indolent tumors. However, by recommending against prostate cancer
screening, the CMMS will blind physicians to potentially curable diseases by
censoring information. Yes, I view the penalization for gathering information
about a patient's prostate cancer risk as censorship. It is also profoundly
un-American to exempt the patient's right to choose to be screened after an
informed discussion of the risks, benefits, and alternatives. I hope that the
CMS and other parties germane to this discussion are able to come to an
equitable and fair compromise regarding the right of patients and caregivers
to screen for prostate cancer. I am happy to discuss this further by email or
by telephone. Sincerely, Philip Abbosh MD-PhD philip.abbosh@fccc.edu
812-320-1880 (Submitted by: Fox Chase Cancer Center)
- (Early public comment)I think this is too general. I believe that
in some circumstances men should be offered PSA testing and that in the age
range 55-69 men should be given the educated option to test or not. High risk
men need to be identified and given this option as well. (Submitted by: CIty
of Hope)
- (Early public comment)I am a 77 yo male in good health. Over 30
years ago, I was found to have an elevated PSA. I underwent a transurethral
ultrasound and biopsy of my prostate which was negative for prostate cancer.
My PSA was monitored biannually, and 1 year later was noted to increase
slightly. Another TRUSP and biopsy was negative except for 1 small focus of
cancer which was so small, that the pathologist was unable to even grade it
(Gleason). I was placed on Avodart, and continued biannual PSA's. Over the
next 30 years, periodic elevations in my PSA required repeat biopsies all of
which were negate except for one done this year which showed an area of
Gleason 4+3=7 prostate cancer. My urologist recommended external beam IMRT
radiation therapy for which I received 44sessions without problems. I agreed
with everything my urologists in Texas and Florida recommended over the 30
plus years my PSA was elevated, for you see, I am a Board Certified urologist
myself. We now have another tool - MRI Prostate Imaging which may have
confirmed a diagnosis of prostate cancer earlier in my case. The PSA is a very
valuable tool for urologists used to both diagnose and follow the course of
the disease post treatment. (Submitted by: AUA)
- (Early public comment)To Whom It May Concern: As a urologic
oncologist and health services researcher, I welcome the opportunity to review
and provide comments on the Non-recommended PSA- Based Screening Measure under
Consideration. I believe that the proposed measure will lead to a number of
unintended consequences, the most egregious of which is a significant step
away from individualized, patient-centered care and shared decision-making.
Shared decision-making between the patient and provider for prostate cancer
screening with a PSA test is unanimously supported by the American Urological
Association, the American Cancer Society, the American College of Physicians,
the American Society of Clinical Oncology and the National Comprehensive
Cancer Network. The proposed measure will effectively eliminate the patient
from the decision to obtain PSA screening by penalizing physicians who provide
this service. Beyond completely disregarding individual patient preferences,
the proposed measure provides no consideration for the patients who benefit
the most from PSA screening, including those with a family history or a racial
predilection to high-risk prostate cancer. While the role of PSA screening
in the general population remains debated, denying men who are predisposed to
high-risk the opportunity to screen for this lethal disease is not acceptable.
Specifically, this measure is neither useful nor appropriate for assessing
the quality of care for Medicare beneficiaries, as most would agree that high
quality care must consider patient preferences. Our current models of
prostate cancer care support patient autonomy, discussions of risks and
benefits and shared decision making between patients, families and their
providers. Clearly, this measure will undermine these efforts and I urge you
to reconsider its adoption. Sincerely, Lindsey A. Herrel, MD MS (Submitted
by: Urology)
- (Early public comment)I think this does a great injustice to men in
allowing them to make an informed decision regarding PSA testing. Just as
everyone agrees that 'blanket' PSA testing at fairs, etc is not an effective
strategy; blanketing it a 'bad' idea, universally is also highly problematic.
At the end of the day, the diagnosis and treatment of prostate cancer is about
weighing risks and benefits--it is about managing risk. To decide for men
that they don't have a choice in being diagnosed and treated for a potentially
life-threatening cancer--even if it means the unlikely side effects of
incontinence or impotence is paternalistic. It would not surprise me if
twenty years down the road or so, when the natural history of untreated and
metastatic prostate cancer plays out if we look at this measure (and at the
USPSTF task force recommendation) as one of the modern day blunders in
contemporary medicine, akin to estrogen replacement therapy in women.
(Submitted by: Memorial Sloan Kettering)
- (Early public comment)As you know, discussion about the risks and
benefits of PSA screening, in targeted populations, is advocated by many
leading societies, including the American College of Physicians, the American
Society of Clinical Oncology, the American Cancer Society, the National
Comprehensive Cancer Network and the American Urological Association. The
American College of Physicians recommends discussion about risks and benefits
of PSA screening in men between the age of 50 and 69 years. The American
Society of Clinical Oncology recommends discussion about risks and benefits of
PSA screening in men with a life expectancy > 10 years. The American Cancer
Society recommends discussion about risks and benefits of PSA screening in
men: over the age of 50 years for men who are at average risk of prostate
cancer and are expected to live at least 10 more years, over the age of 45
years for African Americans and men who have one first-degree relative
diagnosed with prostate cancer at an age younger than 65 years, and over the
age of 40 years for men with more than one first-degree relative diagnosed
with prostate cancer at an age younger than 65 years. The National
Comprehensive Cancer Network recommends discussion about risks and benefits of
PSA screening in men over the age of 45 years. Finally, the American
Urological Association recommends discussion about risks and benefits of PSA
screening in men between the age of 55 and 69 years, and in men 40 to 54 years
who are African-American or have family history of prostate cancer. Clearly
there is substantial disagreement about the role of PSA-screening. At the very
least, a national clinical quality measure should not be deeply divisive and
controversial, as this PSA screening measure would be. The measure, as
currently drafted, recognizes the shortcomings of routine PSA screening
without consideration of age/comorbidities, individualized risk for prostate
cancer and patient preferences. Additionally, it is based on a the current
recommendation of the United States Preventive Services Task Force (USPSTF)
and a HEDIS measure that only focuses on PSA-based screening in men 70 years
and older. As you know, the USPSTF is now in the process of updating this
specific recommendation (currently in the phase of public comment about
research methodology). Therefore, I urge CMS to delay further development of
this measure until the task force has reviewed the literature, analyzed the
evidence, and completed its update process. The proposed measure does not
provide exclusions for men at high risk, including African Americans and those
with a family history. This is a critical patient population which many
medical societies specifically state should be considered distinct from the
broader population. (Submitted by: University of Michigan Dept of
Urology)
- (Early public comment)To whom it may concern, Non reimbursement of
PSA screening would represent a considerable step backward in the diagnosis
and treatment of prostate cancer in the United States. Please note the
following: 1, While the death rate from prostate cancer has decreased
somewhat since PSA screening was introduced in the late 1980's, the total
population of the U.S. has increased significantly, Because of an aging
population, the population at risk from prostate cancer has actually increased
even more, resulting in a significant decrease in prostate cancer mortality
over this time period. 2. There is no commercially available test which
could at the present time replace PSA. 3. This decision would
disproportionately affect older men, and would represent gender and
age-related discrimination. 4. Studies that were available to U.S.
Preventive Services Task Force when their recommendation for non-screening was
made, contradict their estimation of over treatment. 5. Their recommendation
of non screening has not been adopted by other developed countries or US-based
healthcare agencies. Sincerely, Gary H. Carl, MD Olean General Hospital 623
Main St.. Ste 200 Olean, New York, 14760 (Submitted by: Olean General
Hospital)
- (Early public comment)A measure against PSA screening would have
drastic public health implications for American men. There are numerous
studies that prove that intelligent use of PSA as a screening tool decreases
prostate cancer mortality in appropriate candidates. While we can all agree
that not all men should be screened, there are clearly a subset of men who
will benefit from PSA screening. Certainly we need to focus on screening more
intelligently, but eliminating PSA screening all together will certainly
increase rates of metastatic prostate cancer and prostate cancer mortality.
Enacting a measure that will increase a man's risk of dying of prostate cancer
would be a terrible, and entirely avoidable, mistake. (Submitted by: Temple
University School of Medicine)
- (Early public comment)I write this note with great concern
regarding PSA screening. PSA is the mainstay marker for diagnosis and
management of prostate cancer. The USPSTF recommendation of not using PSA for
screening is irresponsible and illogical. There is no widely accepted test
other than PSA that is economical and efficient in detecting prostate cancer.
If we don't screen for harmful prostate cancer, it will cost the society in
the long run even more by having to take care of late stage cancer patients,
not to mention the side effects and overall survival decrease that will happen
as well. This ruling goes against logic and all guidelines of AUA, SUO, etc. I
would recommend to consult with the experts and then make a final decision
regarding better Prostate cancer screening. Sincerely, Saumil Karavadia, MD
(Submitted by: Advanced Urology)
- (Early public comment)To whom it may concern, Thank you for
considering my comments on the proposed MUC15-1019 - Non-Recommended PSA-Based
Screening. As a practicing general urologist, I see this issue as one of the
utmost importance to the future of men's health and cancer care in the United
States. The USPSTF decision to change the rating of PSA as a screening test
was deeply disturbing, and based on flawed and incomplete data. Of the two
trials used to arrive at the decision, one was flawed in its methods, allowing
up to 50% of men in the non-screening arm to undergo screening. The other
trial, which did have a better design, eventually showed a survival benefit to
screening in data published within 1 year after the data used by the task
force. An additional limitation of both studies was the single focus on
mortality, and the disregard for morbidity of metastatic prostate cancer,
which is significant. It is well known, based on retrospective data, that
implementation of PSA screening in this country has led to a 50% reduction in
prostate cancer mortality. In addition, we have seen the proportion of
prostate cancer that was metastatic at diagnosis drop by 80% since PSA
screening has become widespread. Please consider these facts when
deciding on the proposed regulation. Also consider the lives of all the
fathers, brothers, and sons who will be deprived of proper cancer prevention,
and will be forced to return to an era when the only treatment options were
palliative care and comfort measures. (Submitted by: American Urologic
Association)
- (Early public comment)The suggestion that using the ordering of PSA
as a negative quality point represents a step backward in the identification
of prostatic cancer. The overwhelming number of prostate cancers are
identified by following up on an elevated PSA. Prostate cancer is not
characterized by any specific symptoms and these symptoms or physical changes
are late stage developments. The thought that a physician would have to choose
between doing what is the possibility a life saving test or avoiding a neg
quality indicator for the doctor is totally inappropriate. The government has
not made its case to the public or the profession and until it does it would
be inappropriate to incorporate this quality indicator. (Submitted by: Urology
Associates, Nashville Tn)
- (Early public comment)Blanket recommendations to avoid PSA
screening are likely based on the USPSTF's inherently flawed recommendations.
The control arm of the PLCO trial cited by the the task force was heavily
contaminated with PSA screened patients. PLCO is therefore a trial of "some
screening" vs "more screening." It is therefore understandable that the PLCO
trial did not show a benefit to PSA screening. The ESRPC study (European)
had very little PSA screening in the control arm, and shows a clear cancer
specific survival benefit to PSA screening. Subsequent longer term followup
of ESRPC continues to show an even larger benefit as longer term data becomes
available. Intelligent use of PSA screening coupled with appropriate use of
treatment (including active surveillance in appropriate patients) is a clear
benefit to our patients. Every man deserves a thoughtful discussion with his
physician about the risks and benefits of screening for the second leading
cause of cancer death in men. Penalizing his physician (and ultimately the
patient) for screening will ultimately put us on the wrong side of history
(and the wrong side of good medical science). (Submitted by: Canton Urology
Associates)
- (Early public comment)I am very much in favor of efforts to reduce
the harm associated with PSA testing. But reducing PSA screening for all men
is a very blunt instrument. I am against the proposed measure for two reasons.
First, quality measures that attempt to restrict access to an intervention
should be restricted to areas where there is a broad consensus that the
intervention does more harm than good. There is no such consensus with respect
to PSA screening. The US PLCO trial was grossly contaminated, with about half
of patients in the control group undergoing PSA testing. The authors of the
PLCO trial describe the trial not as a trial of screening vs. no screening but
“opportunistic vs. systematic screening”. Hence there is one major randomized
trial, ERSPC, that compared screening to no screening (Lancet. 2014 Dec
6;384(9959):2027-35). This found a mortality benefit to screening. A major
modeling study has demonstrated that screening leads to improvements in
quality adjusted life years (N Engl J Med. 2012 Aug 16;367(7):595-605. doi:
10.1056/NEJMoa1201637). It is extremely problematic to restrict access to an
intervention that is clearly favored by the major studies of that
intervention. Many of us would be prepared to listen to arguments that PSA
screening does indeed do more harm than good. That is not the point, however:
unless there is an academic consensus an issue, it should not be a quality
measure. My second objection to the proposed quality measure is that there are
much more effective ways to achieve the desired ends of reducing harm from PSA
screening. The most obvious point is that the majority of the harms from
screening come from overtreatment, not overdiagnosis. There is good evidence
from a randomized trial (N Engl J Med. 2012 Jul 19;367(3):203-13. doi:
10.1056/NEJMoa1113162), and considerable consensus in the academic community,
that treatment does not benefit patients with low risk disease. Treatment of
low risk prostate cancer is therefore an obvious candidate for a quality
metric, indeed, it is one metric used to evaluate surgeons at Memorial
Sloan-Kettering Cancer Center. Another alternative to the proposed quality
metric is to a more nuanced approach to reduced PSA testing. The ERSPC trial
did not find benefit to screening in men over 70, and the modeling study
referenced above found that any mortality benefits from screening men in their
70’s is offset by reductions in quality of life. My own group has demonstrated
that 42% of overdiagnosed cases occur in men over 70 and nearly 70% of
overdiagnosed cases occur in men over the age of 65 (BMC Med. 2014 Feb
11;12:26. doi: 10.1186/1741-7015-12-26). Hence restricting screening only in
older men would dramatically reduce overtreatment without a consequent impact
on any benefits of PSA screening. In sum, I agree that reduce harms from PSA
screening should be an urgent priority. Reducing PSA screening across the
board is not the best way to achieve this aim. (Submitted by: Memorial Sloan
Kettering Cancer Center)
- (Early public comment)I have many concerns regarding the flawed
interpretation of PSA screening by the USPSTF in the PLCO and an almost
complete disregard of the ERSPC trial which showed the advantage of PSA
screening. My concerns echo that of LUGPA and AUA letters which have already
been submitted. However, the greater concern is that CMS now proposes to
provide a financial incentive for physicians to NOT have an informed
discussion with their patients about the risks and benefits of prostate cancer
screening. Prostate cancer is the number one cause of non-skin cancer in men
and the second leading cause of death from cancer in men. CMS now proposes a
financial incentive to NOT screen men for the second leading cause of cancer
death? In addition to taking the decision about health related issues out of
the hands of the involved stakeholders (patient and physician), the proposed
policy is directly against the recommendations of the 2 groups that actually
care for the men with prostate cancer (AUA and ACS). I am almost at a loss
for words due to the shocking nature of this proposal. (Submitted by: Urology
Clinics of North Texas)
- (Early public comment)This is simply a mistake. The USPSTF
recommendations were flawed, and one cannot make recommendations when the base
building blocks are incorrect. Please, for the sake of our patients, consider
abolishing this until years of properly performed research can be completed.
We physicians use our years of training and experience in dealing with our
patients, you should let us practice medicine for the benefit of the patient.
(Submitted by: Rocky Mount Urology Associates)
- (Early public comment)While PSA as a screening measure has
limitations, it remains the best available screening test for the most common
cancer among men. Discouraging testing, while seemingly financially
attractive for the healthcare system at large, will lead to the scenario of
aggressive and potentially lethal cancers being missed. Turning a blind eye
to a cancer that kills 1 in 38 men is not quality care. I support the current
PSA screening guidelines of the American Urological Association where
screening is focused on shared decision making and assessment of risk. I do
not believe that a financial incentive has any place in that conversation.
(Submitted by: Aultman Hospital)
- (Early public comment)The proposed “Non-Recommended PSA-Based
Screening” measure discourages PSA screening in all men over age 18,
regardless of age or risk factors. The proposed measure could potentially be
used in all of Medicare’s quality reporting programs, which would financially
penalize physicians or other providers who order a PSA screening test. The
measure is based on the flawed PSA screening recommendation of the U.S.
Preventive Services Task Force and contradicts practice guidance by the AUA,
the National Comprehensive Cancer Network, the American Society of Clinical
Oncology, the American College of Physicians-American Society of Internal
Medicine and the American Cancer Society. (Submitted by: Kansas City Urology
Care)
- (Early public comment)On behalf of the physicians of Urology
Specialists Clinic and Surgical, we are strongly opposed to this proposed
measure. In the United States, the rate of dying from prostate cancer has
decreased by 40% and the rate of developing metastatic prostate cancer has
decreased by 75% since the introduction of PSA testing 25 years ago. This
disease is curable if caught early, but shows no symptoms until it has spread.
Therefore, PSA is still really the only tool we have to detect the cancer
before it is too late to cure. We continue to believe that PSA screening is
valuable, saves lives, and it is the right of each patient to have a
conversation with their physician about potential benefits as well as harms
and decide whether PSA screening is right for them. The proposed
"Non-Recommended PSA-Based Screening" measure discourages PSA screening in all
men over age 18, regardless of age or risk factors. The proposed measure could
potentially be used in all of Medicare's quality reporting programs, which
would financially penalize providers who order a PSA screening test. The
measure is based on the flawed PSA screening recommendations of the U.S.
Preventive Services Task Force and contradicts practice guidance issued by the
AUA, the National Comprehensive Cancer Network, the American Society of
Clinical Oncology, the American College of Physicians-American Society of
Internal Medicine and the American Cancer Society. (Submitted by: Urology
Specialists Chartered)
- (Early public comment)PSA is the best screening tool at this time
for proper diagnosis and treatment of prostate cancer. Until a better test
becomes available, we should not pretend that prostate cancer does not exist.
PCA s still the most commonly diagnosed solid organ cancer in men, and the
second leading cause of cancer death in men. PSA screening, when done
properly, has shown to decrease mortality from PCA. Not using PSA to screen
men for PCA will harm men, and is not in the best interest of our patients.
Instead of focusing on PSA screening, we should focus on proper treatment of
PCA, and proper selection of who needs to be treated. Currently, there are a
number of prognostic tests such as the 4K score, Prolaris Genetic Marker test,
Oncotype Dx, and others that help clinicians risk stratify patients newly
diagnosed with prostate cancer, and these tests can help direct proper
selection of those who need to be treated. (Submitted by: Advanced
Urology)
- (Early public comment)Most primary care physicians are ignorant
about the nuances of screening, diagnosis, and treatment of prostate cancer.
Thus, they refer appropriate patient to urologists. Unfortunately, since they
are the gatekeepers to the specialists, measures like MUC15 disincentive
primary care physicians to refer appropriate patients to urologists, who are
knowledgeable in such aspects related to prostate cancer. Before and since the
USPSTF recommendations against PSA screening, I have seen numerous black men
under the age of 55 with PSA values in the 50 to 100 range. Such high risk
individuals will die in the future if PSA screening and prostate cancer
management is taken out of the hands of those who know it best, the
urologists. (Submitted by: U of Florida College of Medicine,
Jacksonville)
- (Early public comment)I am a practicing urologist. I strongly
oppose any measure which would penalize physicians for ordering PSA tests. No
matter what the details of the proposal are, the message to primary care
providers would be interpreted simply as "If I a order PSA, I will pay a
penalty." This measure would indeed have a chilling effect on PSA testing
among those who are really at the front line of screening, primary care
providers. Urologists are all too aware that the USPSTF recommendations are
based on fundamentally flawed data, and as such have not stopped appropriate
PSA screening. We have, however, made massive changes in the way we treat
prostate cancer, with rapid adoption of active surveillance as a primary
option for many men. Improvements in treatment of the primary tumor and better
understanding of the natural history of the disease, however, mean nothing to
men who are diagnosed with metastatic disease. These are the men who will pay
the price for the discontinuation of PSA screening by primary care providers.
On October 29. 2015, Gilbert Welch, MD MPH authored a piece in the NEJM which
shows that since the initiation of widespread PSA screening in 1990, the
incidence of new presentations of metastatic prostate cancer has dropped from
around 65 per 100,000 to around 25. Unfortunately, there has been no
comparable decrease in the incidence of metastatic breast cancer since the
institution of widespread mammography. In addition, a quick look to the SEER
database website on prostate cancer shows a more than 50% drop in the
incidence of death from prostate cancer in the US since 1990. To stop PSA
screening, we would give up these incredible gains we have made against
prostate cancer. This change would be tantamount to stopping our anti-smoking
campaign, which has brought similar massive improvements in the fight against
lung cancer. If CMS would like to improve the lives of men at risk for
prostate cancer, I would suggest that the agency focus on ensuring that men
diagnosed with cancer are properly counseled and that those who would benefit
from active surveillance are offered it. By doing so, treating physicians can
help improve quality of life without sacrificing the amazing gains that PSA
screening has produced in the last 25 years. (Submitted by: Virginia
Urology)
- (Early public comment)I am Associate Professor of Urology, and of
Epidemiology and Biostatistics, at the UCSF Helen Diller Family Comprehensive
Cancer. I have published over 200 peer-reviewed peer reviewed articles,
focused primarily on prostate cancer
(http://www.ncbi.nlm.nih.gov/pubmed/?term=cooperberg+m). Much of my work and
that of my colleagues at UCSF over the past 15 years has focused on problems
of over-treatment of low-risk prostate cancer, and the resulting impacts of
that over-treatment on affected men's quality of life. I have reviewed the
USPSTF evidence summary and position in statement in detail and have met 4 of
the task force members over the years. There is really no argument among
anyone with true expertise on this question that the USPSTF reached the wrong
conclusion with their "D" recommendation against screening. By regulation, the
panel excludes specialists, but they chose to reject many key opinions by both
clinical and statistical content experts, including the NIH/NCI-sponsored
CISNET researchers. As a result, their evidence review was based on a
fundamentally flawed interpretation of the existing evidence base. As just a
few examples: • The PLCO trial, by the trial authors' own statement, was not
a trial of screening vs. no screening; it was a trial of annual screening vs.
opportunistic screening.(http://dx.doi.org/10.1093/jnci/djr500) It therefore
should not have been included as evidence against screening. • The USPSTF
statement re: absence of benefit at 8-10 years follows indicates a poor
understanding of the intent of screening. The benefits only start to accrue at
8 years and take much longer to be fully realized
(http://dx.doi.org/10.1200/JCO.2010.30.6373). A man with an 8-10 life
expectancy should not be screened, and this is not controversial. • The
USPSTF drastically over-states the harms of screening by cherry-picking the
literature to find worst-case scenarios re: harms of treatment. E.g., they
cite a 0.5% perioperative mortality rate for prostatectomy, based on out-dated
papers reporting data from low-volume surgeons treating only older men. They
ignored, e.g., a JAMA study showing a 10-fold lower rate in contemporary
practice (http://dx.doi.org/10.1001/jama.2009.1451). • The USPSTF completely
ignored risk factors like race and family history. African-American men are
completely under-represented in all available data sources on screening, and
are known to have much higher rates of prostate cancer and lethal prostate
cancer. There are many, many other examples. The USPSTF is the only major
guideline recommending against all screening. Most others, including the NCCN,
AUA, ACS, and ACP/ASIM, recommend some variation on shared decision-making
recognizing both benefits and harms of screening. There is no question that
PSA screening has not been implemented optimally in the U.S.—we tend to start
screening too late, we repeat screening too frequently, we continue too late
among men with comorbidity, and we often overtreat low-risk disease and
undertreat high-risk disease. The solution, however, is not to abandon
screening but rather to screen smarter. Men with good life expectancy should
be screened early, and, if the baseline is low, much less frequently. Low-risk
disease should rarely be treated, and recent evidence shows that rates of
active surveillance are rising very rapidly
(http://dx.doi.org/10.1001/jama.2015.6036). But high-risk disease needs to be
found early and treated aggressively. Screening and better treatment explain
=60% of the over 50% drop in prostate cancer mortality rates we have seen
since the 1990s (http://dx.doi.org/10.1002/cncr.27594), and it is a
mathematical certainty that if we abandon screening wholesale we will be
return to the 1980s in terms of metastatic disease levels
(http://dx.doi.org10.1002/cncr.28932), and given the aging population and new
treatments available, this will equate to an extraordinary burden of entirely
avoidable suffering, early mortality, and costs to the healthcare system.
Early data following the 2012 "D" recommendation suggest that we have seen a
25% drop in overdiagnosis of low-risk disease—and a 25% drop in diagnosis of
high-risk disease as well which implies a comparable increase in
underdiagnosis. (http://dx.doi.org/10.1016/j.juro.2015.06.075). Final specific
comments on the proposed CQM: 1) 4.0 is no longer recognized as a uniform
threshold. A PSA above 4 for an older man with BPH may be unconcerning, but a
PSA even above 1 for a healthy 50 year old would at least justify follow-up
repeat retesting. 2) "Dysplasia" of the prostate is a nonspecific term that
does not correspond to any current pathological diagnosis. 3) LUTS (voiding
symptoms) and BPH are also absolute indications for PSA. In closing, to
establish a CQM on this issue suggests that consensus exists where in fact a
raging controversy continues. In fact, even the USPSTF will be re-addressing
the question and has just opened public comment on their evidence plan. PSA
screening should be improved not abandoned, and this CQM would be a major step
in the wrong direction, and exactly the wrong time. Feel free to contact me at
matthew.cooperberg@ucsf.edu for any clarifications or questions. (Submitted
by: University of California, San Francisco)
- (Early public comment)As a urologist who treats prostate cancer
patients, I do not support using PSA testing as a quality measure. The
original grade D decision by the USTSPS was based on poor studies and the
current risks/benefit ratio has tipped in favor of PSA screening as active
surveillance of prostate cancer has become more utilized. Appropriate PSA
testing based on shared decision making between the patient and the doctor
should be recommended, and a physician should not be penalized if a mutual
decision has been made to screen for prostate cancer, especially in high risk
patients. (Submitted by: Mayo Clinic Arizona)
- (Early public comment)There is ample evidence to prove that PSA
screening significantly improves survival in the treatment of prostate cancer.
It is highly unfortunate that the USPTFA did not take this data into
consideration or allow the input of National Urological Associations and
Oncology associations. For any decision like this to be made, thought leaders
in these fields need to reexamine this issue to formulate an appropriate
decision. I feel that this is so wrong, that it would be justified to take
legal action for male discrimination by CMS and get the Supreme Court involved
as well as Congress to overturn this misguided decision. (Submitted by:
AUA)
- (Early public comment)The PSA is a valuable tool for diagnosis and
management of men who are at risk for prostate cancer. Improved
interpretation of the test and counseling are more appropriate than attempts
to penalize providers for ordering the test. Do not discourage counseling and
communication between patient and physician. (Submitted by: J Szobota
MD)
- (Early public comment)Patrick Conway, MD Deputy Administrator for
Innovation & Quality Centers for Medicare & Medicaid Services Chief
Medical Officer 7500 Security Boulevard Baltimore, MD 21244 Kate Goodrich, MD
Director Quality Measurement and Value-Based Incentives Group Centers for
Medicare & Medicaid Services 7500 Security Boulevard Baltimore, MD 21244
Subject: MUC15-1019: Non-Recommended PSA-Based Screening December 7, 2015
Dear Drs. Conway and Goodrich, ZERO - The End of Prostate Cancer (ZERO)
appreciates the opportunity to comment on the draft clinical quality measure
MUC15-1019 the “Non-Recommended screening for prostate cancer using
prostate-specific antigen (PSA): Percentage of men who were screened
unnecessarily for prostate cancer using a prostate-specific antigen
(PSA)-based screening.” ZERO is a national nonprofit with the mission of
ending prostate cancer. We lead the fight to end the disease by advancing
research, encouraging action, and providing education and support to men and
their families. As you may know, prostate cancer is a disease that will impact
one in seven American men in his lifetime. There are nearly 2.8 million men
living in the United States with prostate cancer and the American Cancer
Society estimates that in 2015 roughly 220,800 men will be diagnosed and
27,540 men will lose their lives to the disease. ZERO is very concerned the
measure under consideration does not include basic exclusions recommended by a
range of provider and advocacy groups or appropriately target the harmful
overtreatment of men (instead focusing on over-screening). In addition, we are
troubled that the release of the draft measure does not take into
consideration the upcoming revision of the U.S. Preventive Services Task Force
(USPSTF) recommendation. CMS’ call for comments asked for feedback in several
specific areas, for those our comments are as follows. First, this draft
measure is too broad in its population catchment to add significant value in
assessing the quality of care for Medicare-aged beneficiaries. We recommend a
more nuanced approach, making exclusions for age and other risk factors, which
will allow CMS to accurately assess whether or not patients are encountering
physicians who employ best practices in screening across the range of age
groups in the Medicare population and accurately adjust for an individual
patient’s demographic factors and medical history. Second, the measure could
significantly harm patient outcomes. The absence of ordering a diagnostic
blood test does not indicate quality provider performance or improve patient
outcomes; quite the contrary. Instead it offers a perverse incentive for
physicians to maintain ignorance of the condition, including associated new
diagnoses or treatment options, and limit discussion, diagnosis and treatment
for patients. The burden of reporting this measure is best commented on by
provider. However, the promise of EHRs allows for a more accurate provider
response, and thus a more detailed screening and treatment recommendation,
reflecting best practices that National Headquarters 515 King Street • Suite
420 • Alexandria, VA 22314 take into consideration risk factors, individual
life expectancy, and disease progression estimations. Finally, Zero is
supportive of recommendations by many of the professional societies, provided
in more detail below, all of which acknowledge the variations that exist in
men of different ages and backgrounds. These recommendations are discussed in
more detail below. ZERO’s broad concern with the proposed measure is that it
further discourages the use of medically necessary PSA screening in all men
over age 18, regardless of age or risk factors, setting up a scenario whereby
physicians could be financially penalized for diagnosing a fatal cancer in men
who, with treatment, would not die of the disease. The measure is based on the
flawed PSA screening recommendations of the USPSTF and contradicts practice
guidance issued by the American Urological Association, the National
Comprehensive Cancer Network, the American Society of Clinical Oncology, the
American College of Physicians-American Society of Internal Medicine, and the
American Cancer Society. The measure, as currently drafted, paints the
shortcomings of PSA screening with too broad a brush and fails to make any
consideration of individual patient risk factors, including age, race, family
history and comorbidities. High risk patients, including men with
African-American ancestry, veterans, and those with a family history, should
be considered distinct from the broader population, as reflected by the
guidance of many medical societies and patient care groups. Furthermore, the
stratification by age is an important component in all the societies’
guidance: • The American Urological Association recommends discussion about
risks and benefits of PSA screening in men between the age of 55 and 69 years,
and in men 40 to 54 years who are African-American or have family history of
prostate cancer. • The American College of Physicians recommends discussion
about risks and benefits of PSA screening in men between the age of 50 and 69
years. • The American Society of Clinical Oncology recommends discussion about
risks and benefits of PSA screening in men with a life expectancy > 10
years. • The American Cancer Society recommends discussion about risks and
benefits of PSA screening in men: over the age of 50 years who are at average
risk of prostate cancer and are expected to live at least 10 more years, over
the age of 45 years for African- Americans and men who have one first-degree
relative diagnosed with prostate cancer at an age younger than 65 years, and
over the age of 40 years for men with more than one first-degree relative
diagnosed with prostate cancer at an age younger than 65 years. • The National
Comprehensive Cancer Network recommends discussion about risks and benefits of
PSA screening in men over the age of 45 years. That the USPSTF recommendation
contradicts practice guidance issued by these expert groups reflects the flaws
in the Task Force methodology more than any compelling science arguing against
such basic exclusions for race and other risk factors. In October, the USPSTF
initiated the process of updating its PSA recommendation. The public comment
period on the draft research plan ended November 26, 2015. Making changes to
the current recommendation about Medicare practices until this re-assessment
has been completed would appear to be premature at best. ZERO strongly
encourages CMS to delay further development of this measure until the USPSTF
has completed its update process, including a thorough review of the latest
literature and evidence. Finally, we believe the most important point in the
discussion around appropriate use of the PSA test is that the potential harms
associated with the use of the test itself are negligible, simply reflecting
the potential harms associated a common blood draw. It is the potential harms
associated with the improper treatment of prostate cancer that the Task Force
seeks to mitigate. A more appropriate policy should discourage the overly
aggressive use of invasive treatment for localized forms of low risk prostate
cancer among men who are unlikely to have clinically significant prostate
cancer that could lead to their deaths. Discouraging use of the PSA test in
the early detection of prostate cancer will lead to an increase in the number
of men diagnosed at an advanced stage of prostate cancer when the disease can
no longer be cured with localized treatments. While the draft measure
recognizes the value of PSA testing in men with a known elevation in the PSA
level, or with a diagnosed disorder that affects PSA levels, it would
effectively eliminate use of the PSA test in men with no clinical signs or
symptoms of a prostatic disorder (prostate cancer specifically included).
These exact groups of men, and particularly those who are otherwise healthy
between the ages of 45 and 69, serve to benefit the most from a PSA test,
which helps to diagnose men at risk for clinically significant prostate cancer
before there are any signs and symptoms of the disease. This practice is
clearly associated with (if not entirely responsible for) the decline in both
the prostate cancer-specific mortality rate and in the risk of a metastatic
prostate cancer diagnosis over the past 25 years. A national clinical quality
measure should not be deeply divisive and controversial, as this PSA screening
measure would be. Therefore, ZERO joins many other provider groups and patient
advocacy organizations in urging CMS to abandon, or delay, this misguided
effort. On behalf of the millions of men and their families fighting prostate
cancer, we thank you for the opportunity to share these comments and look
forward to working with CMS to ensure that men at risk for prostate cancer are
diagnosed early and when diagnosed, receive appropriate treatment. Best
Regards, Jamie Bearse President and CEO ZERO - The End of Prostate Cancer
(Submitted by: ZERO - The End of Prostate Cancer)
- (Early public comment) Washington State Urology Society To: NQF CMS
Quality Measures Committee From: Jeff Evans, MD Date: December 5, 2015 Re:
Public Comment concerning NQF recommendation regarding PSA screening quality
measure Members of NQF Quality Measures Committee: I am writing on behalf of
the Washington State Urology Society (WSUS) membership regarding the NQF
recommendation of using PSA screening as a quality measure. Most urology
organizations and the American Cancer Society disagree with the “D” rating
handed down by the US Preventative Services Task Force (USPSTF) May 21, 2012
regarding prostate cancer screening. The fallout of that decision has
resulted in far less prostate cancers being diagnosed this year and we fear
will lead to a higher number of prostate cancer deaths. NQF is taking the same
view as the USPSTF and recommending PSA screening be linked to quality care.
We feel this action would be very irresponsible and is politically and morally
indefensible. CMS should not get in the middle of this statistical
disagreement between the USPSTF (an organization that did not seek meaningful
input from urologists, radiation oncologists or medical oncologists) and the
experts that actually treat prostate cancer. Not getting a PSA should in no
way be a quality measure unless not getting this test shows compromised
quality. Prostate cancer is the 2nd leading cause of cancer death in men
(kills more men than colon cancer). The advantages and disadvantages of PSA
screening regarding survival are certainly debatable. Most of the controversy
is regarding the interpretations of the Prostate, Lung, Colon and Ovarian
Cancer Screening Trial (PLCO) and the European Randomized Study of Screening
for Prostate Cancer (ERSPC). It is key to recognize the significant
limitations of those studies when attempting to make policy decisions. The
PLCO was a study of “some screening” v. “good screening” (i.e. pre-screening
contamination). However, the PLCO still showed that in young men with no
co-morbidities there was a statistically significant reduction in prostate
cancer deaths. Updated data from ERSPC has demonstrated a 21% risk reduction
in prostate cancer related death associated with screening (up to 29% after
accounting for non-compliance). Regardless of how either study is interpreted,
the U.S. 1990 age-adjusted death rate from prostate cancer was 39 per 100,000
and in 2009 was 18.5 per 100,000, likely from increased prostate cancer
screening with the advent of widespread PSA testing. Additionally, the
Goteborg Trial also showed a substantial 44% relative risk reduction in
prostate cancer mortality in men 50-64 years after a median of 14 years.
Importantly, the risk reduction occurred in a setting where many of the
patients were not aggressively treated for prostate cancer, indicating that
the harms of PSA-based screening can, in fact, be minimized by good clinical
practice. The SEER Registry data demonstrates a 75% reduction in the
proportion of men with prostate cancer who present with metastatic disease, as
well as a 42% reduction in age-adjusted prostate cancer mortality during the
PSA era. No other screening test available can boast such a dramatic reduction
in the risk of developing metastatic disease. The relative survival at 10
years for a patient with localized prostate cancer was 72%, compared to 3% for
a patient with distant (metastatic) disease. Models developed in our state at
the University of Washington (CISNET) demonstrated that early detection
through screening could account for approximately 45-70% of the decline in
prostate cancer mortality under a “stage-shift” mechanism for screening
benefit. The dialogue created by the USPSTF has done a disservice to our male
patients in several ways. Blanket screening of men for screening is one
thing, but patients with lower urinary/pelvic symptoms and patients at higher
risk of death from prostate cancer are not even being screened adequately.
The American Academy of Family Practice Choosing Wisely campaign has even
recommended to never perform a rectal exam for screening purposes. What is the
harm in a physical exam? Those at higher risk such as African Americans,
patients with a significant family history and those with increased prostate
cancer risk (e.g. Agent Orange exposure) are being denied shared decision
making because of the “harms” of prostate cancer screening. What about the
harms of not screening? Our organization is worried that Mathmetica’s
recommendation to make PSA screening a quality measure will make appropriate
evaluation in patients with symptoms, or those that are at increased risk, to
be even less likely to receive a proper evaluation with PSA/DRE for fear of
financial repercussions to the physician. Any urologist will attest to the
fact that we are seeing an increase in advance prostate cancer in our clinics.
The LHRH agonist/antagonist (initial treatment for metastatic disease) sales
force will admit to a 3-4% increase in sales because of an increased
presentation of metastatic prostate cancer over the last 4 years since the
“PSA downgrade”. In the state of Washington our urologists have certainly
noticed this. We all have stories of patients being denied PSA screening
(despite requesting it) and then presenting back later with metastatic
disease. We believe the “risks of screening” have been overstated as
treatments become more precise and when less prostate cancers are being
treated in an era where active surveillance has been embraced for low risk
disease. The harms of treatment for metastatic prostate cancer therapy should
be considered just as carefully given the greatly increased risk of metastatic
disease in an unscreened population. As stage migration regresses back to the
pre-PSA screening era, we will have more men on hormone deprivation, dealing
with bone pain and pathologic fractures and urinary obstruction. Reverting
back to a focus on shared decision making is very appropriate when considering
all the recent improvements in screening tools, genomic testing and adoption
of active surveillance (monitoring patients without active treatment) when
medically appropriate. Active surveillance for low risk disease and improved
screening tools such as 4K score, PCA3 and ERSPC risk calculator aid in the
detection of intermediate and high grade disease prior to biopsy. Genomic
testing on biopsy tissue such as Oncotype Dx and Prolaris are increasingly
being used to aid in predicting those with very low and intermediate risk
disease (eg. Oncotype Dx and Prolaris). Therefore, CMS should not interject
themselves in this very polarizing debate regarding screening for prostate
cancer. The WSUS suggests NQF not move forward with the recommendation to use
PSA screening as a “quality measure”. Thank you for soliciting opinions and
considering the WSUS position on this important topic. Feel free to reach out
to us for any additional comment or resources we can offer you. We would
appreciate your sincere consideration of important comments and eagerly look
forward to your updated recommendations. Respectfully, Jeffrey L. Evans, MD
President of Washington State Urology Society Cell: 206-852-3397
jeffreylewisevans@yahoo.com (Submitted by: Washington State Urology
Society)
- (Early public comment)Malecare Cancer Support facilitate American's
largest prostate cancer patient support network. We are also our country's
leading men's cancer survivor support and advocacy national nonprofit
organization, with a unique focus on African-American cancer survivorship. We
ask that the use of the PSA test for screening of prostate cancer be left as a
option for patients and doctors to utilize. (Submitted by: Malecare Cancer
Support)
- (Early public comment)This measure would essentially take us back
to the 1970's with no screening or preventative care for prostate cancer.
Although there are certain cases of prostate cancer that may not require
therapy, there are many serious and dangerous prostate cancers that would go
undetected and lead to a significant number of patient deaths. It is very
important to at least be able to establish a diagnosis on men in the range of
50-75 years so that options can be given to patients on treatment. A digital
rectal examination is highly inadequate to be able to determine the need for a
prostate biopsy and although PSA is not specific for cancer, it has been a
very good test in reducing the prostate cancer death rates in this country.
This measure of eliminating PSA is ridiculous and dangerous and is not at all
in the best interests of patients! (Submitted by: Martin Health
System)
- (Early public comment)I am a general internist and served as a
member of both the American College of Physicians and the American Urological
Association guideline panels on PSA screening. These guidelines differ from
the USPSTF in that they recommend a “shared decision making” approach to PSA
screening among men in the age range showing a prostate cancer mortality
reduction in the ERSPC trial (approximately age 55-69). The one fewer death
per 1000 men screened over 10 years (and about 1.3 fewer deaths over 13 years
in the most recent ERSPC publication) is not dissimilar to the benefit seen
with breast cancer screening. I believe the ERSPC yields a more valid estimate
of the benefit of PSA screening compared to the PLCO trial in the United
States, given less contamination of the control group with “usual care” PSA
testing. Undoubtedly, PSA screening leads to substantial overdiagnosis and
overtreatment, more so than with breast cancer screening. However, the balance
of benefits and harms is close enough that I believe informed men of an
appropriate age should have a strong say in whether or not to be screened. In
our research, about a third of well-informed men (who have seen a patient
decision aid and completed a knowledge test) still want a PSA test (Barry MJ,
et al. Responses to a Decision Aid on Prostate Cancer Screening in Primary
Care Practices. Am J Prev Med. 2015 Oct;49(4):520-5). I would recommend that
CMS develop a quality measure that discourages screening for men age 75 and
older (too many of whom currently get PSA tests), and allows PSA screening
only after documentation of a shared decision-making process including a
decision aid for younger men. This approach would be similar to the recent CMS
decision to cover low dose computerized tomography for lung cancer screening
only after such a process has been completed. (Submitted by: Informed Medical
Decisions Foundation)
- (Early public comment) December 7, 2015 BY ELECTRONIC SUBMISSION
Elizabeth McGlynn, PhD, MPP Harold Pincus, MD Coordinating Committee Chairs
Measure Applications Partnership National Quality Forum 1030 15th Street NW
Suite 800 Washington DC 20005 Re: MUC15-1019 Non - Recommended PSA - Based
Screening Dear Drs. McGlynn and Pincus, On behalf of LUGPA, we thank you for
the opportunity to comment on the performance measure MUC15-1019 “unnecessary
screening for prostate cancer using prostate - specific antigen (PSA).”
LUGPA has significant clinical concerns regarding how the implementation of
this policy as written will affect patient care; these concerns are based on
several factors: 1. LUGPA (and other organizations representing physicians who
care for or represent the interests of patients with prostate cancer)
fundamentally disagrees with the scientific methodology on which the United
States Preventative Services Task Force (USPSTF) based its Grade “D”
recommendation regarding PSA-based prostate cancer screening; 2. Data
regarding prostate cancer diagnosis suggest that the medical community’s
response to the USPSTF recommendation may already have resulted in reduced
detection of biologically significant cancer with resultant missed opportunity
for curative intervention; and 3. The timing of the proposal is premature
given the fact that the USPSTF itself is revisiting the issue of PSA-based
prostate cancer screening. I. LUGPA In 2008, when physician leaders of
large urology group practices began to recognize the need for a formal
association to help meet the challenges of the future, LUGPA was initially
established with the purpose of enhancing communication between large groups,
allowing for benchmarking of operations, promoting quality clinical outcomes,
developing new business opportunities, and improving advocacy and
communication in the legislative and regulatory arenas. Since that time,
LUGPA has expanded its mission to include smaller group practices that are
equally committed to providing integrated, comprehensive services to patients
suffering from genitourinary disease. LUGPA currently represents 121 urology
group practices in the United States, with more than 2,000 physicians who
collectively provide approximately 30% of the nation’s Urology services.
Integrated urology practices are able to monitor health care outcomes and
seek out medical “best practice” in an era increasingly focused on medical
quality and the cost-effective delivery of medical services, as well as better
meet the economic and administrative obstacles to successful practice.
LUGPA’s mission is to provide urological surgeons committed to providing
integrated, comprehensive care the means to access resources, technology, and
management tools that will enable them to provide all services needed to care
for patients with acute and chronic illnesses of the genitourinary system,
including men with prostate cancer, in an efficient, cost-effective, and
clinically superior manner, while using data collection to create parameters
that demonstrate quality and value to patients, vendors, third party payors,
and regulatory agencies and legislative bodies. Over the past several years,
LUGPA has taken an active role in providing CMS and other governmental
agencies, including the Medicare Payment Advisory Commission (MedPAC) and the
Government Accountability Office (GAO), critical data and other information
regarding diagnostic and therapeutic modalities used in providing prostate
cancer care to Medicare beneficiaries. On numerous occasions, LUGPA
representatives have met with senior leaders in all of these agencies, as well
as with members of Congress, to discuss peer-reviewed and other empirical
studies of the utilization of various modalities for diagnosing and treating
prostate cancer in Medicare beneficiaries. In addition, LUGPA has provided
comments to CMS on the Medicare Shared Savings Program/Accountable Care
Organizations proposed rule and continues to take a leadership role with
respect to proposed bundled payment systems for prostate biopsy services. We
hope to continue the relationship we have established with CMS, MedPAC, GAO,
and others by providing meaningful commentary to agency reports, inquiries,
and proposals. Thus, we respectfully provide the following comments on the
proposed measure regarding non-recommended PSA-based prostate cancer
screening. II. The Scientific Underpinning of the USPSTF Recommendation
is Flawed We do not believe that USPSTF reached a correct conclusion regarding
the clinical value of PSA screening. In fact, we believe that the task force
decision is based on incomplete data, an inappropriate superimposition of the
risks of therapy onto the risks of screening and a misunderstanding for
clinical changes that are occurring presently in the real world management of
PSA screening in conjunction with the shared decision making being offered to
patients with newly diagnosed prostate cancer in the United States today. At
the time of the recommendation we expressed concern that great harm will ensue
for patients with intermediate and high risk localized prostate cancer as well
as those already with advanced, asymptomatic metastatic disease, unintended
victims of collateral damage as a consequence of the USPSTF recommendation to
avoid the overtreatment of prostate cancer patients with low risk disease.
The authors of the supporting review article in the Annals of Internal
Medicine (Chou et al.) and members of the USPSTF shared a number of distinct
characteristics that are troublesome: a void of urology, urologic oncology,
radiation oncology or medical oncology inclusion; some authors are not
physicians and it is unclear for those who are physicians if they are in
active practice. Hence, the review authors and the USPSTF together may lack
certain clinical insights that would assist them to understand: 1) the
significant clinical concerns and consequences of their recent f PSA
screening recommendations in this country and worldwide, 2) the educated and
appropriate use for PSA screening, 3) PSA utilization in conjunction with the
rapidly advancing field of compendium and complimentary biomarkers and how the
screening efficiency has rapidly changed in the last 2 years and 4)
ultimately, best practices for the future. It is critical to the discussion of
screening to differentiate risks of screening from risks of treatment.
Unfortunately, the section of the draft document on Harms of Screening and
Treatment virtually ignores the physical risks of screening, focusing entirely
on risks of biopsy and treatment. Actual physical risks of the screening
process itself are minimal: PLCO reports a combined incidence of 26.3 events
per 10,000 men screened, or 0.26%. It is not common clinical practice to
automatically biopsy every patient detected on PSA screening; there are many
factors that influence this decision including free and total PSA, patient
age, PSA velocity, PSA density, family history, ethnicity, prior biopsy
history and other comorbidities. In making its recommendation, the USPSTF
acknowledged that the existing studies on prostate cancer screening had very
significant methodological flaws, as agreed upon by the authors of the
manuscript as well; in fact, two studies were characterized as “fair.”
However, it was unclear as to the method by which these two studies (the
Prostate, Lung, Colorectal and, Ovarian Cancer Screening Trial (PLCO) and the
European Randomised Screening for Prostate Cancer (ERSPC) trial) were
weighted. It was clear that the panel gives enormous weight to the PLCO study
and virtually disregards the findings of the ERSPC; however, the flaws in the
PLCO study appear much deeper than those in the ERSPC. Please consider the
following: 1. The panel states that overall mortality is the goal studied by
all trials reviewed. This is simply untrue. The ERSPC and Göteburg trials
were specifically statistically powered to evaluate prostate cancer specific
mortality (PCSM), not all cause mortality. Overall mortality provided a
parameter for assessing randomization rather than serving as an end point in
itself. Dismissing the importance of a statistically significant 20%
reduction in the overall PCSM for ERSPC and 44% reduction of PCSM in the
Göteburg component as “small to none” misses the clear clinical benefit to
these patients and their families. 2. The PLCO study recruited 40% of men with
a history of prior screening into their control arm. Furthermore, as the
control arm was defined as “usual care,” and not “no screening,” patients were
continued to be allowed to receive PSA testing during the study interval,
resulting in screening being performed in >50% of the “control” arm, thus
diluting the differential impact of PSA screening. Other than a statement
that the authors attempted to correct for this, the USPSTF does not discuss
their appreciation of this obvious error. 3. Although the major randomization
error in (2) above is mentioned in passing, the following significant flaws in
the PLCO do not appear to have been considered by the panel: a. Only
approximately 40% of patients in the screening population who screened
positive actually underwent prostate biopsy. b. The overall follow-up with 98%
mortality data in the PLCO trial was only 7 years. 4. These errors in the
PLCO, not mentioned in the USPSTF recommendations, reveal that the PLCO report
is inconsistent with the characteristics of a screening trial. Although the
percentage of cancers in screened patients (7.4%) was higher than seen in
“usual care” men (6.1%), this difference is far less than would be expected in
a screened vs. unscreened population. Consider that in the ERSPC, the
reported figures were 8.2% vs. 4.8%, respectively. Additionally, in PLCO, the
presence of stage III/IV disease was nearly the same (122 in screened vs. 133
in “usual care”) compared to what is consistent with screened vs. unscreened
studies like ERSPC where unscreened men were much more likely to have higher
stage disease and, indeed, they did, with 41% more positive bone scans
compared to screened men at diagnosis. There exist today multiple unmet needs
in caring for men with prostate cancer. Curing men with localized high risk
disease is tantamount to reducing the approximate 28,000 annual cause specific
mortality within the US; furthermore, while ~5% of the newly diagnosed
prostate cancer patients within the US present with metastatic disease, the
urologic oncology community goals are not to increase that percentage
population but rather to identify them as early as possible in order to
initiate our many recently approved therapies and thus avoid the sequelae of
this disease. 5. There is no mention of 2 sub-group analysis in the PLCO trial
showing survival benefits: a. About 10% of both controls and usual care men
had undergone 2 or more PSA tests before randomization; their PCSM was 25%
lower than men not tested and b. A later study of a healthier sub-group of
PLCO men by Crawford showed a 44% survival benefit. This discounting of the
then-available data from the ERSPC study was subsequently shown as erroneous.
In its 2012 update, the ERSPC data demonstrated a 21% survival advantage to
PSA screening for all patients, and furthermore, for those with the longest
follow-up (over 10 years) this increased to 38%. As such, the screening
efficiency of PSA testing in this study is similar to that reported for breast
or colo-rectal cancer; CMS is not proposing elimination of screening for
these diseases. II. CMS Must Consider the Impact of the USPSTF Recommendation
on Trends in Prostate Cancer Diagnosis Before any further policy change is
suggested in PSA testing in the United States, particularly one that proposes
to encourage physicians and EPs with remunerative gain who do not order PSA
tests in any men, it is appropriate to regard the changes that have already
occurred in the prostate cancer field since the controversy surrounding the
USPSTF Grade D recommendation against PSA testing began in 2011, culminating
in its publication in 2012. In a relatively short period of time, we have
already seen a number of studies reflecting a significant and concerning
change not only in the number of prostate cancers diagnosed, but also the
stage and grade of newly diagnosed patients. Even if a causal link has yet to
be definitively established, it is clear that a temporally related effect of
the USPSTF Grade D recommendation has been associated with a decrease in the
incidence of prostate cancer screening in the US. Originally these studies
emanated from individual hospitals or health care systems; they clearly
indicated significant reductions in PSA testing, referrals for elevated PSA,
performance of prostate biopsies and lower detection rates of prostate cancer.
, , More recent studies have reflected similar changes nationally. One study
based on the National Health Interview Survey (NHIS) showed significant
declines in PSA based screening in men over age 50: the decline was from 33.2%
to 24.8% in men ages 50- 59 and from 51.2% to 43.6% in men ages 60 -74. A
review of the National Cancer Database (NCBD) and revealed a national decrease
of 28% in incident diagnoses of prostate cancer in the single year after the
USPSTF draft recommendation. Similarly, a review of SEER data was recently
shown to show a precipitous decrease in prostate cancer detection in men over
50, from 213,562 men in 2011 to 180,043 men in 2012: a drop of 33,519 cancers
detected in a single year! A recent review, again examining the NHIS,
studying responses from >20,000 men before and after the USPSTF decision,
found that the largest declines in men reporting PSA screening occurred
between 2010 and 2013 and the declines were greatest in men between the ages
of 50-54 (from 23% to 18%) and men ages 60-64 (from 45% to 35%). These
declines were greater than observed in the elderly population - exactly the
population with the most potential for benefit. In addition to the incidence
of PSA screening and actual detection of prostate cancer falling after the
USPSTF publication, there is also mounting evidence that the cancers being
found are of higher risk. An analysis of National Oncology Data Alliance
records of men with newly diagnosed prostate cancers in the US, reported that
the number of men whose PSA levels were > 10 at diagnosis gradually dropped
between 2005-2010; however, the number of men whose PSA levels were > 10 at
the time of diagnosis rose 3% annually between 2011-2013, suggesting that
cancers were being detected later. Further, in another single institutional
study, there was reported a 31% reduction in prostate biopsies two and a half
years after the USPSTF recommendation. These authors also reported a
statistically higher PSA level at diagnosis, as well as significantly higher
clinical stages detected, along with higher D’Amico risk scores at the time of
diagnosis. These findings caused the authors to conclude that the reduction of
prostate biopsies occurred concomitantly with a decrease in the detection of
potentially curable prostate cancer and to suggest that repeat efforts at
screening might be needed to prevent the reversal of decades of improvement in
the prostate cancer mortality rate. Most recently, a review of over 10,000
patients compared positive biopsy rates, Gleason score and number of positive
cores prior and subsequent to the USPSTF recommendation against PSA screening.
Compared to the two years prior to the USPSTF final recommendation: 1)
positive biopsy rates increased from 39 to 46 percent; 2) in newly diagnosed
cancers, the percent of Gleason 8-10 cancers rose from 14.8 to over 25%; and
3) there was a 4.5% increase in positive cores/patient. The authors suggested
that these changes could portend a loss of advantages previously realized in
prostate cancer mortality since PSA screening became a common clinical
practice III. The USPSTF is in the Process of Reviewing the Issue of Prostate
Screening Despite the objections of those most intimately involved in prostate
cancer diagnosis and treatment, the USPSTF opted to finalize its grade “D”
recommendation on prostate cancer screening. This decision (among others),
and the relative lack of transparency associated with the USPSTF process, has
prompted legislators to act in a bipartisan, bicameral manner to propose
changes in the manner in which the USPSTF conducts its reviews. The USPSTF
Transparency and Accountability Act of 2015, introduced by Reps. Marsha
Blackburn (R-TN-7) and Bobby Rush (D-IL-1) is the vehicle to reform the USPSTF
process. This legislation aims to reform the process by which the U.S.
Preventive Services Task Force (USPSTF) reviews and develops recommendations
for clinical preventive services; a process that is currently exempt from
transparency provisions such as the Federal Advisory Committee Act (FACA) and
the Administrative Procedures Act (APA). The bill includes a critically
important mandate to ensure that a “balanced representation of primary and
specialty care providers” and other key stakeholders in the healthcare
community are involved in development and review of USPSTF recommendations.
Other changes include publishing a draft research plan to guide the systematic
evidence review process; considering findings and research by federal agencies
and departments; and making the evidence review available for public comment.
Whether in response to potential legislative reforms or due to a recognition
that its original one-size-fits-all recommendation disadvantaged patients at
higher risk for developing prostate cancer, the USPSTF is planning to update
their 2012 decision and has already issued a “Draft Research Plan for Prostate
Cancer: Screening” with opportunities for comment by interested parties by
November 26, 2015.These new guidelines might be available as soon as 2017.
IV. Summary Given the aforementioned detrimental trends that have already
occurred since the USPSTF decision, LUGPA is deeply concerned that we now will
compound these changes by promising a financial benefit to doctors and other
EPs who decide against PSA testing. LUGPA believes is it time to review and
revise the potential harm caused by recommending against prostate cancer
screening in its entirety; of note, given the natural history of prostate
cancer diagnosis to death, whether initially localized or metastatic upon
presentation, it is imperative that we utilize the most current literature
available to make policy decisions to avoid escalating prostate cancer as the
2nd leading cause of male US cancer mortality. LUGPA is committed to
contemporaneous review of the current literature and evidenced based medicine
evidence regarding screening, diagnosis, and management of this disease. As
such, we are concerned that the literature cited by CMS simply does not
reflect the current state of knowledge regarding either prostate cancer
screening processes or the potential impact of the USPSTF recommendations on
stage and grade migration. A brief review of the framing document produced by
this entity reveals a lack of familiarity and depth in preparing for this
task, with not a single reference cited beyond 2013. On behalf of LUGPA, we
would like to thank you for providing us with this opportunity to comment on
the performance measure. Please feel free to contact Dr. Kapoor at (516)
342-8170 or dkapoor@impplc.com if you have any questions or if LUGPA can
provide additional information to assist CMS as it considers this issue.
Respectfully submitted, Deepak A. Kapoor, M.D. Carl A Olsson, MD Chairman,
Health Policy LUGPA Clinical Associate Professor of Urology The Icahn School
of Medicine at Mount Sinai Chief Medical Officer Integrated Medical
Professionals, PLLC Director of Quality Initiatives and Strategy, Department
of Urology The Icahn School of Medicine at Mount Sinai 1. Centers for Medicare
and Medicaid Services, Medicare Provider Utilization and Payment Data:
Physician and Other Supplier, available at:
https://www.cms.gov/Research-Statistics-Data-and-Systems/Statistics-Trends-and-Reports/Medicare-Provider-Charge-Data/Physician-and-Other-Supplier.html.
2. Andriole GL, Crawford ED, Grubb RL 3rd, et al. Mortality results from a
randomized prostate-cancer screening trial. N Engl J Med. 2009;360:1310-9 3.
Schröder FH, Hugosson J, Roobol MJ, et al. Screening and prostate-cancer
mortality in a randomized European study. N Engl J Med. 2009;360:1320-8. 4.
Hugosson J, Carlsson S, Aus G, et al. Mortality results from the Göteborg
randomised population-based prostate-cancer screening trial. Lancet Oncol.
2010;11:725-32 5. Schröder FH. Stratifying Risk — The U.S. Preventive
Services Task Force and Prostate-Cancer Screening. N Engl J Med. 2011; doi
10.1056/NEJMp1112140, published October 26, 2011. 6.Crawford, ED, Grubb III,
R, Black, A, et al. Co-morbidity and Mortality Results From a Randomized
Prostate Cancer Screening Trial. J Clin Onc 2011; 29(4): 355-361 7. Schröder
FH, Hugosson J, Roobol MJ et al. Prostate-cancer mortality at 11 years of
follow-up. N Engl J Med 2012; 366:981-990). 8. Greene R, Tausch T, Deo
Perez D et al. An Examination of PSA Utilization and Referral Patterns in a
Large Integrated Health Care System Following the US Preventative Services
Task Force Recommendations. J Urol 2013; 189(4S): e513 9. Aslani A, Minnillo
BJ, Johnson B, et al. The Impact of Recent Screening Recommendations on
Prostate Cancer Screening in a Large Health Care System. J Urol 2013;
191(6):1737 10. Bhindi B, Mamdani M, Kulkarni GS, et al.Impact of the U.S.
Preventive Services Task Force Recommendations against Prostate Specific
Antigen Screening on Prostate Biopsy and Cancer Detection Rates. J Urol 2015;
193: 1519 11. Drazer M, Huo D, Eggene, S. National prostate cancer screening
rates after the 2012 US Preventive Services Task Force recommendations
discouraging prostate-cancer-specific antigen-based screening. J Clin Oncol.
2015; 33: 2416 12 Barocas DA, Mallin K, Graves AJ et al. The effect of the U.
S. Preventive Services Task Force grade D recommendation against screening for
prostate cancer on incident prostate cancer diagnoses in the United States. J
Urol. 2015; 194: 1587 13. Jemal A, Fedewa SA, Ma J, et al. Prostate Cancer
Incidence and PSA Testing Patterns in Relation to USPSTF Screening
Recommendations. JAMA. 2015 Nov 7;314(19):2054-2061. 14. Sammon JD, Abdollah
F, Choueiri TK, et al. Prostate-Specific Antigen Screening After 2012 US
Preventive Services Task Force Recommendations. JAMA. 2015 Nov
17;314(19):2077-2079. 15. Hall MD, Schultheiss TE, Farino G, et al.: Increase
in higher risk prostate cancer cases following new screening recommendation by
the US Preventive Services Task Force (USPSTF). J Clin Oncol 33, 2015 (suppl
7; abstr 143) 16. Banerji JS, Wolff EM, Massman JD III et al: Prostate needle
biopsy outcomes in the era of the U.S. Preventive Services Task Force
recommendations against PSA based screening. J Urol 2015. 17. Olsson CA,
Anderson A, Kapoor DA. Persistent Adverse Trends in Histology of Newly
Diagnosed Prostate Cancer Subsequent to USPSTF PSA Screening Recommendation.
Society of Urologic Oncology Annual Meeting, Washington DC – 12/2015. 18.
Draft Research Plan for Prostate Cancer: Screening. Accessed at:
http://www.uspreventiveservicestaskforce.org/Page/Document/draft-research-plan/prostate-cancer-screening
(Submitted by: LUGPA)
- (Early public comment)I am very concerned about using PSA testing
as a measure of poor quality. My 57 year old accountant has incurable
prostate cancer because his primary care provider was an early adopter of this
foolishness. As a urologist in a muiltispecialty physician group, this is
just the most personal example of patients that my partners and I see on a
regular basis. When I finished residency in 1992, >40,000 men DIED of
prostate cancer per year in the US. Today is it <20,000. The difference?
PSA testing to catch the disease in it's early stages. Shared decision making
between the patient and his physician can only be effective with adeqate data.
PSA (and digital rectal exam) are at this time the best we have to deal with
this common cancer in men. Since prostate cancer is more prevalent in African
American men, this measure could be interpreted as racist as well (Submitted
by: Olympic Medical Physicians)
- (Early public comment)December 1, 2015 Comments for proposed
Clinical Quality Measure: MUC ID – “MUC15-1019” Measure Title -
“Non-Recommended PSA-Based Screening” Description – “Percentage of men who
were screened unnecessarily for prostate cancer using a prostate-specific
antigen (PSA)-based screening.” Measure Type – “Process” Measure Steward –
“Centers for Medicare & Medicaid Services” CMS Program – “MIPS”
Submitted by: Men’s Health Network Men's Health Network (MHN) is a national
non-profit organization whose mission is to reach men, boys, and their
families where they live, work, play, and pray with health awareness and
disease prevention messages and tools, screening programs, educational
materials, advocacy opportunities, and patient navigation. MHN appreciates the
opportunity to provide comments on the draft clinical quality measure
developed by the National Quality Forum regarding “Non-Recommended PSA-Based
Screening.” We have serious concerns about this proposed measure and the
impact it would have on men who would benefit from early detection of prostate
cancer. We thank you for considering the comments outlined below. We
understand that the development of this clinical quality measure is based in
large part on the “D” recommendation given to PSA screening by the United
States Preventive Services Task Force (USPSTF) in 2012. This recommendation
has been very controversial and is not supported by the majority of
professional associations and prostate cancer advocacy organizations. Also,
notably, prostate cancer screening is currently under review again by the
USPSTF, making CMS consideration of this clinical quality measure seemingly
premature.
http://www.uspreventiveservicestaskforce.org/Page/Document/draft-research-plan/prostate-cancer-screening1
The use of the PSA as an early indicator that the individual’s prostate may
have or be developing abnormal conditions is too often mischaracterized as a
cancer test. It is not, but is useful in detecting non-symptomatic prostate
cancer, as well as other abnormalities in the prostate. The PSA is also
useful in tracking the progress of prostate cancer, or lack of progress, once
detected. The medical community understands these limitations, and does not
use the PSA as a stand-alone cancer test, instead using it as an indication of
prostate health, and in combination with other tests to determine if prostate
cancer might be present. The risk of “harms” associated with the test are
minimal, and no different from any other blood draw, procedures that are used
to determine cholesterol and glucose levels daily in every medical setting
across the country. This is a simple test that has helped diagnose thousands
of men who had potentially life-threatening prostate cancer, but had no idea
they might be at risk. It has also helped discover many more prostate cancers
that would never be life threatening, and that might never be treated, but,
instead, may be carefully monitored to ensure that the cancer does not
progress. The decision to treat prostate cancer, once identified – or to
engage in either active monitoring (active surveillance) or passive monitoring
(watchful waiting) – is a decision to be made by a man in consultation with
his physician and his family. This process is entirely separate from the
screening decision. Leading organizations including the American Urological
Association, the American Cancer Society, and the National Comprehensive
Cancer Network have each issued their own, more nuanced, guidance recommending
discussions between patients and providers on PSA and other screening tools in
the early detection of prostate cancer. New technologies are now being used
in conjunction with PSA testing to help determine the likelihood of aggressive
prostate cancer and guide treatment decisions, and while PSA may eventually be
replaced by more precise screening tools, it is currently an essential option
for patients and providers in the early diagnosis of clinically significant
prostate cancer. The effect of this quality measure would be to discourage
the important conversation between a health care provider and the patient to
determine if the patient might benefit from prostate cancer screening, a
screening which may include a PSA. This would discourage discussions with men
who know they might be at high risk for prostate cancer because of race,
ethnicity, family history, age, or exposure to certain carcinogens such as
Agent Orange and the dust and debris from the World Trade Center disaster. It
would also discourage similar talks with men who do not know their family
medical history. Failure to have those discussions will mean many of these men
are diagnosed with later stage prostate cancer, condemning them to painful,
perhaps life-threatening, experiences in their fight for survival. We agree
with one physician who states that the quality measure is misdirected and that
the treatment (and decision to treat or not) should be the quality metric,
rewarding appropriate care, and not rewarding inappropriate care: “Instead of
using PSA screening (or lack thereof) as a quality metric, how about using
treatment as a quality metric? Why not use the EHR to see who is treating
low-risk prostate cancer inappropriately? Or use the EHR to see who is
ordering inappropriate CT scans or bone scans? Let’s monetize appropriate
care, not monetize the wholesale disruption of PSA screening.” Benjamin
Davies MD, Urologic Oncologist and Associate Professor of Urology at the
University of Pittsburgh. Chief of Urology at UPMC Shadyside Hospital and
Director of the Urologic Oncology Fellowship at the University of Pittsburgh.
www.forbes.com/sites/benjamindavies/2015/11/15/the-governments-war-against-mens-health-its-about-to-get-worse
Thank you for your thoughtful consideration of these comments. (Submitted by:
Men's Health Network)
- (Early public comment)The AMA recognizes that this measure has been
created in response to the USPSTF recommendations against PSA screening
regardless of age. This recommendation conflicts with the current
recommendations released by the American Urological Association in 2013, which
emphasizes that an individual’s values and preferences must be taken into
account and for this reason the recommendation focuses on shared
decision-making between the physician and patient. We are concerned that this
measure as currently specified could negatively impact the physician-patient
relationship and should not be recommended until the concept of shared
decision-making and the discrepancy between the guidelines are addressed. In
addition, USPSTF is in the process of reviewing the literature again with a
possible update to the recommendations. Therefore, given the timeline for
updates, we believe it is premature to move forward with a measure based on
the USPTSF recommendations. (Submitted by: American Medical
Association)
- (Early public comment)The American Association of Clinical
Urologists (AACU), a professional association representing thousands of
urologists from across the country, appreciates the opportunity to comment on
the Centers for Medicare & Medicaid Services’ (CMS) quality measure under
development entitled, “Non-Recommended PSA-Based Screening.” The AACU opposes
the adoption of this proposed quality measure. The AACU opposes any attempt to
use the ordering of a prostate-specific antigen (PSA) test as a negative
quality measure. Multiple experts in the diagnosis and treatment of prostate
cancer who have researched PSA-based testing have found PSA-based testing to
be an effective diagnostic tool. The AACU and its urologist members, in
addition to other leading societies, have emphasized the importance of an
individualized decision on PSA-based testing between the patient and the
physician. Physicians should not be penalized for ordering a test that, while
not perfect, has long been recognized as an important tool in the diagnosis of
prostate cancer. The AACU has strong concerns over the impact the adoption of
this proposed quality measure would have on the early diagnosis and evaluation
of patients with prostate cancer. Accordingly, the AACU opposes any use or
adoption of the proposed quality measure entitled, “Non-Recommended PSA-Based
Screening.” The AACU appreciates the opportunity to comment and is available
for questions. Jeffrey M. Frankel, MD Health Policy Chair, American
Association of Clinical Urologists (Submitted by: American Association of
Clinical Urologists)
- (Early public comment)The American Urological Association (AUA) is
highly concerned about measure MUC 15-1019 (non-recommended PSA-based
screening) and its potential to negatively impact patient care. Despite
differences of opinion about the role of PSA-screening for prostate cancer,
discussion about the risks and benefits of PSA screening in targeted
populations is advocated by many leading societies, including the American
College of Physicians, the American Society of Clinical Oncology, the American
Cancer Society, the National Comprehensive Cancer Network and the AUA. In
contrast, the measure as proposed will incentivize providers to disregard
patient and clinician discussion about PSA screening, thereby obviating the
patient’s right to information about risks and benefits, and thus, completely
preventing any attempt at shared decision making. Additionally, the measure
addresses the shortcomings of routine PSA screening without consideration of
age/comorbidities, individualized risk for prostate cancer and patient
preferences. The proposed measure does not provide exclusions for men at high
risk, including African Americans and those with a family history of prostate
cancer. This high risk group is a critical patient population which many
medical societies, including the AUA, specifically state should be considered
distinct from the broader population. Furthermore, this measure is a process
measure with no link to outcomes. It is based on the current recommendation
of the United States Preventive Services Task Force (USPSTF) and a HEDIS
measure that only focuses on PSA-based screening in men 70 years and older.
The USPSTF is now in the process of updating this specific recommendation
(currently in the phase of public comment about research methodology).
Therefore, the AUA urges that this measure not be considered for inclusion in
the Merit-Based Incentive Payment System (MIPS) or Physician Compare until the
task force has reviewed the literature, analyzed the evidence, and completed
its update process. The stratification by age is an important component of
the AUA’s guideline recommendations. After the 2013 release of its guideline
on early detection of prostate cancer, the AUA has been engaged in ongoing
efforts to optimize the use of PSA testing, relying heavily on the guideline
recommendations which are stratified by age and further educating members on
the importance of shared decision making through publication of a white paper
(2015) and implementation of a quality improvement summit (to be convened in
2016) to assist members in the use of decision aids, communicating with
patients/families, and clarifying values of importance to the patient.
Ultimately, this measure, as currently drafted, would be detrimental to
patient care, and the AUA strongly recommends that the MAP reject this measure
based on the issues outlined above. Penalizing providers for PSA testing will
significantly restrict the opportunity for shared decision making and patient
involvement in their own care. Thank you for the opportunity to provide
input. (Submitted by: American Urological Association)
- (Early public comment)As a practicing oncologist, I am seeing more
and more high risk and metastatic prostate cancer since the UPSTF
recommendation against PSA screening. Further reducing PSA screening will
lead to more advanced disease diagnosed in men, more aggressive therapy
(including toxic chemotherapy), more morbidity from treatment of the more
adcanced disease, more harm from metastatic and locally advanced disease and
more deaths from prostate cancer. PSA screening is crucial to saving patients
from these outcomes and further limiting this is an attack on the health and
well being of men along with their ability to manage their own health in an
informed manner. (Submitted by: Rainier Cancer Center)
- (Early public comment)The U.S. Centers for Medicare and Medicaid
Services ("CMS") is proposing an outrageous measure that will set back men’s
health and cause great harm, including unnecessary death. The proposed
measure, which discourages screening for prostate cancer, should get the
attention and action of all men, particularly Black men. Prostate cancer
diagnoses, aggressive cases, and deaths are extraordinarily high among Black
men, twice that of their White counterparts. The prostate cancer incidence
rate for White men is 130 cases per 100,000 vs. 215 cases per 100,000 for
Black men and twice the mortality rate of 19 vs. 46 per 100,000. Nonetheless,
the proposed “Non-Recommended PSA-Based Screening” measure discourages PSA
(prostate-specific antigen) screenings in all men, regardless of age or risk
factors. The proposed measure is based upon insufficient data and flawed,
unreliable methodology of the U.S. Preventive Services Task Force. The Task
Force, stunningly, dismisses a whole population of men who are
disproportionately burdened with prostate cancer. The Task Force maintains,
the harm from screening outweighs the benefits of screening. The Task Force
reports that: “Although prostate cancer is very common, in many cases, the
cancer does not grow or cause symptoms. If it does grow, it often grows so
slowly that it isn’t likely to cause health problems during a man’s lifetime.
The PSA screening test often suggests that prostate cancer may be present when
there is no cancer, a false positive. False-positive results cause worry and
anxiety and can lead to follow-up tests that aren’t needed. These tests can
cause harms such as fever, infection, bleeding, urinary problems, and pain. A
small number of men will need to go to the hospital because of these
complications.” Surely, the men and families of the 250,000+ men who are
diagnosed each year and the 27,000+ men who died last year from prostate
cancer, beg to differ. What of the high risk population? The proposed
measure would also potentially be used in all of Medicare's reporting programs
and would financially penalize providers who order a prostate cancer screening
test (PSA) for a patient whether he is high risk or not. As expressed by Dr.
James Bennett, the highly-regarded Atlanta, Georgia based urologist and
surgeon, this potential change in Medicare coverage is akin to the Tuskegee
Experiment and must be vehemently opposed. Says Dr. Bennett: “As a practice
that primarily deals with African American patients, we know based upon our
years of detecting prostate cancer early for thousands of patents through PSA
screenings that this measure will set back early detection of prostate cancer
of this high risk group 30 to 40 years. It is disturbing that this ruling
restricts PSA screenings, but has not given us an alternative measure to
address the high incidence and mortality rate of African American men or men
who have a significant family history of prostate cancer.” It is apparent
that the CMS and the U.S. Preventive Services Task Force are not familiar with
the pre-PSA era when prostate cancer was discovered in African American men in
advanced and incurable stages. The proposed measure doesn’t take any of these
medical facts and data into account. Could it be because the U.S. Preventive
Services Task Force doesn’t even include an oncologist or urologist on its
16-member task force? The proposed measure also contradicts the practice
guidance of the American Urological Association, the National Comprehensive
Cancer Network, the American Society of Clinical Oncology, the American
College of Physicians-American Society of Internal Medicine and the American
Cancer Society. This is clearly and simply a matter of life and death for a
whole population of men. What CMS is proposing is not only unconscionable and
summarily dismissive, but immoral and deadly. The PSA has worked for decades,
and has enabled physicians to save the lives of many men by detecting prostate
cancer early and before the cancer metastasizes. Every man who needs a PSA
screening must be able to get it. The Prostate Cancer Advisory Council based
in Atlanta, Georgia, is an advocacy group composed of Black and White men
dedicated to helping bring about more awareness to all issues around prostate
cancer and educate all men about the importance of regular medical check-ups
and PSA screenings. We call upon the CMS to 1) reject the flawed
recommendation of the Task Force and 2) to reconstitute the Task Force so that
it includes oncologists and urologists who are devoted to the care,
prevention, and treatment of prostate cancer. Prostate Cancer Advisory Council
- Atlanta Our members include: Dr. James Bennett, Ambassador Andrew Young,
Dr. Walter Young, Erroll Davis, John Guillory, Attorney Hank Fellows, Harold
Lewis, among others. (Submitted by: Midtown Urology)
- (Early public comment)At least one NRHI member has concerns with
this measure. There is concern that this measure has not tested well in the
field, and that it could potentially discourage clinicians from conducting
necessary screenings. (Submitted by: Network for Regional Healthcare
Improvement)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)As a prostate cancer survivor, spokesperson
for the Know Your Stats® About Prostate Cancer campaign and Pro Football Hall
of Fame member, I am writing to express my strongest concern about measure MUC
15-1019 (non-recommended PSA-based screening) and its potential to negatively
impact patient care. The Know Your Stats® campaign, a partnership between the
Urology Care Foundation and the National Football League (NFL), is a rallying
force to connect, educate and inspire men across the country to know their
prostate cancer risk and to talk to their doctor about whether prostate cancer
testing is right for them. For nearly 10 years, our mission has been to
increase the cure rate of prostate cancer by educating men, particularly those
at high risk for the disease, about the importance of early detection to
prostate cancer outcomes and the latest in prostate cancer screening.
Ultimately, this measure, as currently drafted, would be detrimental to
patient care. Prostate cancer is the most common cancer among men, and the
second-leading cause of cancer death in men. Key prostate cancer risks
include race and family history. African American men are twice as likely to
develop the disease as Caucasian men and one in three men with a family
history of prostate cancer will be diagnosed with the disease. Because of
these and other factors, the decision to have a PSA test should be between the
patient and their physician and include a discussion about the patient’s risk
factors and the benefits and harms associated with testing as well as
subsequent tests (e.g., biopsy). Shared decision-making is critical – and the
decision to get tested isn’t one to be made outside the context of a detailed
conversation with a physician. I can tell you that if the decision to have a
PSA test was not available to me when I met with my doctor several years ago,
I may not be writing this letter to you today nor working on a daily basis to
educate men about their prostate health, and potentially saving lives. My
journey with prostate cancer started in Canton, Ohio at the Pro-football Hall
of Fame. The American Urological Association’s official Foundation, the
Urology Care Foundation, had teamed up with the NFL to offer prostate cancer
screenings to retired players. After having a discussion with my doctor about
my prostate cancer risks, I participated in their very first screening. Based
on the results from my screening and a rise in my PSA, my doctor and I decided
on a biopsy. Twelve core samples were taken as part of the biopsy – six on
each side of the urethra. To my surprise, cancer was found in nine of the
twelve places. My life was saved by a simple prostate exam. I am living proof
of the power knowing your risk and talking to your doctor! As drafted, the
measure on PSA screening disregards shared decision making, consideration of
age/comorbidities, individualized risk for prostate cancer and patient
preferences. I am afraid this would prevent much-needed discussions between
physicians and patients about prostate cancer and could result in tests not
being ordered even if a man wants to be screened. The proposed measure does
not provide exclusions for men at high risk, including African Americans and
those with a family history of prostate cancer. This high risk group is a
critical patient population which many medical societies, including the
American Urological Association, specifically state should be considered
distinct from the broader population. Despite substantial disagreement
about the role of PSA-screening for prostate cancer, discussion about the
risks and benefits of PSA screening in targeted populations is advocated by
many leading societies, including the American Urological Association,
American College of Physicians, the American Society of Clinical Oncology, the
American Cancer Society, and the National Comprehensive Cancer Network. In
contrast, the measure as proposed will incentivize providers to disregard
patient and clinician discussion about PSA screening, thereby obviating the
patient’s right to information about risks and benefits, and thus, completely
preventing any attempt at shared decision making. I also note that this
measure is based on the current recommendation of the United States Preventive
Services Task Force (USPSTF) that only focuses on PSA-based screening in men
70 years and older. The USPSTF is now in the process of updating this
specific recommendation (currently in the phase of public comment about
research methodology). Therefore, I urge that this measure be withdrawn until
the task force has reviewed the literature, analyzed the evidence, and
completed its update process. The stakes are just too high for us not to be
talking about prostate cancer. Don’t sit on the sidelines, I urge the National
Quality Forum to withdraw this measure rather than finalize a measure that may
restrict the opportunity for shared decision making and patient input.
Thank you for the opportunity to provide feedback. (Submitted by: Know Your
Stats® About Prostate Cancer )
(Program:
Hospital Inpatient Quality Reporting and EHR Incentive Program; MUC ID:
MUC15-1033) |
- CAPC supports the MAP’s recommendation “Do not support” for the inclusion
of MUC15-1033 in the Hospital Inpatient Quality Reporting program (HIQR).
Schwarze et al. (2014) noted that the use of 30-day mortality measures can
inhibit the use of palliative services and fail to accommodate the wishes of
patients who would prefer death over prolonged life-sustaining treatment. As
proposed, this measure does not provide for consideration of a patient’s goals
of care – including the decision to withdraw life-sustaining treatment – in
setting of severe stroke. Inclusion of this measure in the HIQR could create
perverse incentives to keep patients alive despite their wishes; it is easy to
keep someone alive on a percutaneous endoscopic gastronomy tube for a long
period of time following acute stroke. This measure could also potentially
inhibit palliative care referral, as some providers may fear the consequences
of patients choosing to pursue comfort-related goals. We appreciate the MAP’s
position on this measure, and reiterate the MAP’s suggestion to consider
cognitive or functional outcomes such as impaired capacity. (Submitted by:
Center to Advance Palliative Care)
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by:
Premier)
- AAHPM agrees with the MAP’s recommendation to NOT support this measure. We
agree that mortality is not the only (or most) important measure for
post-stroke care. We also agree with the MAP’s suggestion to consider
cognitive or functional outcomes such as impaired capacity. (Submitted by:
American Academy of Hospice and Palliative Medicine)
- AAHPM agrees with the MAP’s recommendation to NOT support this measure. We
agree that mortality is not the only (or most) important measure for
post-stroke care. We also agree with the MAP’s suggestion to consider
cognitive or functional outcomes such as impaired capacity. The use of
30-day mortality measures can inhibit the use of palliative services and fail
to accommodate the wishes of patients who would prefer death over prolonged
life-sustaining treatment. As such, inclusion of this measure in the Hospital
IQR could create perverse incentives to keep patients alive despite their
wishes. This measure could also potentially inhibit palliative care referral,
as some providers may fear the consequences of patients choosing to pursue
comfort-related goals. This measure needs to better consider a patient’s
goals of care—including the decision to withdraw life-sustaining treatment.
If this measure is ever adopted, we believe that at the very least, there
should be an exclusion for both hospice patients and those who opt to receive
primarily palliative care. It is equally important to include "discharged to
hospice" as part of the exclusion criteria as it is to include “admitted from
hospice.” Hospitals should not be penalized for the mortality of patients
discharged to hospice or this will set up a disincentive to discharge patients
from hospital to hospice. (Submitted by: American Academy of Hospice and
Palliative Medicine)
- GNYHA supports the MAP’s decision and does not support this measure for
adoption in the Hospital Inpatient Quality Reporting Program. While GNYHA
supports a patient safety focus on improved management and outcome for acute
ischemic stroke, mortality is not the most meaningful stroke-related outcome
to track. Furthermore, currently certified electronic health records (EHR)
still do not reliably capture and calculate electronic measures. The data
points required to calculate this and other electronic clinical quality
measures are not currently readily and consistently available within the EHR.
Lastly, many hospitals have disparate systems, and use different outpatient
and inpatient systems. Reporting on this would potentially require pulling
from different source EHRs. Additionally, GNYHA agrees with MAP’s rationale
that more testing on this measure is needed before it is considered for
adoption. (Submitted by: Greater New York Hospital Association)
- We tentatively support this as a future measure as the electronic format
is premature at this time. We recommend deferring this metric until hospitals
have successfully demonstrated their ability to submit accurate eMeasures
throught he IQR program. (Submitted by: Baylor Scott & White
Health)
- The American Heart Association (AHA) and its division, the American Stroke
Association (ASA), appreciate the opportunity to submit comments on the MAP
preliminary recommendations. We applaud the MAP and the NQF on their
meticulous work in evaluating the measures under consideration. The AHA/ASA
believes that all three of the revised or new hybrid stroke mortality
measures, including this hybrid measure, represent a significant improvement
over the CMS claims-based risk model that is currently in use. The addition
of the National Institutes of Health Stroke Score (NIHSS) as a measure of
initial stroke severity should greatly enhance CMS’ ability to accurately
classify hospital performance and to limit the risk of unintended adverse
effects on patient care. The NIHSS is well-validated, highly reliable, and an
extremely strong predictor of both mortality and short- and long-term
functional outcomes. It is recommended in national guidelines and widely used
in clinical practice. While we understand the MAP’s concerns regarding the
performance of this version of the measure, as compared to the claims-based
only measure and the EHR plus claims-based measure, we would strongly
encourage CMS to continue to refine this version to provide an alternative
that allows the use of clinical data for risk adjustment, but may lower the
burden of data collection for hospitals. (Submitted by: American Heart
Association)
- (Early public comment)We support adjusting the measure for stroke
severity; however, it is not clear if the revised measure has been endorsed.
Additionally, we are unsure if the stroke severity scale can be captured
consistently across EHR products. CEHRT requirements will need to incorporate
the elements of this measure prior to implementation. (Submitted by:
Premier)
- (Early public comment)As with all mortality measures, Intermountain
has found the "all cause" mortality difficult to do performance improvement
on. Specifically, our providers would prefer a mortality related to the
initial disease process. (Submitted by: Intermountain
Healthcare)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program: Ambulatory Surgical
Center Quality Reporting Program; MUC ID: MUC15-1047) |
- The American Academy of Ophthalmology, the American Society of Cataract
and Refractive Surgery, the Outpatient Ophthalmic Surgery Society, and the
Society for Excellence in Eyecare strongly support adoption by CMS for the ASC
Quality Reporting Program of MUC15-1047, Toxic Anterior Segment Syndrome
(TASS) Outcomes. TASS, an acute and serious inflammation of the anterior
chamber, or segment, of the eye following cataract surgery, is directly
related to extraocular substances that inadvertently enter the eye during
surgery. The number of anterior segment surgeries performed in ASCs is
significant, numbering in the millions each year, and is expected to grow as
the population ages. Incidence of TASS is measurable, attributable to the ASC,
and prevention is actionable by the facility. There are published guidelines
regarding cleaning and sterilizing of intraocular surgical instruments to help
improve quality and prevent TASS. This measure would promote collaboration
between the surgeon and the facility, as the surgeon would report back to the
facility any incidence of TASS, as is already done by surgeons. Further,
measuring the incidence may aid in better tracking and understanding the
prevalence of TASS, as the Food and Drug Administration contends that TASS is
significantly underreported and surveillance is underway. There are specific
prevention guidelines that have been developed, and this measure would help
ensure that they are being appropriately followed. The measure is a fully
developed and piloted-tested facility-level measure. Reliability and validity
testing have been conducted and the results have been shared with CMS.
(Submitted by: American Academy of Ophthalmology, American Society of Cataract
and Refractive Surgery, Outpatient Ophthalmic Surgery Society, Society for
Excellence in Eyecare)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- The ASC Quality Collaboration developed the “Toxic Anterior Segment
Syndrome” or “TASS” outcome measure to fill MAP-identified ASCQR Program
measure gaps in complications and surgical care quality. The number of
anterior segment surgeries performed in ASCs is enormous, numbering in the
millions each year, with that number expected to grow as the population ages.
Studies in the literature have reported TASS complication rates of 1.8 to
2.1%, pointing to a significant opportunity for improvement. Eye
professionals agree that major efforts should be focused on the prevention of
TASS. The ASCRS and ASORN have published recommended practices for cleaning
and sterilizing intraocular surgical instruments aimed at the prevention of
TASS. These recommended practices were developed with guidance from AORN,
APIC, SHEA, CDC and the FDA. In addition, ASCRS, AAO and OOSS recently
released recommendations regarding the use of enzyme detergent for cleaning
intraocular surgical instruments. Inclusion of the TASS measure in the ASCQR
Program will help promote adherence to these recommended practices. The
measure is a fully developed and piloted-tested facility-level measure.
Reliability and validity testing have been conducted and results have been
shared with CMS. We note that the NQF’s Eye Care and Ear, Nose, and Throat
Conditions Project closed on March 27, 2015 - prior to our completion of
measure testing. (Submitted by: ASC Quality Collaboration)
- (Early public comment)The American Society of Cataract and
Refractive Surgery, the Outpatient Ophthalmic Surgery Society, and the Society
for Excellence in Eyecare strongly support adoption by CMS for the ASC Quality
Reporting Program of MUC15-1047, Toxic Anterior Segment Syndrome (TASS)
Outcomes. TASS, an acute and serious inflammation of the anterior chamber, or
segment, of the eye following cataract surgery, is directly related to
extraocular substances that inadvertently enter the eye during surgery.
Incidence of TASS is measurable, attributable to the ASC, and prevention is
actionable by the facility. There are published guidelines regarding cleaning
and sterilizing of intraocular surgical instruments to help improve quality
and prevent TASS. This measure would promote collaboration between the surgeon
and the facility, as the surgeon would report back to the facility any
incidence of TASS, as is already done by surgeons. Further, measuring the
incidence may aid in better tracking and understanding the prevalence of TASS,
as the Food and Drug Administration contends that TASS is significantly
underreported and surveillance is underway. There are specific prevention
guidelines that have been developed, and this measure would help ensure that
they are being appropriately followed. The ASC Quality Collaboration has
conducted reliability testing. (Submitted by: Outpatient Ophthalmic Surgery
Society, American Society of Cataract and Refractive Surgery, Society for
Excellence in Eyesore)
- (Early public comment)The ASC measure as it requires follow up
withing 24-48 hours. Intermountain is unclear about how this information can
be collected as it is not specific and looks to be on the ASC getting
diagnostics from the physician which would be very difficult (Submitted by:
Intermountain Healthcare)
- (Early public comment)The American Academy of Ophthalmology
encourages MAP to support the adoption by CMS for the ASC Quality Reporting
Program of MUC15-1047, Toxic Anterior Segment Syndrome (TASS) Outcomes. TASS,
an acute and serious inflammation of the anterior chamber, or segment, of the
eye following cataract surgery, is directly related to extraocular substances
that inadvertently enter the eye during surgery. Incidence of TASS is
measurable, attributable to the ASC, and prevention is actionable by the
facility. There are published guidelines regarding cleaning and sterilizing of
intraocular surgical instruments to help improve quality and prevent TASS.
This measure would promote collaboration between the surgeon and the facility,
as the surgeon would report back to the facility any incidence of TASS, as is
already done by surgeons. Further, measuring the incidence may aid in better
tracking and understanding the prevalence of TASS, as the Food and Drug
Administration contends that TASS is significantly underreported and
surveillance is underway. There are specific prevention guidelines that have
been developed, and this measure would help ensure that they are being
appropriately followed. The ASC Quality Collaboration has conducted
reliability testing. (Submitted by: American Academy of
Ophthalmology)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program: Skilled Nursing Facility Value-Based
Purchasing Program; MUC ID: MUC15-1048) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. AHCA is pleased to have the opportunity to comment on the MAP
Preliminary Decisions and MAP Draft Report ”. Thank you again for the
opportunity to provide these comments. Please contact me at DGifford@ahca.org
with any questions or for additional information. We support the MAP’s
preliminary decision to “encourage continued development” of this measure.
However, in the draft report, the MAP must clearly state that encouraging
continued development of this measures should not be taken as support of
inclusion of this measure in the SNF VBP. We also think the report needs to
include the comments and recommendations made by the MAP workgroup on each
measure since that is the primary role of the MAP to provide DHHS with
feedback on the MUC list and DHHS needs to respond to those comments in any
proposed rule. Without inclusion of these comments, if DHHS decided to
implement this measure for rule making via the Federal Register process, CMS
does not need to provide a rationale for their decision. Additionally, for
the sake of transparency and enhanced stakeholder feedback the draft report
should include the specific public comments submitted. Our specific comments
on this measure are as follows. A preliminary draft yet incomplete
specifications for this measure were provided by CMS for public comment, with
the deadline for comment being December 1st, 2015, which is after the MUC list
was published. No information on reliability or validity of the measure is
available and the risk adjustment methodology is not fully specified. In
addition, CMS has provided inadequate time for public review and comment of
this measure. In fact, the TEP never saw the preliminary draft full
specification of this measure until it was made available for public comment
in late November 2105 after the TEP meeting. This measure (MUC15-1048)
double counts readmissions with other SNF potentially preventable readmission
measure (MUC15-495). Measure MUC15-1048 includes readmission that occur
within a SNF stay and after a SNF stay. Thus, this measure will capture the
same readmissions as in measure MUC14-495 resulting in a double counting of
measures. This measure is developed for the SNF VBP. The SNF VPB statute does
not require readmissions after SNF stay to be included. The statute only
states that (g) Skilled nursing facility readmission measure (1) Readmission
measure Not later than October 1, 2015, the Secretary shall specify a skilled
nursing facility all-cause all-condition hospital readmission measure (or any
successor to such a measure). (2) Resource use measure Not later than October
1, 2016, the Secretary shall specify a measure to reflect an all-condition
risk-adjusted potentially preventable hospital readmission rate for skilled
nursing facilities.
https://www.govtrack.us/congress/bills/113/hr4302/text/enr#link=II_215_a_~T1&nearest=H77F0E089948D48C8A638611B926D2ABF
In addition, this measure does not harmonized with the within stay IRF
measure MUC15-497, which only counts readmissions that occur during the IRF
stay. Thus, this measure needs to be revised to only count readmission during
the SNF stay. We have additional concerns with this measure that mirror our
comments on measure MUC15-495 related to: 1. The name of the measures should
reflect the limited population to which they apply – fee-for service (FFS)
Medicare beneficiaries; particularly since in many states 40% or more of
Medicare beneficiaries are enrolled in MA plans and for SNFs over half of SNF
admissions and discharges are not enrolled in FFS Medicare. 2. The
specifications are based on ICD-9 but all providers as of October 2015 are
required to use ICD-10 and no cross walk with ICD-10 is provided. 3. The
numerator definition and methodology of calculating a “predicted actual” is
extremely confusing, which makes the data less likely to be used and is of
questionable benefit. Data showing how this approach is superior to using an
actual rate divided by the expected rate needs to be provided. 4. Many of the
potentially preventable admissions contains diagnoses that do not meet the
proposed definition of potentially preventable readmissions; therefore, these
should be dropped. 5. The process for developing the list of potentially
preventable admissions used existing literature but would have benefited from
a more formal process such as the RAND appropriateness rating system (e.g.
modified Delphi approach) rather than ad hoc TEP and consultant experts. 6.
Risk adjustment does not included a. SES characteristics, an issue identified
in the last round of NQF readmission measure reviews as a requirement. b.
Functional status, one of the strongest predictors of hospitalizations. All
the PAC settings are now required to utilize standard functional status
assessment – Section GG from the CARE tool. c. The risk adjustment variables
are not specifically specified with respect to data source and categories but
are given as examples with just a descriptor. For example is age continuous or
categorical variable and if categorical how and from what source? d. Prior
utilization variables indicate they “vary by measure” but how they vary by
measure is not provided. 7. Exclusions are confusing and need some
modifications a. The denominator exclusions appear confusing and overlapping
so that it is unclear if discharges from IRF or LTCH to SNF or HH are included
in the IRF and LTCH denominator. Similarly, if SNF discharges to HH are
included. b. We agree that AMA discharges from PAC provider should be
excluded but so should hospital discharges that are AMA but end up in PAC
provider. 8. The list of related to other NQF endorsed measures is incomplete
and only compares to CMS or RTI endorsed measures. All other NQF endorsed
measures should be included. 9. We agree with the expansion of unplanned
readmission diagnoses from YALE’s list, but will this also be applied to the
SNFRM and hospital readmission measures? (Submitted by: American Health Care
Association )
- In principle, we support a 'readmit measure,' with our only concern being
that the measure be something that can be more easily replicated/tracked by a
delivery system through (e.g.,) claims in contrast to what is proposed here
comparable to a 'black box' - garbage in, garbage out--overly
complicated---and not replicable through claims. This is eomething to be
considered in the "further development" (Submitted by: American Medical group
Association - EB)
- (Early public comment)We recommend against approval of the measures
at this time because they are not fully developed and ask the NQF MAP PAC/LTC
workgroup to exercise their option to vote to "encourage further development"
of this set of measures. The rationale for this recommendation is supported
by the facts that: • many of the measures are not fully specified yet – the
initial CMS comment periods for some of these measures is ongoing at this
point (e.g., Discharge to Community and Potentially Preventable
Hospitalization) and no specifications have been released for others (e.g.,
Spending per Beneficiary); • the intended uses for each measure have not been
specified; • while some are existing measures, they have not been tested for
specific purposes or are now being recommended for use in settings where they
have not been tested (e.g., IRF measures now being applied to the SNF
setting); • some have never been used previously and many have had no testing
for reliability and validity. These measures remain early in their
development process and do not meet NQF MAP criteria for recommendation at
this time. We are concerned that the timeline for the process of review,
stakeholder input and testing has been shortened unrealistically and has not
allowed for adequate vetting of the measures and their potential applications.
A more thorough and transparent process is required before these can and
should be used in programs that have the potential to significantly affect
provider behavior and practices. Please keep in mind as you discern these
measures, that the SNF does not have authority to control conditions once a
patient leaves our setting. It is the SNF responsibility to set up a proper
discharge plan, provide proper patient/care giver education; however, patient
choice to not follow recommendations is beyond our control and authority.
Thank you for your consideration of these comments. (Submitted by:
Benedictine Health System)
- (Early public comment)AHCA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. Thank you again for the opportunity to provide these comments. Please
contact me at DGifford@ahca.org with any questions or for additional
information. A preliminary draft yet incomplete specifications for this
measure were provided by CMS for public comment, with the deadline for comment
being December 1st, 2015, which is after the MUC list was published. No
information on reliability or validity of the measure is available and the
risk adjustment methodology is not fully specified. In addition, CMS has
provided inadequate time for public review and comment of this measure. In
fact, the TEP never saw the preliminary draft full specification of this
measure until it was made available for public comment in late November 2105
after the TEP meeting. Therefore, for these reasons and our concerns detailed
below, we believe this measure does not meet NQF MAP criteria for endorsement
but rather should receive a vote of “encourage continued development” This
measure (MUC15-1048) double counts readmissions with other SNF potentially
preventable readmission measure (MUC15-495). Measure MUC15-1048 includes
readmission that occur within a SNF stay and after a SNF stay. Thus, this
measure will capture the same readmissions as in measure MUC14-495 resulting
in a double counting of measures. This measure is developed for the SNF VBP.
The SNF VPB statute does not require readmissions after SNF stay to be
included. The statute only states that (g) Skilled nursing facility
readmission measure (1) Readmission measure Not later than October 1, 2015,
the Secretary shall specify a skilled nursing facility all-cause all-condition
hospital readmission measure (or any successor to such a measure). (2)
Resource use measure Not later than October 1, 2016, the Secretary shall
specify a measure to reflect an all-condition risk-adjusted potentially
preventable hospital readmission rate for skilled nursing facilities.
https://www.govtrack.us/congress/bills/113/hr4302/text/enr#link=II_215_a_~T1&nearest=H77F0E089948D48C8A638611B926D2ABF
In addition, this measure does not harmonized with the within stay IRF
measure MUC15-497, which only counts readmissions that occur during the IRF
stay. Thus, this measure needs to be revised to only count readmission during
the SNF stay. We have additional concerns with this measure that mirror our
comments on measure MUC15-495 related to: 1. The name of the measures should
reflect the limited population to which they apply – fee-for service (FFS)
Medicare beneficiaries; particularly since in many states 40% or more of
Medicare beneficiaries are enrolled in MA plans and for SNFs over half of SNF
admissions and discharges are not enrolled in FFS Medicare. 2. The
specifications are based on ICD-9 but all providers as of October 2015 are
required to use ICD-10 and no cross walk with ICD-10 is provided. 3. The
numerator definition and methodology of calculating a “predicted actual” is
extremely confusing, which makes the data less likely to be used and is of
questionable benefit. Data showing how this approach is superior to using an
actual rate divided by the expected rate needs to be provided. 4. Many of the
potentially preventable admissions contains diagnoses that do not meet the
proposed definition of potentially preventable readmissions; therefore, these
should be dropped. 5. The process for developing the list of potentially
preventable admissions used existing literature but would have benefited from
a more formal process such as the RAND appropriateness rating system (e.g.
modified Delphi approach) rather than ad hoc TEP and consultant experts.
6. Risk adjustment does not included a. SES characteristics, an issue
identified in the last round of NQF readmission measure reviews as a
requirement. b. Functional status, one of the strongest predictors of
hospitalizations. All the PAC settings are now required to utilize standard
functional status assessment – Section GG from the CARE tool. c. The risk
adjustment variables are not specifically specified with respect to data
source and categories but are given as examples with just a descriptor. For
example is age continuous or categorical variable and if categorical how and
from what source? d. Prior utilization variables indicate they “vary by
measure” but how they vary by measure is not provided. 7. Exclusions are
confusing and need some modifications a. The denominator exclusions appear
confusing and overlapping so that it is unclear if discharges from IRF or LTCH
to SNF or HH are included in the IRF and LTCH denominator. Similarly, if SNF
discharges to HH are included. b. We agree that AMA discharges from PAC
provider should be excluded but so should hospital discharges that are AMA but
end up in PAC provider. 8. The list of related to other NQF endorsed measures
is incomplete and only compares to CMS or RTI endorsed measures. All other
NQF endorsed measures should be included. 9. We agree with the expansion of
unplanned readmission diagnoses from YALE’s list, but will this also be
applied to the SNFRM and hospital readmission measures? (Submitted by:
American Health Care Association )
- (Early public comment)this measure is redundant and overlapping
with MUC15-495 adn seems in conflict with the IRF measure MUC15-497. the list
of preventable diagnoses includes several that are NOT preventable by the SNF
and do not reflect the care provided. This is an incomplete measure, as
written and we would recommend additional work (Submitted by:
leadingage)
- (Early public comment)While written comments were not provided, the
commenter indicated their support for this measure in this program. (Submitted
by: Smith & Nephew )
- (Early public comment)Avoiding potentially preventable readmissions
is an important component of improving resident satisfaction and avoiding
unnecessary healthcare spending. The key to this measure being useful and
appropriate for inclusion is the ability to consistently and effectively
distinguish between preventable and unpreventable hospital visits. SHE was
not able to find information about how these determinations weremade. Could
such a measure lead to resident selection that would serve as a barrier to
care skilled nursing facility care for persons thought to be at higher risk of
“unplanned” hospital visits (e.g., those with more severe underlying illness)?
(Submitted by: The Society for Healthcare Epidemiology of
America)
- (Early public comment)AMDA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
AMDA - The Society for Post-Acute and Long-Term Care Medicine (AMDA)
represents over 5,500 physician medical directors, attending physicians, and
other practitioners who work in post-acute and long-term care settings.
Thank you again for the opportunity to provide these comments. Please contact
me at abardakh@amda.com with any questions or for additional information. A
preliminary draft yet incomplete specifications for this measure were provided
by CMS for public comment, with the deadline for comment being December 1st,
2015, which is after the MUC list was published. No information on reliability
or validity of the measure is available and the risk adjustment methodology is
not fully specified. In addition, CMS has provided inadequate time for public
review and comment of this measure. In fact, the TEP never saw the preliminary
draft full specification of this measure until it was made available for
public comment in late November 2105 after the TEP meeting. Therefore, for
these reasons and our concerns detailed below, we believe this measure does
not meet NQF MAP criteria for endorsement but rather should receive a vote of
“encourage continued development” This measure (MUC15-1048) double counts
readmissions with other SNF potentially preventable readmission measure
(MUC15-495). Measure MUC15-1048 includes readmission that occur within a SNF
stay and after a SNF stay. Thus, this measure will capture the same
readmissions as in measure MUC14-495 resulting in a double counting of
measures. This measure is developed for the SNF VBP, but the definition of a
“potentially preventable” readmission is not stated. The SNF VPB statute does
not require readmissions after SNF stay to be included. The statute states
that: (g) Skilled nursing facility readmission measure (1) Readmission measure
Not later than October 1, 2015, the Secretary shall specify a skilled nursing
facility all-cause all-condition hospital readmission measure (or any
successor to such a measure). (2) Resource use measure Not later than October
1, 2016, the Secretary shall specify a measure to reflect an all-condition
risk-adjusted potentially preventable hospital readmission rate for skilled
nursing facilities.
https://www.govtrack.us/congress/bills/113/hr4302/text/enr#link=II_215_a_~T1&nearest=H77F0E089948D48C8A638611B926D2ABF
In addition, this measure does not harmonized with the within stay IRF
measure MUC15-497, which only counts readmissions that occur during the IRF
stay. Thus, this measure needs to be revised to only count readmission during
the SNF stay. We have additional concerns with this measure that mirror our
comments on measure MUC15-495 related to: 1. The name of the measures should
reflect the limited population to which they apply – fee-for service (FFS)
Medicare beneficiaries; particularly since in many states 40% or more of
Medicare beneficiaries are enrolled in MA plans and for SNFs over half of SNF
admissions and discharges are not enrolled in FFS Medicare. 2. The
specifications are based on ICD-9 but all providers as of October 2015 are
required to use ICD-10 and no cross walk with ICD-10 is provided. 3. The
numerator definition and methodology of calculating a “predicted actual” is
extremely confusing, which makes the data less likely to be used and is of
questionable benefit. Data showing how this approach is superior to using an
actual rate divided by the expected rate needs to be provided. 4. Many of the
potentially preventable admissions contains diagnoses that do not meet the
proposed definition of potentially preventable readmissions; therefore, these
should be dropped. 5. The process for developing the list of potentially
preventable admissions used existing literature but would have benefited from
a more formal process such as the RAND appropriateness rating system (e.g.
modified Delphi approach) rather than ad hoc TEP and consultant experts.
6. Risk adjustment does not included a. SES characteristics, an issue
identified in the last round of NQF readmission measure reviews as a
requirement. b. Functional status, one of the strongest predictors of
hospitalizations. All the PAC settings are now required to utilize standard
functional status assessment – Section GG from the CARE tool. c. The risk
adjustment variables are not specifically specified with respect to data
source and categories but are given as examples with just a descriptor. For
example is age continuous or categorical variable and if categorical how and
from what source? d. Prior utilization variables indicate they “vary by
measure” but how they vary by measure is not provided. 7. Exclusions are
confusing and need some modifications a. The denominator exclusions appear
confusing and overlapping so that it is unclear if discharges from IRF or LTCH
to SNF or HH are included in the IRF and LTCH denominator. Similarly, if SNF
discharges to HH are included. b. We agree that AMA discharges from PAC
provider should be excluded but so should hospital discharges that are AMA but
end up in PAC provider. 8. The list of related to other NQF endorsed measures
is incomplete and only compares to CMS or RTI endorsed measures. All other
NQF endorsed measures should be included. 9. We agree with the expansion of
unplanned readmission diagnoses from YALE’s list, but will this also be
applied to the SNFRM and hospital readmission measures? (Submitted by:
AMDA-The Society for Post-Acute and Long-Term Care Medicine)
- (Early public comment)Initially, we would urge you to vote to
require additional development on this proposed set of measures. We are
concerned that these measures are not fully developed and require additional
testing. In support of this position, we would submit that: • Many of the
measures are not fully specified and public comments are still pending; in
fact, Golden Living submitted comments last week on Potentially Preventable
Hospital Rehospitalization. • No specifications have been released for certain
measures, for example, the measure on Spending per Beneficiary. • Intended
uses for each measure have not been specified. • While some of the proposed
measures are existing measures, they have not been tested for specific
purposes, or are now being submitted for use in settings where they have not
been tested, for example IRF measures would be applied to SNF settings. • Some
measures have never been used and many have not been tested for reliability
and validity. We are concerned that many of these measures are only in the
development phase and do not meet NQF MAP criteria for recommendation at this
time. We are also concerned about the challenging timeframe for review and
stakeholder input that has been applied to these measures. We urge you to
allow adequate time for vetting, comment, and testing of these measures and
their application. In addition to urging additional development of all the
measures, we would submit the following comments on specific measures. • NQF
#2633 is primarily intended for use by inpatient rehab facilities and while it
shares some elements also included in Section GG on the MDS for implementation
October 2016, there are additional elements in this measure not included on
the MDS. These include, in the Self Care Area – wash upper body, shower/bathe
self, upper body dressing, lower body dressing, putting on/taking off
footwear; and in the Mobility Area – roll left and right, care transfer, walk
10 feet, walking 10 feet on uneven surface, 1 step (curb), 4 steps, 12 steps,
and picking up object. Since the IMPACT Act mandates reporting of
“standardized data set” from all PAC settings, we would urge you to require
providers in all settings to report the same items. • Discharge to
Community-Post Acute Care (PAC) Skilled Nursing Facility Quality Reporting
Program – We generally believe that this measure insures a consistent,
standardized approach to calculation of the measure for all SNFs. • Percent of
Skilled Nursing Facility Residents Who Self-Report Moderate to Severe Pain –
While we generally support this measure, we urge the development of a
companion measure to report the percentage of short-stay patients who
demonstrate a change in reporting pain during the stay. This would measure the
effectiveness of the facility’s effort to address and manage the pain. Thank
you for your attention to the concerns of Golden Living. Candace Bartlett
National Senior Director Regulatory Affairs Golden Living 8930 Valley Creek
Dr. Arlington, TN 38002 (901) 504-8313 robin.bartlett@goldenliving.com
(Submitted by: Golden Living)
- (Early public comment)At least one NRHI member has expressed
concerns regarding this measure. Specifically, clinical staff at
HealthInsight have concerns with inclusion of this measure due to the validity
of and complicated methodologies used for "risk adjustment for patient
characteristics and a statistical estimate of the facility effect beyond
patient mix." This methodology is frequently cited as the basis for
determining potentially avoidable hospital facility admissions. This
methodology is not well-established. (Submitted by: Network for Regional
Healthcare Improvement)
(Program: Inpatient Psychiatric
Facility Quality Reporting Program; MUC ID: MUC15-1065) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Indian Health
Service)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- What constitutes a referral or prescription seems vague. Also, the
measure would be stronger if it excluded patients who do not have active
substance use issues. A patient with a remote history of alcohol dependence,
for example, who is in A.A., has a sponsor, and in full remission, might have
“history of” (or some variant of this) alcohol dependence on their diagnosis
list, but would not need a referral or prescription. Yet the patient could be
counted as a failure for the hospital. (Submitted by: Johns Hopkins Armstrong
Institute for Patient Safety and Quality)
- The Joint Commission supports inclusion of these measures for both the
IPFQR and HIQR programs; however, we do not support expansion of these
measures to include patients under 18 years of age. The current measure
specifications are based on the 2009 VA/DoD Clinical Practice Guideline for
Management of Substance Use Disorders which applies to adults 18 years of age
or older. The evidence-base does not support the use of pharmacological agents
for younger patients, since these medications have not been approved for use
in this cohort of patients. The Joint Commission supports inclusion of these
measures in the MUC as they are currently specified, only applying to adults
18 years of age or older. (Submitted by: The Joint Commission)
- AAHPM agrees that patients discharged to home or another healthcare
facility for hospice care should be excluded from this measure. (Submitted by:
American Academy of Hospice and Palliative Medicine)
- This measure is not a good fit for SUD patients in treatment in IPFs. It
is a population screening measure. For that reason it does not add value to
the program measure set. (Submitted by: National Association of Psychiatric
Health Systems)
- (Early public comment)The measure is a logical extension to the SUB
1 and 2/2a measures for patients with alcohol use disorders. For these
individuals, continuation of their treatment for unhealthy alcohol use after
their hospital stay is recommended to reduce the relapse rate of patients
during care transitions. The SUB 3/3a measures include patients with drug
use disorders listed on the ICD-10 code inclusion tables at discharge, which
differs from SUB1 and SUB 2/2a. The denominator for SUB-3 measures (patients
with alcohol or drug disorders) will be greater than the numerator for SUB-1
(patients with an alcohol disorder) because it includes patients who received
an ICD-10 diagnosis of alcohol or drug use during their stay, as well as those
screened with a non-validated tool which indicated unhealthy alcohol use. The
disconnect in patients included in the SUB 1 and SUB3 measures makes it more
complicated to understand the size of the population in need of these
services. It is important to keep in mind that one reason that these measures
are reported publically is to help patients make decisions about where to get
their health care. Keeping measures harmonious makes the results easier for
the public to understand. Calculation of the SUB3/3a measures rely, in part,
on ICD-10 procedure codes for alcohol or drug services. We have been informed
by some of our facilities that they do not bill based on procedure codes since
Medicare pays facilities based on the IPF PPS. Therefore, IPFs do not track
drug or alcohol procedure codes in their systems. In summary, given the high
rate of patients in inpatient psychiatric care who have co-occurring alcohol
and/or other drug abuse and dependence, we support the inclusion of the
SUB3-3a measures to monitor continuity of care for alcohol/drug disorders
after discharge. (Submitted by: NRI)
- (Early public comment)The Joint Commission appreciates the support
for this measure for the Inpatient Psychiatric Facility setting. Of note is
the fact that this measure was developed for use in all care settings, and The
Joint Commission would urge consideration for adoption in the Hospital
Inpatient Quality Reporting Program and other CMS program settings as well.
The Joint Commission currently includes SUB-3: Alcohol and Other Drug Use
Disorder Treatment Provided or Offered at Discharge and SUB-3a: Alcohol and
Other Drug Use Disorder Treatment at Discharge in the Substance Use (SUB) core
measure set in their ORYX performance measurement reporting program. The
Joint Commission’s ORYX® initiative integrates outcomes and other performance
measurement data into the accreditation process. ORYX measurement requirements
are intended to support Joint Commission-accredited organizations in their
quality improvement efforts. In addition, these measures are reported on
Quality Check® which is the Joint Commission’s public website that allows
consumers to: search for accredited and certified organizations by city and
state, by name or by zip code (up to 250 miles); find organizations by type of
service provided within a geographic area; download free hospital performance
measure results; and, print a list of Joint Commission certified
disease-specific care programs and health care staffing firms. The Joint
Commission continuously monitors and as appropriate revises their performance
measures based on feedback from the field in order to clarify measure
specifications. There have been no reports of difficulty implementing these
measures. (Submitted by: The Joint Commission)
(Program: Inpatient
Psychiatric Facility Quality Reporting Program; MUC ID: MUC15-1082)
|
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Johns Hopkins
Armstrong Institute for Patient Safety and Quality)
- The AHA agrees with the MAP’s recommendation for this measure, and
strongly encourages CMS to incorporate sociodemographic adjustment as needed.
We also urge CMS to ensure that readmissions unrelated to the index IPF
admission are excluded from the measure calculation. As demonstrated in a
growing body of research, sociodemographic factors – such as the availability
of primary care, physical therapy, easy access to medications and appropriate
food, and other supportive services – significantly influence performance on
outcome measures like readmissions, mortality and resource use. For the
inpatient psychiatric facility readmission measure, we believe adjusting for
sociodemographic factors is significantly important. In many instances, the
readmission risk for psychiatric and behavioral health patients will hinge on
whether they have access to outpatient mental health services after discharge
from and inpatient psychiatric facility. However, the U.S. has a shortage of
mental health professionals – currently the Health Resources and Services
Administration has identified 4,000 mental health professional shortage areas.
Measures that fail to adjust for sociodemographic factors when there is a
conceptual and empirical relationship between those factors and the measure
outcome lack credibility, unfairly portray the performance of providers caring
for more complex and challenging patient populations, and may serve to
exacerbate health care disparities. Furthermore, we are concerned that there
may be instances where the IPF readmission measure would penalize an IPF
because of an unrelated readmission, even if the IPF did everything within its
control to ensure the patient had a good outcome. We agree that IPFs should
evaluate and treat patients in a holistic way and address their medical as
well as physical needs during the hospital stay. Nevertheless, unrelated
readmissions often are beyond the control of an IPF. For example, a patient
may be discharged from an IPF after an admission for severe depression, and
within 30 days be readmitted to an acute care hospital for appendicitis or
another condition or injury that is not related to the patient’s depression.
While the planned readmissions algorithm addresses some of our concerns about
unplanned readmissions, it does address all of our concerns about unrelated
readmissions. (Submitted by: American Hospital Association (AHA))
- FAH supports the workgroup's recommendation and rationale. (Submitted by:
Federation of American Hospitals)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- We agree with the recommendation that this measure not be implemented
until endorsed by NQF. We also agree that attention must be paid to the
influence of sociodemographic factors including access to community resources.
The measure needs to be aligned with all other readmission measures including
how psychiatric admissions are accounted for in the IPPS system. (Submitted
by: National Association of Psychiatric Health Systems)
- (Early public comment)It is unclear from the List of Measures Under
Consideration if the 30-day all-cause unplanned readmission measure is a
Medicare claims-based measure. It appears that the psychiatric hospital would
be responsible for ensuring patients are enrolled in both Part A and B
Medicare at the time of discharge and for 30 days after discharge. Hospitals
would not have a way of knowing where patients are readmitted after discharge.
We do not believe an “all-cause” readmission measure appropriately reflects
the level of responsibility of inpatient psychiatric hospitals. After a
patient is discharged from an IPF, their improved psychiatric state may allow
them insights into their medical needs, leading them to seek medical
treatment. An admission for medical reasons may be an appropriate action to
tend to a patient’s medical needs, and would not be a reflection of inadequate
psychiatric care. A re-admission for medical reasons can be identified from
paid Medicare claims, and therefore excluded from the measure. Psychiatric
readmission is a measure commonly used by psychiatric facilities; however, it
is limited to psychiatric reasons for readmission to the same facility. This
is an area of accountability that has been acceptable to psychiatric
facilities, readmission being interpreted as lack of readiness of the patient
for discharge, unavailability of appropriate community supports, or patient
follow-through. NRI does not support an all-cause readmission measure as
appropriate for the IPFQR. A more appropriate measure would be limited to
re-admission to IPF setting. (Submitted by: NRI)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)On review of our readmit data, primary causes
of readmissions are refusal/inability to continue psych meds post-discharge,
refusal of mental health/substance abuse tx, and discharge to home even if the
treatment team recommended otherwise. Either the insurance or city/state won't
fund an alternative environment, or there is no legal mechanism to support
placement against someone's will. (Submitted by: Univ of CA, San
Francisco)
(Program:
Hospital Inpatient Quality Reporting and EHR Incentive Program; MUC ID:
MUC15-1083) |
- This measure is problematic for several reasons: 1. Patient autonomy – The
patient must give informed consent to undergoing this type of delivery and can
decline. Many patients decline and there is no way to determine this from
administrative data which is the source for this measure. 2. The likelihood of
success can be calculated antenatal using the following web base calculator:
https://mfmu,bsc.gwu.edu/PublicBSC/MFMU/VGBirthCalc/vagbirth.html. This is
used in counseling and if a patient has a low likelihood of success she is
counseled against VBAC. 3. This measure was used in the past as a quality
measure and was abandoned when it was found to not save money at any VBAC
rate. 4. To offer this 24 hour in house anesthesia coverage is needed which is
not available at all hospitals. 5. At better quality measure would be VBAC
success rate which is ( (VBAC attempts that result in vaginal births)/(all
attempted VBACs)) x (100) with a goal of 64% or greater. At this rate the
morbidity is improved for the procedure. If it is coded this can be obtained
from administrative data and there would need to be no exclusions. (Submitted
by: Johns Hopkins Armstrong Institute for Patient Safety and
Quality)
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- This measure has not been reviewed/endorsed by NQF. Some issues that still
need to be discussed/vetted with this measure include, times when it is
appropriate not to have a VBAC ; no understanding of what ideal VBAC is; not
based sufficiently on ACOG guideline – ACOG focus on trial of labor discussed
with the mother. (Submitted by: Children's Hospital Association)
- While this measure addresses an important topic the apporpriate VBAC rate
is not known. We agree with MAP that calculating VBAC rates using only CMS
claims data would be inadequate. (Submitted by: Premier)
- GNYHA agrees with MAP’s recommendation to not support this measure for
adoption in the Hospital Inpatient Quality Reporting Program. GNYHA agrees
with MAP’s rationale that the measure adds little value to this measure set
since VBAC rates would be calculated using only CMS claims data. (Submitted
by: Greater New York Hospital Association)
- (Early public comment)While this measure addresses an important
topic the apporpriate VBAC rate is not known. Additionally, this measure
should be reviewed for endorsement. (Submitted by: Premier)
- (Early public comment)Cesarean section is often "mis"classified as
an outcome measure. Truly, the outcomes of birth are 1) healthy mother and 2)
healthy baby (or babies). Cesarean section is technically a process, and
performance measures on cesareans are technically process measures. We have
been willing to classify cesareans as "Intermediate Outcomes" and with that
same rationale, vaginal births after cesareans should also be considered
"Intermediate Outcomes". For consistency, we would like this re-classified as
an intermediate outcome measure. Other than its classification, the American
College of Obstetricians and Gynecologists supports this measure.
(Submitted by: American College of Obstetricians and
Gynecologists)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program: Home Health Quality Reporting Program; MUC ID: MUC15-1127)
|
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- The Alliance supports the use of this measure, but is concerned about the
lack of clarity involving the definition of key terms and administrative
burden associated with the measure, and the need for adequate testing before
such a measure is applied broadly. The Alliance is concerned that there are
not clear definitions for the term “potential clinically significant”
medication issues, as well as for what constitutes “significant drug
interactions,” and “significant side effects,” “any potential adverse
effects.” Greater clarity is also needed to understand what constitutes
ineffective drug therapy. Moreover, the Alliance is concerned about burden
associated with this measure. The follow up time with the physician or
physician designee must be clearly defined, but also adaptive to the risk and
urgency of follow-up with a physician. We are also concerned about whether
agencies will be penalized if physicians are not responsive to home health
agency follow-up. Unfortunately, physicians often are not conscientious about
follow up with home health agencies that are reaching out regarding their
patients. Finally, the Alliance urges testing of this measure and
reconsideration before it is finalized. Testing and validation should be no
less than six months with an opportunity to modify the measure prior to
finalizing it. A similar approach was used for many of the OASIS-based
measures that CMS uses for home health agencies. (Submitted by: Alliance for
Home Health Quality and Innovation)
- These comments cover MUC 1127-1130. for all four of these MUC, suggest
using complete medication reconciliation as per vis ACO measures at
SOC/ROC/admission. In this methodology, reconciliation includes documentation
of 'No Change' if there is no change - for completeness of reporting
(Submitted by: American Medical Group Asssociation - EB)
- NAHC agrees with the MAP's decision to encourage continued development on
this measure . We also agree with the reasons discussed by the group for
addition development. (Submitted by: NAHC)
- (Early public comment)In general, NAHC supports the Drug Regimen
Review measure as proposed. However, to ensure accurate measure comparison and
data exchange among the post-acute care providers, we urge the developers to
establish clear definitions for the terms “clinically significant” medication
issues and “one calendar day”. (Submitted by: National Association for Home
Care & Hospice (NAHC))
- (Early public comment)• MUC15-1127: Drug Regimen Review Conducted
with Follow-Up for Identified Issues Post Acute Care (PAC) Home Health
Quality Reporting Program (Required under the IMPACT Act)- The numerator
contains components of a drug regimen review, as well as a follow up with the
physician or physician designee. The numerator does not specifically state
there is a process of medication reconciliation. Medication reconciliation is
mentioned in the rationale for this measure. There is no mention of
medications being prescribed by specialists that may not be relevant to the
acute care stay. We recommend continued development of the measure under
consideration because we feel there should be an emphasis on medication
reconciliation, drug/drug interactions, food/drug interactions and compliance
with medications. The way this measure under consideration is designed, it
minimally assesses the process of reviewing medication and reporting this
review to the physician. (Submitted by: LeadingAge)
- (Early public comment)While we recognize the inclusion of a
Medication Reconciliation measure as part of the IMPACT Act requirements, we
are highly concerned that the measure under consideration is a process measure
that will not evaluate the quality of care being provided, but instead will
measure the effectiveness/efficiency of the data collection of a check-box or
Yes/No value. Furthermore, the requirements of participation in Medicare
payment systems for many of the PAC venues already include considerations for
Medication Reconciliation and/or Drug Regimen Review, suggesting that this
process is already in place for PAC sites, and that the quality measure
results should show near 100% compliance for all facilities. We would also
note that in CMS' public comment summary for this measure, created on November
6, 2015, the "Preliminary Recommendations" state the plan for CMS and the
measure developers to "Continue measure testing and development" as well as
planning on "Conducting pilot testing to assess feasibility, reliability, and
validity of assessment data". This suggests that the measure has not yet been
finalized, and also may not NQF requirements for measure endorsement.
(Submitted by: UDSMR)
- (Early public comment)The Alliance supports the use of this
measure, but is concerned about the lack of clarity involving the definition
of key terms and administrative burden associated with the measure, and the
need for adequate testing before such a measure is applied broadly. The
Alliance is concerned that there are not clear definitions for the term
“potential clinically significant” medication issues, as well as for what
constitutes “significant drug interactions,” and “significant side effects,”
“any potential adverse effects.” Greater clarity is also needed to understand
what constitutes ineffective drug therapy. Moreover, the Alliance is concerned
about burden associated with this measure. The follow up time with the
physician or physician designee must be clearly defined, but also adaptive to
the risk and urgency of follow-up with a physician. We are also concerned
about whether agencies will be penalized if physicians are not responsive to
home health agency follow-up. Unfortunately, physicians often are not
conscientious about follow up with home health agencies that are reaching out
regarding their patients. Finally, the Alliance urges testing of this measure
and reconsideration before it is finalized. Testing and validation should be
no less than six months with an opportunity to modify the measure prior to
finalizing it. A similar approach was used for many of the OASIS-based
measures that CMS uses for home health agencies. (Submitted by: Alliance for
Home Health Quality and Innovation)
- (Early public comment)We support the inclusion of this
cross-setting measure in the home health quality reporting program and believe
that cross-setting comparisons are appropriate. (Submitted by: Association of
Home & Hospice Care of NC/SC Home Care & Hospice
Association)
- (Early public comment)At least one NRHI member has expressed
concerns regarding this measure. Specifically, clinical staff at
HealthInsight have indicated a lack of clarity surrounding the methodologies
that can be used to determine "follow up with a physician" and "physician
designee." (Submitted by: Network for Regional Healthcare
Improvement)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program: Inpatient Rehabilitation Facility
Quality Reporting Program; MUC ID: MUC15-1128) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- FAH supports the workgroup's recommendation and rationale. In addition,
we strongly encourage CMS to conduct robust widespread testing of the measure
before further consideration of its inclusion in the IMPACT Act payment
programs. (Submitted by: Federation of American Hospitals)
- This measure is currently under development. We have concerns that, as
drafted, the information form on which CMS sought public comment describes a
process that is inconsistent with hospital practices. The form describes how a
PAC setting should reconcile medications and then contact the physician within
one day. In the hospital, it is the physician who takes the initiative to
review and reconcile medications that the patient was taking prior to
admission, and then writes orders for those to be continued, deleted, or
changed. We recommended to CMS changes that reflect standard hospital
practice. Furthermore, the information form states that the data associated
with this measure will be collected via the Inpatient Rehabilitation Facility
Patient Assessment Instrument (IRF-PAI). While the IRF-PAI is an excellent
instrument for this type of data collection, significant changes were made to
it in the Fiscal Year (FY) 2016 Inpatient Rehabilitation Facility Prospective
Payment System (IRF PPS) final rule expanding it in length from eight to
eighteen pages. Therefore, any additions to the IRF-PAI should be considered
carefully in terms of any additional administrative burden, even if such
additions are limited to a few items or questions. Additionally, changes to
the IRF-PAI can require staff training, the hiring of additional staff, and
changes to electronic health records and billing and documentation software
all of which take time and can be costly. These changes should be considered
when developing the timeline for modifying the IRF-PAI to give the field
adequate time to make the required changes. Finally, having a mechanism in
place to validate the data associated with this measure to ensure it is
entered and completed is critically important. As proposed, a provider could
easily check a box “yes” to indicate the requirements of the measure were met.
We believe the documentation or other form of verification that this measure
was completed accurately is important and we will work with CMS and NQF to
develop such a mechanism that minimize the administrative burden. Until these
modifications are made we do not believe the measure fulfills its promise to
improve outcomes for patients. Also, it is still in the development phase
within CMS. Therefore, it may be premature to endorse this measure for the
purpose of the IRF QRP. (Submitted by: American Medical Rehabilitation
Providers Association)
- (Early public comment)While we recognize the inclusion of a
Medication Reconciliation measure as part of the IMPACT Act requirements, we
are highly concerned that the measure under consideration is a process measure
that will not evaluate the quality of care being provided, but instead will
measure the effectiveness/efficiency of the data collection of a check-box or
Yes/No value. Furthermore, the requirements of participation in Medicare
payment systems for many of the PAC venues already include considerations for
Medication Reconciliation and/or Drug Regimen Review, suggesting that this
process is already in place for PAC sites, and that the quality measure
results should show near 100% compliance for all facilities. We would also
note that in CMS' public comment summary for this measure, created on November
6, 2015, the "Preliminary Recommendations" state the plan for CMS and the
measure developers to "Continue measure testing and development" as well as
planning on "Conducting pilot testing to assess feasibility, reliability, and
validity of assessment data". This suggests that the measure has not yet been
finalized, and also may not NQF requirements for measure endorsement.
(Submitted by: UDSMR)
- (Early public comment)This measure is currently under development.
We have concerns that, as drafted, the information form on which CMS sought
public comment describes a process that is inconsistent with hospital
practices. The form describes how a PAC setting should reconcile medications
and then contact the physician within one day. In the hospital, it is the
physician who takes the initiative to review and reconcile medications that
the patient was taking prior to admission, and then writes orders for those to
be continued, deleted, or changed. We recommended to CMS changes that reflect
standard hospital practice. Furthermore, the information form states that the
data associated with this measure will be collected via the Inpatient
Rehabilitation Facility Patient Assessment Instrument (IRF-PAI). While the
IRF-PAI is an excellent instrument for this type of data collection,
significant changes were made to it in the Fiscal Year (FY) 2016 Inpatient
Rehabilitation Facility Prospective Payment System (IRF PPS) final rule
expanding it in length from eight to eighteen pages. Therefore, any additions
to the IRF-PAI should be considered carefully in terms of any additional
administrative burden, even if such additions are limited to a few items or
questions. Additionally, changes to the IRF-PAI can require staff training,
the hiring of additional staff, and changes to electronic health records and
billing and documentation software all of which take time and can be costly.
These changes should be considered when developing the timeline for modifying
the IRF-PAI to give the field adequate time to make the required changes.
Finally, having a mechanism in place to validate the data associated with
this measure to ensure it is entered and completed is critically important. As
proposed, a provider could easily check a box “yes” to indicate the
requirements of the measure were met. We believe the documentation or other
form of verification that this measure was completed accurately is important
and we will work with CMS and NQF to develop such a mechanism that minimize
the administrative burden. Until these modifications are made we do not
believe the measure fulfills its promise to improve outcomes for patients.
Also, it is still in the development phase within CMS. Therefore, it may be
premature to endorse this measure for the purpose of the IRF QRP. (Submitted
by: American Medical Rehabilitation Providers Association)
- (Early public comment)The proposed measure “Percentage of care
episodes or stays in which a drug regimen review was conducted at the
Admission /SOC /ROC, and timely follow-up with a physician occurred each time
potentially significant medication issues were identified throughout the care
episode or stay” is intended to be collected by 3 items: • Item 1 asks
providers if a complete drug regimen review conducted at admission identified
any “potentially clinically significant issues” for a patient. • Item 2 asks
providers if they contacted a physician within one calendar day and completed
the recommended course of action for the “identified clinically significant
medication issues” found at admission, if any. • Item 3 asks providers if
they contacted a physician and completed the recommended actions within one
calendar day each time clinically significant medication issues were
identified following admission. While the IMPACT Act designated “medication
reconciliation” as one of several domains for which cross-setting quality
measures are required, the proposed measure instead utilizes “drug regimen
review” to calculate the measure numerator. Although there is an overlap
between “medication reconciliation” and “drug regimen review,” drug regimen
review is a fundamentally distinct process from medication reconciliation.
According to the definition of “drug regimen review” as stated by the Home
Health (HH) Conditions of Participation (CoPs) at §484.55c, the intent is to
“review medications a patient is currently using in order to identify
potential adverse effects or drug reactions.” This most notably includes
noncompliance with drug therapy, significant side effects, and ineffective
drug therapy – all of which are typically infeasible for an admitting facility
to assess during a medication reconciliation process at admission. Such drug
regimen review is distinct from the medication reconciliation act of
“comparing the medications a patient is taking (and should be taking) with
newly ordered medications in order to identify and resolve discrepancies,
including omissions, duplications, contraindications, unclear information, and
changes.” Furthermore, the proposed drug regimen review tracks medication
issues at any point during the care episode or stay (dividing the episode of
care into “admission” and “after admission”) even though medication
reconciliation occurs only during transitions of care, i.e. admission,
transfer, and discharge. According to The Joint Commission, medication
reconciliation occurs at transition points of care where new medications are
ordered or existing orders are rewritten. The Institute for Healthcare
Improvement also considers the medication reconciliation process to occur at
transition points only: “Each time a patient moves from one setting to
another where orders change or must be renewed, clinicians should review
previous medication orders alongside new orders and plans for care, and
reconcile any differences. If this process does not occur in a standardized
manner that is designed to ensure complete reconciliation, medication errors
may lead to adverse events and harm.” A measure that tracks variables
associated with drug regimen review throughout the patient’s stay (as proposed
by the measure) is fundamentally different from a measure that tracks
variables associated with the medication reconciliation processes that occur
only when the patient moves from one setting to another. Additionally, by
lumping discharge into the overly-general “after admission” timeframe, the
proposed measure also fails to adequately capture the discharge process, even
though CMS’ proposed Drug Regimen Review Measure Justification Form lists the
importance of discharge as a critical part of medication reconciliation:
“Hospital discharge is one high risk time point with evidence that there are
high levels of discrepancy. In fact, there is evidence that 50% of patients
experience a clinically important medication error after hospital discharge.”
A thorough and complete medication reconciliation as part of the discharge
planning process is critical for a patient’s successful transition to her/his
discharge destination, whether to home or community or to another inpatient
care setting. It is troubling that the proposed medication reconciliation
measure fails to distinguish this important aspect of a patient’s episode of
care in a post-acute setting. We encourage CMS to propose a “medication
reconciliation” measure that focuses on medication review at transition points
of care and remove elements related to drug regimen review, as they
fundamentally differ in scope and definition. Our comments related to the
existing measure as proposed follow: COMMENTS RELATED TO ITEMS 1 AND 2 Drug
regimen review activities that occur prior to the medication order The term
“medication reconciliation” as defined by The Joint Commission NPSG 03.06.01,
and used in the proposed measure, involves comparing “the medication
information the patient brought to the hospital [either from the discharging
facility or from home] with the medications ordered for the patient by the
hospital in order to identify and resolve discrepancies.” Based on this
definition, medication reconciliation only includes medications that have been
ordered for the patient, but not medications that were prevented from being
ordered by a drug regimen process. For example, hospitals that use an
electronic medical record (“EMR”) typically utilize computer physician order
entry (“CPOE”) that has safeguards in place to prevent a physician from
ordering medications which may have potential adverse effects and drug
reactions for the particular patient. Since these medications were never
ordered, they would not be part of the medication reconciliation and drug
regimen review as defined by the proposed quality measure. We ask that CMS
clarify whether the measure is intended to include or exclude instances where
a drug was reviewed for potential adverse effects and drug reactions prior to
the medication actually being ordered (thus eliminating potential adverse
effects and drug reactions). For example, patients admitted to inpatient
rehabilitation hospitals are typically on anticoagulation therapy. If a
physician attempts to submit an order for the anticoagulant Coumadin in the
EMR, a CPOE may trigger an alert to the physician that this medication
duplicates the existing order for Lovenox, another anticoagulant. The
physician could then cancel the prescription and the medication would never be
ordered, thus avoiding a potential “duplicate drug therapy” result. Because
Coumadin was never actually “ordered,” the process engineered by the CPOE’s
alert system would not be captured as an act of medication reconciliation in
the proposed quality measure. It is unclear whether such processes were
intended to be captured as part of the drug regimen review since, in this
illustrative example, the potentially clinically significant medication issues
were avoided by virtue of a drug order never being executed in the first
place. Further, the physician can accept or override this type of alert in a
CPOE system depending on patient-specific circumstances and his/her own
clinical judgment. If they choose to override the alert, the medication would
be ordered and therefore become subject to a medication reconciliation process
and drug regimen review. While an EMR allows these changes and alerts to be
identified and tracked before a medication is actually ordered, this would be
far more difficult to capture in a non-electronic system, if these decisions
occurred prior to the ordering process. Referring to the previous
anticoagulation example, if a physician considered writing a prescription for
Coumadin but caught this potential “duplicate drug therapy” issue prior to
writing the actual order, no one would ever know. Definition of “Clinically
significant medication issue” We encourage the measure developers to
specifically define, and NQF to ask, what constitutes a “potential clinically
significant medication issue.” Without an explicit and detailed definition of
this term, it will likely vary widely across providers and care settings,
which will in turn cause serious integrity issues for the resulting quality
measure data. It is also important to specify what would not constitute a
“potential clinically significant medication issue.” For HealthSouth’s
recommendations of “potential clinically significant medication issue,” please
see Appendix A. Subjectivity of “Potential” The proposed measure asks
clinicians to predict if a medication issue (potential adverse effect or drug
reaction) found during a drug regimen review would be “potentially clinically
significant.” While some medication issues might undoubtedly cause clinically
significant issues (however such issues are defined), others would be left to
subjective judgment about whether the issue would or would not potentially
cause clinically significant patient effects. This type of subjectivity is
concerning when developing a measure that will be utilized by a wide variety
of clinicians across post-acute care settings, and one that is intended to
achieve standardized data points for subsequent comparison between such
settings. As such, this high level of subjectivity would be a significant
concern to reliability and validity of the proposed quality measure. Item 1 –
Answers “0/1/9” It is unclear how a hospital would answer Item 1 if they found
medication issues that were considered “issues,” but not deemed to be
“potentially clinically significant.” It is implied that 0 “No, no issues
found” and 1 “Yes, issues found” apply only to “potentially clinically
significant medication issues” (particularly given the logic that an answer of
“1” requires Item 2 to be completed), not any “issue” at all. Therefore, if a
hospital finds a medication issue they deem not clinically significant (by the
defined term), there is no available answer option. Accordingly, we recommend
that, for answers 0 and 1, the language be clarified from “issues” to
“potential clinically significant medication issues” and an additional
selection be added for “Yes, medication issues were identified but were not
deemed potentially clinically significant.” This additional answer choice
would also presumably skip Item 2, like current selections “0” and “9”. Item 2
- Medication Follow-Up Under Item 2, it is unclear whether the facility/agency
has one calendar day to “complete prescribed/recommended actions in response
to the identified clinically significant medication issue” or whether that
applies only to contacting the physician (or physician designee). If the
proposed measure is intended to capture whether the physician was contacted
and the recommendation action all occurred in one calendar day, this could be
reworded to clarify. Notably, in Item 3, providers are given one calendar day
for both actions. Admission Clarification The assessment timing for Item 1 and
Item 2 are identified as “admission” for SNF, IRF, LTCH, and SOC/ROC for HH.
However, “admission” remains undefined. Admission orders at a receiving IRF
(and likely SNF and LTCH) typically follow the discharging orders from the
prior level of care until a full reconciliation of the medical record and
medication history can occur. This includes an evaluation by the pharmacist,
a discussion with the patient and/or family, and a review by a physician.
While medication review and reconciliation are initiated immediately upon
admission it can take up to 48 hours for a full “admission medication
reconciliation” to be completed. Therefore, we suggest the “admission”
timeframe be 2 calendar days – the day of admission and the following calendar
day. COMMENTS RELATED TO ITEM 3 The proposed quality measure information
begins with a definition of medication reconciliation and drug regimen review:
Medication reconciliation – the process of comparing the medications a
patient is taking (and should be taking) with newly ordered medications in
order to identify and resolve discrepancies. (Reference: The Joint Commission,
National Patient Safety Goals). Drug regimen review – a review of all
medications the patient is currently using in order to identify any potential
adverse effects and drug reactions, including ineffective drug therapy,
significant side effects, significant drug interactions, duplicate drug
therapy, and noncompliance with drug therapy. (Reference: Home Health
Conditions of Participation Home Health §484.55c). Medication reconciliation
and drug regimen review are intended to identify and avoid potential
medication issues, but the wording of Item 3 omits the word “potential.” We
ask CMS to clarify whether Item 3 is intended to measure potential clinically
significant medication issues or clinically significant medication issues that
have already occurred. This is a critically important distinction.
Reconciling medication instructions before the administration of medication is
a structured, deliberate clinical activity. But handling a clinically
significant issue, such as an adverse drug reaction, is highly variable and
may call for anything from the application of a reversal agent to readmission
to a general acute hospital. Treating these two types of medication-related
events under one measure conflates two processes that are fundamentally
different from one another. While we agree that measuring the timeliness of
notifying the physician after a clinically significant medication issue is
extremely important to patient safety, we believe it is outside the scope of
“medication reconciliation” – which is intended to identify potential issues
before medication is administered. Measuring physician notification after a
clinically significant medication event happens is a separate and distinct
quality measure, and one that should almost never take a full calendar day to
occur. ADDITIONAL COMMENTS Unintended Consequences The purpose of medication
reconciliation is to find and correct errors. No measure, either now or in
the future, should be designed so as to discourage clinicians from reporting
and correcting errors in patient medication. Numerator/Denominator
Exclusions Patients who were admitted and unexpectedly discharged prior to a
medication reconciliation process being completed should be excluded from this
measure. It is assumed this would be indicated on the respective assessment
instruments with a dash (“-“) as currently documented for other quality
measures. Care Setting Differences The drug regimen review that may occur in a
home health setting would be significantly different from an inpatient setting
where the patient is receiving 24-hour care. If clinically significant
medication issues occur in the inpatient setting, they are handled more
immediately than in home health settings. Larger Emphasis on Medication
Reconciliation at Discharge We encourage CMS to consider an aspect of
“medication reconciliation” specifically at the discharge timeframe. A
thorough and complete medication reconciliation and drug regimen review at
this point in the patient’s care is part of the discharge planning process, as
it is critical for a patient’s successful transition to her/his discharge
destination, whether to home or community or to another inpatient care
setting. (Submitted by: HealthSouth)
- (Early public comment)At least one NRHI member has expressed
concerns regarding this measure. Specifically, clinical staff at
HealthInsight have indicated a lack of clarity surrounding the methodologies
that can be used to determine "follow up with a physician" and "physician
designee." (Submitted by: Network for Regional Healthcare
Improvement)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program: Long-Term Care Hospital Quality Reporting
Program; MUC ID: MUC15-1129) |
- FAH supports the workgroup's recommendation and rationale. In addition,
we strongly encourage CMS to conduct robust widespread testing of the measure
before further consideration of its inclusion in the IMPACT Act payment
programs. (Submitted by: Federation of American Hospitals)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- (Early public comment)While we recognize the inclusion of a
Medication Reconciliation measure as part of the IMPACT Act requirements, we
are highly concerned that the measure under consideration is a process measure
that will not evaluate the quality of care being provided, but instead will
measure the effectiveness/efficiency of the data collection of a check-box or
Yes/No value. Furthermore, the requirements of participation in Medicare
payment systems for many of the PAC venues already include considerations for
Medication Reconciliation and/or Drug Regimen Review, suggesting that this
process is already in place for PAC sites, and that the quality measure
results should show near 100% compliance for all facilities. We would also
note that in CMS' public comment summary for this measure, created on November
6, 2015, the "Preliminary Recommendations" state the plan for CMS and the
measure developers to "Continue measure testing and development" as well as
planning on "Conducting pilot testing to assess feasibility, reliability, and
validity of assessment data". This suggests that the measure has not yet been
finalized, and also may not NQF requirements for measure endorsement.
(Submitted by: UDSMR)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program: Skilled Nursing Facility Quality Reporting
System; MUC ID: MUC15-1130) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. AHCA is pleased to have the opportunity to comment on the MAP
Preliminary Decisions and MAP Draft Report ”. Thank you again for the
opportunity to provide these comments. Please contact me at DGifford@ahca.org
with any questions or for additional information. We support the MAP’s
preliminary decision to “encourage continued development” of this measure.
However, in the draft report, the MAP must clearly state that encouraging
continued development of this measures should not be taken as support of
inclusion of this measure in the SNF QRP. We also think the report needs to
include the comments and recommendations made by the MAP workgroup on each
measure since that is the primary role of the MAP to provide DHHS with
feedback on the MUC list and DHHS needs to respond to those comments in any
proposed rule. Without inclusion of these comments, if DHHS decided to
implement this measure for rule making via the Federal Register process, CMS
does not need to provide a rationale for their decision. Additionally, for
the sake of transparency and enhanced stakeholder feedback the draft report
should include the specific public comments submitted. Our specific comments
on this measure are as follows. This measure has not been fully specified. In
fact, the TEP discussion raised some serious concerns about the measure which
it is unclear if they have been addressed. The data source for this measure
has not been specified nor has any of the data elements needed for this
measure been tested for reliability or validity. In fact, CMS has just called
to find 4 SNFs to pilot this measure. This measure also does not appear to be
consistent with the legislative intent of the IMPACT act to develop a
medication reconciliation measure. This a drug regime review for
appropriateness of medications not a measure of reconciliation. Additional
concerns with this measure are listed below. 1. The measure plans to use data
elements from PAC assessments that have not yet been specified and therefore,
the data does not currently exist., In fact, CMS just called for SNFs to
pilot test a data collection tool in 4 SNFs. 2. The measure uses a
definition of Drug Regimen Review which is defined from Conditions of
Participation for Home Health. This definition is not consistent with other
PAC settings. In particular, the definition in this measure is inadequate in
capturing the scope of a drug/medication regimen review and does not address
involvement of interdisciplinary team members. 3. The measure description
includes measurement of follow up on potentially significant medication issues
but does not define what constitutes a potentially significant medication
issue. Lack of clear definition for this critical part of the measure will
result in inconsistent data collection and measurement. 4. It is not clearly
stated if this measure will only apply to short stay or also to long stay
residents/patients in SNFs. 5. There is no information on reliability or
validity for this measure. 6. This measure has not been tested nor has an
examination of feasibility for implementing this measure across PAC settings
been completed. A recent notice on this measure stated “RTI is conducting a
pilot test to investigate data collection methods and the feasibility of
implementing a cross-setting DRR quality measure”. During a recent inquiry,
we were advised only 4 SNF, 4 LTCH and 4 IRF will be participating in this
pilot. This is only 0.0002 percent of SNFs in the country which is an
inadequate representation. (Submitted by: American Health Care Association
)
- (Early public comment)This measure does not distinguish between
Drug Regimen Review and Medication Reconciliation. Within the measure
description, it does not define "potentially significant medication issues".
That is too broad of a statement and comparisons between providers will not be
accurate. Thank you for your consideration of these comments. (Submitted by:
Benedictine Health System)
- (Early public comment)This measure is currently in early
development and measure specifications are in preliminary stages of
clarification. The proposed application could create inaccuracy in
measurement of patient condition and payment. The Numerator requires
“documentation of drug regimen” as opposed to the IMPACT Act of 2014
requirement for “Medication Reconciliation”. The terms need to be better
defined to assure compliance with the IMPACT Act provisions. Once this has
been done, exclusions need to be defined for clinical reasonableness as well
as payment logic. This measure needs extensive work to assure accuracy and to
meet the purpose for which it was intended. Because there is potential for
accuracy this measure should continue to be developed. (Submitted by: Genesis
Health Care)
- (Early public comment)While we recognize the inclusion of a
Medication Reconciliation measure as part of the IMPACT Act requirements, we
are highly concerned that the measure under consideration is a process measure
that will not evaluate the quality of care being provided, but instead will
measure the effectiveness/efficiency of the data collection of a check-box or
Yes/No value. Furthermore, the requirements of participation in Medicare
payment systems for many of the PAC venues already include considerations for
Medication Reconciliation and/or Drug Regimen Review, suggesting that this
process is already in place for PAC sites, and that the quality measure
results should show near 100% compliance for all facilities. We would also
note that in CMS' public comment summary for this measure, created on November
6, 2015, the "Preliminary Recommendations" state the plan for CMS and the
measure developers to "Continue measure testing and development" as well as
planning on "Conducting pilot testing to assess feasibility, reliability, and
validity of assessment data". This suggests that the measure has not yet been
finalized, and also may not NQF requirements for measure endorsement.
(Submitted by: UDSMR)
- (Early public comment)AHCA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. Thank you again for the opportunity to provide these comments. Please
contact me at DGifford@ahca.org with any questions or for additional
information. This measure has not been fully specified. In fact, the TEP
discussion raised some serious concerns about the measure which it is unclear
if they have been addressed. The data source for this measure has not been
specified nor has any of the data elements needed for this measure been tested
for reliability or validity. In fact, CMS has just called to find 4 SNFs to
pilot this measure. This measure also does not appear to be consistent with
the legislative intent of the IMPACT act to develop a medication
reconciliation measure. This a drug regime review for appropriateness of
medications not a measure of reconciliation. Therefore, we believe this
measure does not meet NQF MAP criteria for endorsement but rather should
receive a vote of “encourage continued development” Based on information
available, we have the following specific concerns with this measure. 1. The
measure plans to use data elements from PAC assessments that have not yet been
specified and therefore, the data does not currently exist., In fact, CMS
just called for SNFs to pilot test a data collection tool in 4 SNFs. 2. The
measure uses a definition of Drug Regimen Review which is defined from
Conditions of Participation for Home Health. This definition is not
consistent with other PAC settings. In particular, the definition in this
measure is inadequate in capturing the scope of a drug/medication regimen
review and does not address involvement of interdisciplinary team members.
3. The measure description includes measurement of follow up on potentially
significant medication issues but does not define what constitutes a
potentially significant medication issue. Lack of clear definition for this
critical part of the measure will result in inconsistent data collection and
measurement. 4. It is not clearly stated if this measure will only apply to
short stay or also to long stay residents/patients in SNFs. 5. There is no
information on reliability or validity for this measure. 6. This measure has
not been tested nor has an examination of feasibility for implementing this
measure across PAC settings been completed. A recent notice on this measure
stated “RTI is conducting a pilot test to investigate data collection methods
and the feasibility of implementing a cross-setting DRR quality measure”.
During a recent inquiry, we were advised only 4 SNF, 4 LTCH and 4 IRF will be
participating in this pilot. This is only 0.0002 percent of SNFs in the
country which is an inadequate representation. (Submitted by: American Health
Care Association )
- (Early public comment)This measure is somewhat confusing. How does
this relate to the already regualtory requirement of DDR, as defined by the
CMS Requirement of Participation? Furthermore, the time lines are unclear, as
is the term "significant change". it also doesn't describe what the scope of
this review is to be. We believe this measure needs further consideration and
testing. (Submitted by: leadingage)
- (Early public comment)AMDA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
AMDA - The Society for Post-Acute and Long-Term Care Medicine (AMDA)
represents over 5,500 physician medical directors, attending physicians, and
other practitioners who work in post-acute and long-term care settings.
Thank you again for the opportunity to provide these comments. Please contact
me at abardakh@amda.com with any questions or for additional information.
This measure has not been fully specified. In fact, the TEP discussion raised
some serious concerns about the measure which it is unclear if they have been
addressed. The data source for this measure has not been specified nor has any
of the data elements needed for this measure been tested for reliability or
validity. In fact, CMS has just called to find 4 SNFs to pilot this measure.
This measure also does not appear to be consistent with the legislative intent
of the IMPACT act to develop a medication reconciliation measure. This a drug
regime review for appropriateness of medications not a measure of
reconciliation. Therefore, we believe this measure does not meet NQF MAP
criteria for endorsement but rather should receive a vote of “encourage
continued development” Based on information available, we have the following
specific concerns with this measure. 1. The measure plans to use data
elements from PAC assessments that have not yet been specified and therefore,
the data does not currently exist., In fact, CMS just called for SNFs to
pilot test a data collection tool in 4 SNFs. 2. The measure uses a
definition of Drug Regimen Review which is defined from Conditions of
Participation for Home Health. This definition is not consistent with other
PAC settings. In particular, the definition in this measure is inadequate in
capturing the scope of a drug/medication regimen review and does not address
involvement of interdisciplinary team members. 3. The measure description
includes measurement of follow up on potentially significant medication issues
but does not define what constitutes a potentially significant medication
issue. Lack of clear definition for this critical part of the measure will
result in inconsistent data collection and measurement. 4. It is not clearly
stated if this measure will only apply to short stay or also to long stay
residents/patients in SNFs. 5. There is no information on reliability or
validity for this measure. 6. This measure has not been tested nor has an
examination of feasibility for implementing this measure across PAC settings
been completed. A recent notice on this measure stated “RTI is conducting a
pilot test to investigate data collection methods and the feasibility of
implementing a cross-setting DRR quality measure”. During a recent inquiry,
we were advised only 4 SNF, 4 LTCH and 4 IRF will be participating in this
pilot. This is only 0.0002 percent of SNFs in the country which is an
inadequate representation. (Submitted by: AMDA-The Society for Post-Acute and
Long-Term Care Medicine)
- (Early public comment)At least one NRHI member has expressed
concerns regarding this measure. Specifically, clinical staff at
HealthInsight have indicated a lack of clarity surrounding the methodologies
that can be used to determine "follow up with a physician" and "physician
designee." (Submitted by: Network for Regional Healthcare
Improvement)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)To Whom It May Concern: The American Society
of Consultant Pharmacists is the only international professional society
devoted to optimal medication management and improved health outcomes for all
older persons. ASCP's members manage and improve drug therapy and improve the
quality of life of geriatric patients and other individuals residing in a
variety of environments, including nursing facilities, sub-acute care and
assisted living facilities, psychiatric hospitals, hospice programs, and home
and community-based care. ASCP has a long history of advocating for the
medical best interests of people who reside in long- term care facilities and
those enrolled in hospice programs. We are pleased to have the opportunity to
comment on the “List of Measures under Consideration for December 1, 2015.”
Our specific comments relate to Measures Under Consideration (MUC) 15-1130:
Drug Regimen Review. ASCP supports quality measures and believes strongly,
based on experience and available data, that appropriate drug regimen review
(DRR), combined with timely medication reconciliation, are among the most
effective methods by which to ensure the health and safety of LTC residents.
However, implementation of IMPACT Act quality measures has been a hurried
process that has not allowed stakeholder groups to adequately review the
measures, draft and submit comments. NQF, CMS, and CMS contractors ABT
Associates and RTI have all been involved in the measures related to the
IMPACT Act. There has been confusion on the meaning of terminology, especially
“medication reconciliation” versus DRR. Although ASCP supports DRR and
medication reconciliation quality measures, we ask the National Quality Forum
(NQF) to “encourage continued development” in order to gather further input
from providers with clinical expertise. The definition of Medication
Reconciliation is not clear in any of the proposed measures that we reviewed.
ASCP envisions medication reconciliation as an important quality indicator
involving participation from members across disciplines and institutions. The
process of reconciliation and the objective criteria required to ensure
compliance, as well as the responsibility of providers across care settings
should be clearly stated. The proposed measure should be tested for
feasibility and refinement using a statistically valid sample in order to
arrive at a measure that has meaning and can be replicated over the 16,000
skilled nursing facilities around the country. We appreciate NQF’s work on
this important issue and would like to note that the process for vetting these
quality measures has not met CMS’ normal standard of thoroughness and
consideration. NQF provided notice after the comment period had begun and many
of the important constituents within the LTC community have not had the
opportunity to engage the process. ASCP also proposes that NQF further refine
this measure. This is an excellent opportunity to add an important quality
measure, but the measure should be as clear and consistent as possible before
it is finalized. We look forward to working on this important process.
Sincerely Sincerely, Frank Grosso, RPh Executive Director and CEO American
Society of Consultant Pharmacist (Submitted by: American Society of
Consultant Pharmacist )
(Program: Skilled Nursing Facility Quality Reporting System; MUC ID:
MUC15-1131) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- AAHPM views this as an important measure that should be implemented as
soon as possible. It is important to move beyond screening and adopt measures
that aim to actually improve pain among appropriate populations. (Submitted
by: American Academy of Hospice and Palliative Medicine)
- AHCA is pleased to have the opportunity to comment on the MAP Preliminary
Decisions and MAP Draft Report ”. The American Health Care Association (AHCA)
represents more than 12,000 non-profit and proprietary skilled nursing centers
and assisted living communities. Rather than having many of our individual
members who have contacted us with comments and to more efficiently provide
NQF with feedback, we have received from our various members, we have
summarized their comments here. Thank you again for the opportunity to
provide these comments. Please contact me at DGifford@ahca.org with any
questions or for additional information. We disagree with the MAPs decision
to “encourage continued development” of this measure and rather support it’s
inclusion in SNF QRP. (Submitted by: American Health Care Association
)
- ARN opposes the Percent of SNF Residents Who Self-Report Moderate to
Severe Pain measure. While ARN is committed to ensuring that our patients
receive the highest quality health care possible, we are concerned that
overutilization of quality measures – while well intentioned – may have the
unintended consequence of impeding health care quality. We agree that pain is
what the resident states it is, occurring when the resident says it does, and
that all reports of pain must be taken seriously and managed appropriately.
However, pain is subjective, and pain is expected during the rehabilitation
process. The patients report of pain does not measure the quality of care
provided, it measures occurrence of pain. It is how that pain is or is not
effectively managed that indicates quality care. The proposed measure is not
related to the specific rehabilitative care provided to the patient and/or
resident of a SNF and thus should not be included in the SNF Quality Reporting
Program. (Submitted by: Association of Rehabilitation Nurses)
- CAPC urges the MAP to change its preliminary recommendation for MUC15-1131
from “Encourage Continued Development” for the inclusion in the Skilled
Nursing Facility Quality Reporting Program (SNF QRP) to “Do Not Support”. For
patients receiving palliative care, many of whom are receiving care in skilled
nursing facilities, we have found that it is not fair to hold clinicians to
the standard of eliminating symptoms such as pain, because doing so involves
necessary tradeoffs. If people are in their last 3-5 years of life, it is
conceivable that they would rather be alert and in pain, than drugged and
unconscious or disoriented. Rather than measuring a reduction in symptoms, we
encourage CMS and NQF to consider pain screening, assessment, and plan of care
measures for inclusion in this program as well as home health, hospice,
hospital and other long-term care reporting programs. (Submitted by: Center
to Advance Palliative Care)
- (Early public comment)AHCA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. Thank you again for the opportunity to provide these comments. Please
contact me at DGifford@ahca.org with any questions or for additional
information. There is no reference or link to the measure specifications for
this proposed measure about pain (MUC15-1131) but we assume it is the measure
currently in use by CMS and publicly reported on Nursing Home Compare and if
so, support its inclusion. (Submitted by: American Health Care Association
)
- (Early public comment)AMDA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
AMDA - The Society for Post-Acute and Long-Term Care Medicine (AMDA)
represents over 5,500 physician medical directors, attending physicians, and
other practitioners who work in post-acute and long-term care settings.
Thank you again for the opportunity to provide these comments. Please contact
me at Abardakh@amda.com with any questions or for additional information.
There is no reference or link to the measure specifications for this proposed
measure about pain measure (MUC15-1131) but we assume it is the measure
currently in use by CMS and publicly reported on Nursing Home Compare and if
so, support its inclusion. (Submitted by: AMDA-The Society for Post-Acute
and Long-Term Care Medicine)
(Program: Skilled Nursing Facility Quality
Reporting System; MUC ID: MUC15-1132) |
- ARN supports this measure as individuals residing in long-term care may
not otherwise have access to a flu vaccine. (Submitted by: Association of
Rehabilitation Nurses)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. AHCA is pleased to have the opportunity to comment on the MAP
Preliminary Decisions and MAP Draft Report ”. Thank you again for the
opportunity to provide these comments. Please contact me at DGifford@ahca.org
with any questions or for additional information. We disagree with the MAPs
decision to “encourage continued development” of this measure and rather
support it’s inclusion in SNF QRP. (Submitted by: American Health Care
Association )
- (Early public comment)Inclusion of these measures will build on
existing immunization-related measures currently used in the Physician Quality
Reporting System to help ensure that Medicare beneficiaries benefit from these
important vaccinations. (Submitted by: Trust for America's
Health)
- (Early public comment)AHCA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. Thank you again for the opportunity to provide these comments. Please
contact me at DGifford@ahca.org with any questions or for additional
information. There is no reference or link to the measure specifications for
this proposed measure about influenza vaccine use (#1132) but we assume it is
the NQF endorsed measure currently in use by CMS and publicly reported on
Nursing Home Compare and if so, support its inclusion. (Submitted by:
American Health Care Association )
- (Early public comment)ARN opposes the Percentage of Residents or
Patients Who Were Assessed and Appropriately Given the Seasonal Influenza
Vaccine measure. While ARN is committed to ensuring that our patients receive
the highest quality health care possible, we are concerned that
overutilization of quality measures – while well intentioned – may have the
unintended consequence of impeding health care quality. The purpose of
rehabilitative care is to promote functional recovery and achievement of goals
by patients so that they are able to function to their maximum potential in
the least restrictive environment. The proposed measure is not related to the
specific rehabilitative care provided to the patient and/or resident of a SNF
and thus should not be included in the SNF Quality Reporting Program (QRP).
Numerous opportunities exist in other health care settings to receive
immunizations, prior to an individual’s admission to the SNF. (Submitted by:
Association of Rehabilitation Nurses)
- (Early public comment)AMDA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
AMDA - The Society for Post-Acute and Long-Term Care Medicine (AMDA)
represents over 5,500 physician medical directors, attending physicians, and
other practitioners who work in post-acute and long-term care settings.
Thank you again for the opportunity to provide these comments. Please contact
me at abardakh@amda.com with any questions or for additional information.
There is no reference or link to the measure specifications for this proposed
measure about influenza vaccine use (#1132) but we assume it is the NQF
endorsed measure currently in use by CMS and publicly reported on Nursing Home
Compare and if so, support its inclusion. (Submitted by: AMDA-The Society
for Post-Acute and Long-Term Care Medicine)
(Program: Skilled Nursing Facility Quality Reporting
System; MUC ID: MUC15-1133) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. AHCA is pleased to have the opportunity to comment on the MAP
Preliminary Decisions and MAP Draft Report ”. Thank you again for the
opportunity to provide these comments. Please contact me at DGifford@ahca.org
with any questions or for additional information. We have two primary
concerns with this measure: 1. There is no reference or link to the measure
specifications for this proposed measure about antipsychotic use (#1133) but
we assume it is the measure currently in use by CMS and publicly reported on
Nursing Home Compare. We believe for the NQF MAP process to adequately assess
any measure for voting, the full specifications need to be made available. 2.
The measure does not exclude individuals with bipolar disorder, a FDA approved
diagnosis for antipsychotics. The rationale for use of this measure is the
black box warning for the off-label use in elderly, particularly dementia.
However, the measure does not exclude bipolar disorder. A coalition of long
term providers and health care professionals and physician groups have all
signed a letter supporting the addition of bipolar as an exclusion for this
measure. Therefore, according to NQF MAP criteria, this measure should at
best receive a vote of “support with conditions” that it must undergo NQF
endorsement and that bipolar disorder be added as an exclusion. (Submitted
by: American Health Care Association )
- (Early public comment)AHCA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. Thank you again for the opportunity to provide these comments. Please
contact me at DGifford@ahca.org with any questions or for additional
information. We have two primary concerns with this measure: 1. There is no
reference or link to the measure specifications for this proposed measure
about antipsychotic use (#1133) but we assume it is the measure currently in
use by CMS and publicly reported on Nursing Home Compare. We believe for the
NQF MAP process to adequately assess any measure for voting, the full
specifications need to be made available. 2. The measure does not exclude
individuals with bipolar disorder, a FDA approved diagnosis for
antipsychotics. The rationale for use of this measure is the black box warning
for the off-label use in elderly, particularly dementia. However, the measure
does not exclude bipolar disorder. A coalition of long term providers and
health care professionals and physician groups have all signed a letter
supporting the addition of bipolar as an exclusion for this measure.
Therefore, according to NQF MAP criteria, this measure should at best receive
a vote of “support with conditions” that it must undergo NQF endorsement and
that bipolar disorder be added as an exclusion. (Submitted by: American
Health Care Association )
- (Early public comment)AMDA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
AMDA - The Society for Post-Acute and Long-Term Care Medicine (AMDA)
represents over 5,500 physician medical directors, attending physicians, and
other practitioners who work in post-acute and long-term care settings.
Thank you again for the opportunity to provide these comments. Please contact
me at abardakh@amda.com with any questions or for additional information. We
have two primary concerns with this measure: 1. There is no reference or link
to the measure specifications for this proposed measure about antipsychotic
use (#1133) but we assume it is the measure currently in use by CMS and
publicly reported on Nursing Home Compare. We believe for the NQF MAP process
to adequately assess any measure for voting, the full specifications need to
be made available. 2. The measure does not exclude individuals with bipolar
disorder, a FDA approved diagnosis for antipsychotics. The rationale for use
of this measure is the black box warning for the off-label use in elderly,
particularly dementia. However, the measure does not exclude bipolar disorder.
A coalition of long term providers and health care professionals and physician
groups have all signed a letter supporting the addition of bipolar as an
exclusion for this measure. Therefore, according to NQF MAP criteria, this
measure should at best receive a vote of “support with conditions” that it
must undergo NQF endorsement and that bipolar disorder be added as an
exclusion. (Submitted by: AMDA-The Society for Post-Acute and Long-Term Care
Medicine)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
(Program: Home Health
Quality Reporting Program; MUC ID: MUC15-1134) |
- This is important to measure and report - and while there are unintended
consequences for almost everything we do, we just need to make sure it is easy
to get the data and understand what the numbers actually represent. (Submitted
by: American Medical Group Association - EB)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- The Alliance appreciates the importance of developing measures to better
understand Medicare cost and resource use. However, when viewed in isolation,
the Alliance is concerned that cost information alone is a confusing measure
because it does not necessarily correlate with quality of care. The Alliance
believes that spending alone is not an indicator of quality, nor is it an
indicator of efficiency. The measure will be most useful when paired with
quality outcome measures. If outcome measures are not linked to this cost
measure, there may be an incentive for providers not to refer patients for
reasonable and necessary services, including post-acute care services that can
be used to reduce rehospitalization rates and improve patient experience.
Ensuring that adequate quality outcome measures are coupled with measures of
the cost of care is critical to discouraging underuse. Moreover, there is a
need for the development of measures of patient access to care. Reforms that
are aimed at improving efficient, cost-effective delivery of care are needed,
as are measures that will help to encourage efficiency. However, patient
access should not be compromised as a means to lower cost. Unfortunately, this
measure alone cannot be used to assess whether patients have access to quality
care. The Alliance is not aware of any measures at present that would address
access to care. We would support development of such measures. Finally, the
Alliance urges testing of this measure and reconsideration before it is
finalized. Testing and validation should be no less than six months with an
opportunity to modify the measure prior to finalizing it. A similar approach
was used for many of the OASIS-based measures that CMS uses for home health
agencies. (Submitted by: Alliance for Home Health Quality and
Innovation)
- ARN is concerned with how this information will be reported so that it is
meaningful to patients. Spending per beneficiary does not necessarily imply
better or higher quality care. (Submitted by: Association of Rehabilitation
Nurses)
- As noted in the comments from the MAP and NAHC's previous comments, there
are concerns with unintended consequences such as premature discharges and
discrimination against high cost patients. NAHC also wants to reiterate that
although MSPB may provide some useful information on resource utilization of
Medicare providers, it should not be used as the sole resource use measure or
to draw assumptions on quality of care. (Submitted by: NAHC)
- (Early public comment)• MUC15-1134: Medicare Spending Per
Beneficiary Post Acute Care (PAC) Home Health Quality Reporting Program
(Required under the IMPACT Act)- An accurate determination of Medicare
spending should take into account Medicare Part A, B and D expenditures.
Average episode spending is in the numerator and the weighted median MSPB_PAC
amount across all the home health agencies nationally is in the denominator.
It is important to take into account the considerable variation in number of
visits and number of episodes from state to state. A median across all the
home health agencies nationally may not accurately reflect the cost of care in
certain states. This measure does not meet NQF MAP criteria for endorsement
and requires continued development. (Submitted by: LeadingAge)
- (Early public comment)As an IMPACT Act measure that is stated to be
"standardized and interoperable", we are highly concerned that this measure
may allow for comparison between PAC venues without making adjustments for
patient severity or differences inherent within the various payment systems.
For example, some of the PAC venues are paid on a per diem basis, while other
PAC venues have payments that are episodic. How are these differences
accounted for in the measurement calculations. Additionally, each PAC venue
has different regulatory requirements impacting their ability to control
costs, which are not adequately accounted for in this measure. We also note
that at this time some of the PAC venues are in the midst of drastic changes
to their payment systems. Will the currently developed calculations of this
measure be impacted by changes to underlying payment systems? And finally, the
IMPACT Act also requests a report from MedPAC on the feasibility of a unified
PAC payment system. This work is currently underway, and may provide further
clarity to differences in payments between PAC sites. (Submitted by:
UDSMR)
- (Early public comment)The Alliance appreciates the importance of
developing measures to better understand Medicare cost and resource use.
However, when viewed in isolation, the Alliance is concerned that cost
information alone is a confusing measure because it does not necessarily
correlate with quality of care. The Alliance believes that spending alone is
not an indicator of quality, nor is it an indicator of efficiency. The measure
will be most useful when paired with quality outcome measures. If outcome
measures are not linked to this cost measure, there may be an incentive for
providers not to refer patients for reasonable and necessary services,
including post-acute care services that can be used to reduce
rehospitalization rates and improve patient experience. Ensuring that adequate
quality outcome measures are coupled with measures of the cost of care is
critical to discouraging underuse. Moreover, there is a need for the
development of measures of patient access to care. Reforms that are aimed at
improving efficient, cost-effective delivery of care are needed, as are
measures that will help to encourage efficiency. However, patient access
should not be compromised as a means to lower cost. Unfortunately, this
measure alone cannot be used to assess whether patients have access to quality
care. The Alliance is not aware of any measures at present that would address
access to care. We would support development of such measures. Finally, the
Alliance urges testing of this measure and reconsideration before it is
finalized. Testing and validation should be no less than six months with an
opportunity to modify the measure prior to finalizing it. A similar approach
was used for many of the OASIS-based measures that CMS uses for home health
agencies. (Submitted by: Alliance for Home Health Quality and
Innovation)
- (Early public comment) The amount of Medicare spending per
beneficiary (MSPB) does not have a direct correlation with the quality of care
provided by a home health agency. The IMPACT Act requires the establishment of
a measure on resource use. Although MSPB may provide some useful information
on resource utilization of Medicare providers, it should not be used as the
sole resource use measure or to draw assumptions on quality of care on its
own. In addition, using MSPB as a quality measure could negatively impact
access to home health care for certain high risk patient populations as
providers are incented to avoid “high cost” patients in order to achieve
favorable scores on the measure.. Further, with HHPPS, efficient use of
resources in home health is better measured by visits per episode for like
patients, since the amount of Medicare spending for the 60 day episode of care
would be the same regardless of the resources used beyond four visit LUPAs.
The only variance would be for any Medicare spending in the 30 day post
discharge period for this measure. Finally, we strongly believe that NQF
should emphasize that MSPB, to the extent that it has any ultimate relevance
in patient assessment or payment models, should never be used as the sole
measure of value or quality. (Submitted by: National Association for Home
Care & Hospice (NAHC))
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program: Hospital Inpatient Quality Reporting and EHR Incentive Program;
MUC ID: MUC15-1135) |
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- The AHA/ASA supports the MAPs recommendation and appreciates the efforts
of CMS to refine the risk model by exploring the use of new data sources to
create a hybrid model that incorporates the anticipated new ICD-10 code for
NIHSS combined with clinical data from EHRs. As noted in our comments above,
we believe that all three of the revised measures offered as options should
improve CMS’ ability to accurately classify hospital performance and to limit
the risk of unintended adverse effects on patient care. (Submitted by:
American Heart Association)
- We agree that mortality is not the most meaningful outcome for stroke
patients and would prefer measures assessing cognitive and functional
outcomes. However, we support this measure as it adjusts the existing measure
for stroke severity. We are unsure if the stroke severity scale can be
captured consistently across EHR products. CEHRT requirements will need to
incorporate the elements of this measure prior to implementation. (Submitted
by: Premier)
- We tentatively support this as a future measure as the electronic format
is premature at this time. We recommend deferring this metric until hospitals
have successfully demonstrated their ability to submit accurate eMeasures
through the IQR program. (Submitted by: Baylor Scott & White
Health)
- Genentech feels strongly that the CMS Stroke 30-Day Mortality and
Readmission measures need to be adjusted for stroke severity and supports
efforts to improve on these measures. We agree with MAP that Mortality may
not be the most meaningful outcome for stroke patients and that there is a
need for outcomes measures that consider cognitive and functional outcomes.
To that end, we believe that stroke outcome measures should if possible align
to those outcomes most frequently measured in stroke clinical trials such as
the modified Rankin Scale and NIHSS scale, not only at patient discharge but
also after a follow up period, for example 30 and 90 days after stroke.
(Submitted by: Genentech)
- Genentech feels strongly that the CMS Stroke 30-Day Mortality and
Readmission measures need to be adjusted for stroke severity and supports
efforts to improve on these measures. We agree with MAP that Mortality may
not be the most meaningful outcome for stroke patients and that there is a
need for outcomes measures that consider cognitive and functional outcomes.
To that end, we believe that stroke outcome measures should if possible align
to those outcomes most frequently measured in stroke clinical trials such as
the modified Rankin Scale and NIHSS scale, not only at patient discharge but
also after a follow up period, for example 30 and 90 days after stroke.
(Submitted by: Genentech)
- CAPC urges the MAP to change its preliminary recommendation for MUC15-1135
from “Conditional Support” for inclusion in the Hospital Inpatient Quality
Reporting program (conditional pending NQF review and endorsement) to “Do Not
Support”. Schwarze et al. (2014) noted that the use of 30-day mortality
measures can inhibit the use of palliative services and fail to accommodate
the wishes of patients who would prefer death over prolonged life-sustaining
treatment. As proposed, this measure does not provide for consideration of a
patient’s goals of care – including the decision to withdraw life-sustaining
treatment – in setting of severe stroke. Inclusion of this measure in the HIQR
could create perverse incentives to keep patients alive despite their wishes;
it is easy to keep someone alive on a percutaneous endoscopic gastronomy tube
for a long period of time following acute stroke. This measure could also
potentially inhibit palliative care referral, as some providers may fear the
consequences of patients choosing to pursue comfort-related goals. We strongly
urge MAP to reconsider its position on this measure, and reiterate the MAP’s
suggestion to consider cognitive or functional outcomes such as impaired
capacity. (Submitted by: Center to Advance Palliative Care)
- We disagree with MAP’s recommendation to conditionally support this
measure and urge the MAP NOT to support this mortality measure. The use of
30-day mortality measures can inhibit the use of palliative services and fail
to accommodate the wishes of patients who would prefer death over prolonged
life-sustaining treatment. As proposed, this measure does not provide for
consideration of a patient’s goals of care – including the decision to
withdraw life-sustaining treatment – in setting of severe stroke. Inclusion of
this measure in the HIQR could create perverse incentives to keep patients
alive despite their wishes. This measure could also potentially inhibit
palliative care referral, as some providers may fear the consequences of
patients choosing to pursue comfort-related goals. We strongly urge MAP to
reconsider its position on this measure, and reiterate the MAP’s suggestion to
consider cognitive or functional outcomes such as impaired capacity. If the
MAP does proceed with recommending conditional support of this measure, at the
very least there should be an exclusion for both hospice patients and those
who opt to receive primarily palliative care. It is equally important to
include "discharged to hospice" as part of the exclusion criteria as it is to
include “admitted from hospice.” Hospitals should not be penalized for the
mortality of patients discharged to hospice or this will set up a disincentive
to discharge patients from hospital to hospice. (Submitted by: American
Academy of Hospice and Palliative Medicine)
- GNYHA does not support addition of this measure in the Hospital Inpatient
Quality Reporting Program. While GNYHA supports a patient safety focus on
improved management and outcome for acute ischemic stroke, mortality is not
the most meaningful stroke-related outcome to track. Furthermore, currently
certified electronic health records (EHR) still do not reliably capture and
calculate electronic measures. GNYHA fully supports inclusion of risk
adjustment variables for this measure however we are concerned with the use
and quality of EHR data to conduct the risk adjustment. The data points
required to calculate this and other electronic clinical quality measures are
not currently readily and consistently available within the EHR. GNYHA is also
concerned that the measure has a pending NQF endorsement and agrees with MAP’s
request for CMS to consider a phased approach with respect to implementation
to avoid multiple versions of the same measure across its quality programs.
(Submitted by: Greater New York Hospital Association)
- (Early public comment)As with all mortality measures, Intermountain
has found the "all cause" mortality difficult to do performance improvement
on. Specifically, our providers would prefer a mortality related to the
initial disease process. (Submitted by: Intermountain
Healthcare)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program: End-Stage Renal Disease Quality
Incentive Program; MUC ID: MUC15-1136) |
- MUC 15-1136—Measurement of Phosphorus Concentration. KCP concurs with the
MAP recommendation to support MUC 15-1136, which includes plasma as an
acceptable substrate—a change sought and supported by KCP. (Submitted by:
Kidney Care Partners)
- NKF agrees this is an important area to measure and that it is consistent
with the KDOQI guidelines. Measuring phosphorus concentration provides
meaningful and actionable information to patients of all ages and their
healthcare professionals. NKF appreciates that this measure is being extended
to include the pediatric population. Dialysis patients (and their families)
are educated by the dialysis facility care team on reducing the amount of
phosphorus they consume and on taking their phosphorus binders. Measuring
phosphorus is important to facilitate shared decision making and patient
self-management. While NKF questions whether there is a current gap in the
care of dialysis patients that this measure would aim to improve, we note that
current statute also requires that the end-stage renal disease (ESRD) quality
incentive program (QIP) include measures of bone and mineral metabolism. Until
a composite measure of phosphorus, calcium and intact parathyroid hormone
(iPTH) can be developed, NKF supports this measure for use as a reporting
measure in the QIP. (Submitted by: National Kidney Foundation)
- Measurement of Phosphorus Concentration ASN supports this measure and
thanks NQF for including it in this year’s MAP. (Submitted by: American
Society of Nephrology (ASN))
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- We are concerned about the quality of the studies that informed this
measure. This is based on observational data without any RCT evidence.
(Submitted by: Johns Hopkins Armstrong Institute for Patient Safety and
Quality)
- (Early public comment)MUC 15-1136—Measurement of Phosphorus
Concentration. MUC 15-1136 differs from the measure finalized by CMS for the
QIP in PY 2017 by including plasma as an acceptable substrate—a change sought
and supported by KCP and that has been finalized for PY 2018. KCP supports
MUC 15-1136. (Submitted by: Kidney Care Partners)
(Program: Hospital Value-Based
Purchasing Program; MUC ID: MUC15-1143) |
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- While SHM supports the concept of assessing costs around specific clinical
conditions, we have concerns about cases in this measure overlapping with
other measures, and therefore penalizing hospitals repeatedly for the same
costs. We believe that condition-specific cost measures may ultimately provide
more useful and actionable information for hospitals and hospitalists, however
use of this measure in a penalty program is not appropriate at this time. In
addition, as many of the controllable costs in this measure cross care
settings, we caution that the implementation or future iterations of this
measure must not inadvertently penalize smaller or less well-resourced
institutions that may not be able to influence or control this spending.
(Submitted by: Society of Hospital Medicine)
- ACS has concerns with the construction of the cellulitis clinical
episode-based payment measure because this condition is extremely broad with
varying levels of severity. Due to the broad nature of cellulitis, this
measure lacks reliability because it is difficult to define the extent of
cellulitis in enough detail. Cellulitis is inherently difficult to identify
and varies across comorbid conditions. Patients with diabetes further
confound cases of cellulitis since these patients are immunocompromised.
Because of the variation, a severe case of cellulitis can result in a long
hospital stay, whereas a limited case may be treated at home. This is
especially relevant to the clinical episode-based payment measure because the
episode is defined as 30 days after discharge. In other words, the cost of
mild cellulitis treated at home should not be compared to a more severe case
in an immunocompromised patient with a long hospital stay. In summary, ACS
believes this measure includes varying patient and clinical circumstances that
are not homogeneous and therefore difficult to risk adjust. Therefore, this
measure should not be used for accountability purposes. We also we believe
variation across cellulitis could be warranted and should be rewarded not
penalized. (Submitted by: American College of Surgeons)
- We agree with MAP, this measure overlaps with MSPB and would create
uneccessary duplication in the program. (Submitted by: Premier)
- GNYHA agrees with MAP’s decision to not support this measure for adoption
in the VBP Program. GNYHA previously submitted comments on these measure,
noting that clinical management for urinary tract infections, cellulitis and
gastrointestinal hemorrhage can vary based on the array of underlying
illnesses and other factors that contribute to a patient’s response to
treatment. Therefore, the payment per episode for these conditions could also
vary greatly. A publicly reported standard metric would not offer a clear
understanding of differences in quality of care based on payment by episode.
(Submitted by: Greater New York Hospital Association)
- (Early public comment)"This is an acute condition with a
heteregenous population and a wide degree of standards of care; risk
adjustment does not appear to account for this. The condition-specific payment
meaures overlap with the Medicare Spending Per Beneficiary measure that is
currently in HIQR and HVBP; adding segments of MSPB creates unecessary
duplication in the programs. While these payment measures would create
alignment with the physician value-modifier and later MIPS; MACRA requires
establishment of patient relationship categories and codes to attribute
patients and episodes to providers, this significantly change could the way
the episode groupers are implemented and lead to lack of alignment between the
hospital and physician specifications. Accordingly, the measures should not be
added to hospital programs in advance of finalizing the measures for physician
programs. Additionally, we have ongoing concerns about these measures. First,
measures of Federal spending are not real indicators of “value” for
beneficiaries as they neither capture the quality of care, nor are paired with
measures that do so. Moreover, the measures do not give beneficiaries a sense
of their financial obligation so they are not useful for public reporting and
beneficiary engagement purposes. Also, the spending measures are cross-cutting
measures that are not appropriate for evaluating care exclusively in the
inpatient setting. CMS data has previously shown that variation in total
Medicare payments for episodes are primarily due to readmission rates and
post-acute care. Post-acute care use varies due to wide ranging differences in
local market availability of these services and patterns of care, which are
not within the hospital’s control." (Submitted by: Premier)
- (Early public comment)This measure aligns with alternative payment
models that encourage providers to focus on the continuum of care, rather than
just the clinical outcomes in a particular site of care. We believe it will
encourage hospitals to consider the most appropriate wound care management
approaches for these vulnerable patients. (Submitted by: Smith & Nephew
)
- (Early public comment)The AMA continues to have several concerns
regarding the clinical episode-based payment measures. Information on the
reliability and validity of this measure is not yet available. In general, it
is difficult to evaluate whether the measure is appropriate for adoption in
light of this lack of information. Data on the reliability of the measure
specifications is needed. In addition and perhaps more importantly, the
validity of these measures must be demonstrated prior to implementation in any
pay-for-performance program. Finally, continuing to include cost of care
measures in the absence of accompanying quality measures addressing the same
clinical condition is contrary to NQF recommendations and the intent of the
value-based programs. Because the proposed measure does not demonstrate the
linkage of expenditures as a result of quality achieved, the proposed measure
will not provide actionable information that a hospital and physician could
use to identify how to make improvements. In summary, applying this measure
in any pay-for-performance program without adequate review and testing would
have significant negative unintended consequences. Ultimately, the AMA is
hopeful that with some refinements, tying costs and quality to well-defined
episodes of care will provide a more fair and accurate view of physician
performance than the measures that CMS is currently using in the hospital and
physician value-based purchasing programs. We do not think that the measures
proposed in this rule have been sufficiently refined; however, we also are
opposed to layering condition-specific measures on top of the broad total cost
measures CMS is now using. The AMA has expressed frequent objections to CMS’
use of overlapping physician measures that all pick up the costs of a cohort
of chronically ill patients with significant health care costs that make
physicians who treat these patients more likely than others to face penalties
under the value-based modifier. We are concerned that the new episode measures
proposed will intensify similar problems on the hospital side and could create
barriers to care for some patients. The fact that these measures have not yet
been endorsed by NQF and that we do not know their final form adds to our
discomfort and suggests that CMS is not practicing the transparency that it
preaches. Ultimately, the AMA is hopeful that with some refinements, tying
costs and quality to well-defined episodes of care will provide a more fair
and accurate view of physician performance than the measures that CMS is
currently using in the hospital and physician value-based purchasing programs.
We do not think that the measures proposed in this rule have been sufficiently
refined; however, we also are opposed to layering condition-specific measures
on top of the broad total cost measures CMS is now using. The AMA has
expressed frequent objections to CMS’ use of overlapping physician measures
that all pick up the costs of a cohort of chronically ill patients with
significant health care costs that make physicians who treat these patients
more likely than others to face penalties under the value-based modifier. We
are concerned that the new episode measures proposed will intensify similar
problems on the hospital side and could create barriers to care for some
patients. The fact that these measures have not yet been endorsed by NQF and
that we do not know their final form adds to our discomfort and suggests that
CMS is not practicing the transparency that it preaches. (Submitted by:
American Medical Association)
- (Early public comment)This is an interesting measure that could
allow hospitals to better understand their resource utilization and
effectiveness for this common clinical syndrome. A strength of this measure
is the ability to separately assess patients with more complicated disease or
more complicated underlying medical risk factors (e.g., diabetics, pressure
ulcers). The information provided in the rationale section does not provide
any evidence of or reference to validation of the algorithm that would be used
to identify payments that are related to cellulitis. That would be critical
to the acceptance of this measure. (Submitted by: The Society for Healthcare
Epidemiology of America)
(Program: Hospital Value-Based Purchasing Program; MUC ID: MUC15-1144)
|
- FAH supports the workgroup's recommendation and rationale. (Submitted by:
Federation of American Hospitals)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- While SHM supports the concept of assessing costs around specific clinical
conditions, we have concerns about cases in this measure overlapping with
other measures, and therefore penalizing hospitals repeatedly for the same
costs. We believe that condition-specific cost measures may ultimately provide
more useful and actionable information for hospitals and hospitalists, however
use of this measure in a penalty program is not appropriate at this time. In
addition, as many of the controllable costs in this measure cross care
settings, we caution that the implementation or future iterations of this
measure must not inadvertently penalize smaller or less well-resourced
institutions that may not be able to influence or control this spending. We
also have concerns this measure may not adequately adjust for patients with GI
bleeds and liver disease, as spending on these patients would categorically
higher given the spectrum of illness and higher risk severity. (Submitted by:
Society of Hospital Medicine)
- We agree with MAP, this measure overlaps with MSPB and would create
unnecessary duplication in the program. (Submitted by: Premier)
- ACS has concerns with the construction of the gastrointestinal intestinal
(GI) hemorrhage clinical episode-based payment measure because this condition
is extremely broad with varying levels of severity. Due to the broad nature of
GI hemorrhage, this measure lacks reliability because it is difficult to
define the extent of hemorrhage in enough detail. GI hemorrhage is similar to
cellulitis in that it is extremely broad with varying levels of severity. In
an example of a minor GI hemorrhage case, a patient may have a nasogastric
tube that is decompressing their stomach post-op that begins to show traces of
blood. However, the patient may suddenly experience severe gastritis with
hemorrhage requiring transfusion, in which case GI hemorrhage becomes severe.
Furthermore, lower GI bleed does not include conditions such as hemorrhoids or
inflammatory bowel diseases, which bleed a lot compared to diagnoses with
minimal bleeding. In summary, ACS believes this measure includes varying
patient and clinical circumstances that are not homogeneous and therefore
difficult to risk adjust and therefore should not be used for accountability
purposes. We also we believe variation in GI hemorrhage could be warranted
and should be rewarded not penalized. (Submitted by: American College of
Surgeons)
- GNYHA agrees with MAP’s decision to not support this measure for adoption
in the VBP Program. GNYHA previously submitted comments on these measure,
noting that clinical management for urinary tract infections, cellulitis and
gastrointestinal hemorrhage can vary based on the array of underlying
illnesses and other factors that contribute to a patient’s response to
treatment. Therefore, the payment per episode for these conditions could also
vary greatly. A publicly reported standard metric would not offer a clear
understanding of differences in quality of care based on payment by episode.
(Submitted by: Greater New York Hospital Association)
- (Early public comment)ASGE supports this measure concept and would
welcome the opportunity to consult with the measure developer. More specific
comments are as follows. (1) Reliability analysis should be conducted and
reported with transparency before the measure is adapted; this should include
sensitivity analysis (i.e., effect of different assumptions). (2) A minimum
number of cases for reporting needs to be fairly large in order to include a
broad enough spectrum of cases. (3) Risk-adjustment is included in numerator
but methodology needs to be clear. (4)"Spending" should refer to
reimbursement/allowances rather than charges. (5) Definition of GI hemorrhage
needs to be clear. If based on ICD10, it still needs to have the rules clear
(i.e., how do coders decide this is or isn't a GI hemorrhage, versus for
example hemorrhoid bleeding). (6) Methodology appears to only include
inpatient admissions. If true, it would do injustice to cases handled as ER or
observation or hospital-based urgent care. (Submitted by: American Society for
Gastrointestinal Endoscopy)
- (Early public comment)"This is an acute condition with a
heteregenous population and a wide degree of standards of care; risk
adjustment does not appear to account for this. The condition-specific payment
meaures overlap with the Medicare Spending Per Beneficiary measure that is
currently in HIQR and HVBP; adding segments of MSPB creates unecessary
duplication in the programs. While these payment measures would create
alignment with the physician value-modifier and later MIPS; MACRA requires
establishment of patient relationship categories and codes to attribute
patients and episodes to providers, this significantly change could the way
the episode groupers are implemented and lead to lack of alignment between the
hospital and physician specifications. Accordingly, the measures should not be
added to hospital programs in advance of finalizing the measures for physician
programs. Additionally, we have ongoing concerns about these measures. First,
measures of Federal spending are not real indicators of “value” for
beneficiaries as they neither capture the quality of care, nor are paired with
measures that do so. Moreover, the measures do not give beneficiaries a sense
of their financial obligation so they are not useful for public reporting and
beneficiary engagement purposes. Also, the spending measures are cross-cutting
measures that are not appropriate for evaluating care exclusively in the
inpatient setting. CMS data has previously shown that variation in total
Medicare payments for episodes are primarily due to readmission rates and
post-acute care. Post-acute care use varies due to wide ranging differences in
local market availability of these services and patterns of care, which are
not within the hospital’s control." (Submitted by: Premier)
- (Early public comment)The AMA continues to have several concerns
regarding the clinical episode-based payment measures. Information on the
reliability and validity of this measure is not yet available. In general, it
is difficult to evaluate whether the measure is appropriate for adoption in
light of this lack of information. Data on the reliability of the measure
specifications is needed. In addition and perhaps more importantly, the
validity of these measures must be demonstrated prior to implementation in any
pay-for-performance program. Finally, continuing to include cost of care
measures in the absence of accompanying quality measures addressing the same
clinical condition is contrary to NQF recommendations and the intent of the
value-based programs. Because the proposed measure does not demonstrate the
linkage of expenditures as a result of quality achieved, the proposed measure
will not provide actionable information that a hospital and physician could
use to identify how to make improvements. In summary, applying this measure
in any pay-for-performance program without adequate review and testing would
have significant negative unintended consequences. Ultimately, the AMA is
hopeful that with some refinements, tying costs and quality to well-defined
episodes of care will provide a more fair and accurate view of physician
performance than the measures that CMS is currently using in the hospital and
physician value-based purchasing programs. We do not think that the measures
proposed in this rule have been sufficiently refined; however, we also are
opposed to layering condition-specific measures on top of the broad total cost
measures CMS is now using. The AMA has expressed frequent objections to CMS’
use of overlapping physician measures that all pick up the costs of a cohort
of chronically ill patients with significant health care costs that make
physicians who treat these patients more likely than others to face penalties
under the value-based modifier. We are concerned that the new episode measures
proposed will intensify similar problems on the hospital side and could create
barriers to care for some patients. The fact that these measures have not yet
been endorsed by NQF and that we do not know their final form adds to our
discomfort and suggests that CMS is not practicing the transparency that it
preaches. Ultimately, the AMA is hopeful that with some refinements, tying
costs and quality to well-defined episodes of care will provide a more fair
and accurate view of physician performance than the measures that CMS is
currently using in the hospital and physician value-based purchasing programs.
We do not think that the measures proposed in this rule have been sufficiently
refined; however, we also are opposed to layering condition-specific measures
on top of the broad total cost measures CMS is now using. The AMA has
expressed frequent objections to CMS’ use of overlapping physician measures
that all pick up the costs of a cohort of chronically ill patients with
significant health care costs that make physicians who treat these patients
more likely than others to face penalties under the value-based modifier. We
are concerned that the new episode measures proposed will intensify similar
problems on the hospital side and could create barriers to care for some
patients. The fact that these measures have not yet been endorsed by NQF and
that we do not know their final form adds to our discomfort. (Submitted by:
American Medical Association)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program:
Hospital Value-Based Purchasing Program; MUC ID: MUC15-1145)
|
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- While SHM supports the concept of assessing costs around specific clinical
conditions, we have concerns about cases in this measure overlapping with
other measures, and therefore penalizing hospitals repeatedly for the same
costs. We believe that condition-specific cost measures may ultimately provide
more useful and actionable information for hospitals and hospitalists, however
use of this measure in a penalty program is not appropriate at this time. In
addition, as many of the controllable costs in this measure cross care
settings, we caution that the implementation or future iterations of this
measure must not inadvertently penalize smaller or less well-resourced
institutions that may not be able to influence or control this spending. We
also have concerns about the risk adjustment methodology and whether or not it
is able to account for cost differences in treatments for UTIs with different
bacterial etiology that may require more specific or specialized antibiotics
(e.g., MDR bacteria colonization or infection). (Submitted by: Society of
Hospital Medicine)
- We agree with MAP, this measure overlaps with MSPB and would create
unnecessary duplication in the program. (Submitted by: Premier)
- ACS has concerns with the construction of the kidney/urinary tract
infection clinical episode-based payment measure because this condition is
extremely broad with varying levels of severity. Due to the broad nature of
kidney/urinary tract infection, this measure lacks reliability because it is
difficult to define the extent of infection in enough detail. (Submitted by:
American College of Surgeons)
- GNYHA agrees with MAP’s decision to not support this measure for adoption
in the VBP Program. GNYHA previously submitted comments on these measure,
noting that clinical management for urinary tract infections, cellulitis and
gastrointestinal hemorrhage can vary based on the array of underlying
illnesses and other factors that contribute to a patient’s response to
treatment. Therefore, the payment per episode for these conditions could also
vary greatly. A publicly reported standard metric would not offer a clear
understanding of differences in quality of care based on payment by episode.
(Submitted by: Greater New York Hospital Association)
- (Early public comment)"This is an acute condition with a
heteregenous population and a wide degree of standards of care; risk
adjustment does not appear to account for this. The condition-specific payment
meaures overlap with the Medicare Spending Per Beneficiary measure that is
currently in HIQR and HVBP; adding segments of MSPB creates unecessary
duplication in the programs. While these payment measures would create
alignment with the physician value-modifier and later MIPS; MACRA requires
establishment of patient relationship categories and codes to attribute
patients and episodes to providers, this significantly change could the way
the episode groupers are implemented and lead to lack of alignment between the
hospital and physician specifications. Accordingly, the measures should not be
added to hospital programs in advance of finalizing the measures for physician
programs. Additionally, we have ongoing concerns about these measures. First,
measures of Federal spending are not real indicators of “value” for
beneficiaries as they neither capture the quality of care, nor are paired with
measures that do so. Moreover, the measures do not give beneficiaries a sense
of their financial obligation so they are not useful for public reporting and
beneficiary engagement purposes. Also, the spending measures are cross-cutting
measures that are not appropriate for evaluating care exclusively in the
inpatient setting. CMS data has previously shown that variation in total
Medicare payments for episodes are primarily due to readmission rates and
post-acute care. Post-acute care use varies due to wide ranging differences in
local market availability of these services and patterns of care, which are
not within the hospital’s control." (Submitted by: Premier)
- (Early public comment)The AMA continues to have several concerns
regarding the clinical episode-based payment measures. Information on the
reliability and validity of this measure is not yet available. In general, it
is difficult to evaluate whether the measure is appropriate for adoption in
light of this lack of information. Data on the reliability of the measure
specifications is needed. In addition and perhaps more importantly, the
validity of these measures must be demonstrated prior to implementation in any
pay-for-performance program. Finally, continuing to include cost of care
measures in the absence of accompanying quality measures addressing the same
clinical condition is contrary to NQF recommendations and the intent of the
value-based programs. Because the proposed measure does not demonstrate the
linkage of expenditures as a result of quality achieved, the proposed measure
will not provide actionable information that a hospital and physician could
use to identify how to make improvements. In summary, applying this measure
in any pay-for-performance program without adequate review and testing would
have significant negative unintended consequences. Ultimately, the AMA is
hopeful that with some refinements, tying costs and quality to well-defined
episodes of care will provide a more fair and accurate view of physician
performance than the measures that CMS is currently using in the hospital and
physician value-based purchasing programs. We do not think that the measures
proposed in this rule have been sufficiently refined; however, we also are
opposed to layering condition-specific measures on top of the broad total cost
measures CMS is now using. The AMA has expressed frequent objections to CMS’
use of overlapping physician measures that all pick up the costs of a cohort
of chronically ill patients with significant health care costs that make
physicians who treat these patients more likely than others to face penalties
under the value-based modifier. We are concerned that the new episode measures
proposed will intensify similar problems on the hospital side and could create
barriers to care for some patients. The fact that these measures have not yet
been endorsed by NQF and that we do not know their final form adds to our
discomfort and suggests that CMS is not practicing the transparency that it
preaches. Ultimately, the AMA is hopeful that with some refinements, tying
costs and quality to well-defined episodes of care will provide a more fair
and accurate view of physician performance than the measures that CMS is
currently using in the hospital and physician value-based purchasing programs.
We do not think that the measures proposed in this rule have been sufficiently
refined; however, we also are opposed to layering condition-specific measures
on top of the broad total cost measures CMS is now using. The AMA has
expressed frequent objections to CMS’ use of overlapping physician measures
that all pick up the costs of a cohort of chronically ill patients with
significant health care costs that make physicians who treat these patients
more likely than others to face penalties under the value-based modifier. We
are concerned that the new episode measures proposed will intensify similar
problems on the hospital side and could create barriers to care for some
patients. The fact that these measures have not yet been endorsed by NQF and
that we do not know their final form adds to our discomfort. (Submitted by:
American Medical Association)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program: End-Stage Renal
Disease Quality Incentive Program; MUC ID: MUC15-1165) |
- MUC 15-1165—Proportion of Patients with Hypercalcemia. KCP concurs with
the MAP recommendation of “Do not support.” KCP concurs with the rationale
that this measure is not the best to impact patient outcomes in the bone
mineral metabolism domain. NQF also recommended the measure for Reserve
Status because it is topped out; KCP concurred with this recommendation.
(Submitted by: Kidney Care Partners)
- While this measure is consistent with KDOQI guidelines the National Kidney
Foundation agrees with the Measures Application Partnership (MAP) that
performance on this measure is high and that maintaining it as an outcomes
measure in the QIP is unlikely to foster further improvements in outcomes for
dialysis patients. However, we recognize that measuring hypercalcemia, like
phosphorus, does provide meaningful and actionable information to patients and
their healthcare professionals. NKF has made recommendations that CMS use a
hypercalcemia reporting measure, as it has in the past, until such a time
where a composite measure of phosphorus, calcium and intact parathyroid
hormone (iPTH) can be developed. Under the current QIP scoring methodology,
outcomes measures weigh more heavily than process measures. NKF believes
removing hypercalcemia from the outcomes measures score better encourages
facilities to focus on outcomes measures that have room for quality
improvement. (Submitted by: National Kidney Foundation)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- Proportion of Patients with Hypercalcemia (NQF #1454) The society strongly
opposes this measure and points out that there are sufficient data to show
that it is not a valid performance measure (the EVOLVE trial assessed
cinacalcet versus placebo in people with high normal and high serum calcium
levels and found no significant difference in hard clinical outcomes in
intention to treat analyses) and there are no data to show that it is a safety
measure aside from trying to fit something into a safety measure column.
Currently this measure is a weak measure of drivers of calcium levels (e.g.,
phosphate binder efficacy, dialysate calcium concentration, etc) and
specifically supports the use of an expensive medication, cinacalcet, which
has substantial gastrointestinal side effects, major cost implications and
limited evidence supporting a benefit in hard outcomes. Given the exclusion
of this agent from the bundle, dialysis facilities have no economic
disincentive to the prescription of this agent, and therefore there is no
cogent role for including a measure that financially disincentivizes
cinacalcet non-use. Accordingly, NQF 1454 is not a patient-centered measure
as it encourages us to prescribe an agent that may be poorly tolerated, with
twice as many participants in the cinacalcet group noting nausea and vomiting.
We posit that cinacalcet will not be under prescribed regardless of the
presence of this measure and therefore emphasize that a measure pushing
cinacalcet prescription (as is described in the 2015 final rule as
justification for its inclusion in the QIP) is unwarranted. (Submitted by:
American Society of Nephrology (ASN))
- (Early public comment)MUC 15-1165—Proportion of Patients with
Hypercalcemia. The MUC list indicates this measure is NQF 1454, modified to
include plasma as an acceptable substrate, a change sought by KCP. We note,
however that KCP has raised concerns that NQF 1454 is not the best measure for
the bone mineral metabolism domain to impact patient outcomes. NQF also has
recommended the measure for Reserve Status because it is topped out; KCP
concurred with this recommendation. (Submitted by: Kidney Care
Partners)
(Program:
End-Stage Renal Disease Quality Incentive Program; MUC ID: MUC15-1167)
|
- The National Kidney Foundation supports this measure in the QIP. A recent
study suggests this measure is actionable by estimating more frequent
nephrology visits after hospital discharge reduced the risk of readmission
(Erickson KF, Winkelmayer WC, Chertow GM, Bhattacharya J. Physician Visits and
30-Day Hospital Readmissions in Patients Receiving Hemodialysis. Journal of
the American Society of Nephrology?: JASN. 2014;25(9):2079-2087). In an
accompanying editorial, two leaders in dialysis care emphasized the importance
of the availability of the discharge summary and medication reconciliation to
optimize the impact of nephrology follow up visits in the dialysis clinic.
However, NKF remains concerned about the measure on patient access as well as
the absence of exclusions of conditions for causes of readmissions that are
not actionable by the dialysis facility staff. NKF is pleased that CMS plans
to move forward with a study on patient access to dialysis care with respect
to this measure. Specifically, we request that CMS evaluate the combination
effects of socioeconomic status and demographics to determine if they are
influencing poor performance on the measure. (Submitted by: National Kidney
Foundation)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- Standardized Readmission Ratio (SRR) for dialysis facilities ASN supports
the concept of the proposed SRR for dialysis facilities and believes this
measure has great potential for improving patient care. ASN is pleased to see
that the steward has attempted to look at real time data in order to adjust
the expected number of patients being readmitted in the denominator. However,
the society has several questions and concerns regarding implementation of the
proposed SRR measure and believes these concerns must be clarified before the
measure is finalized. Of greatest concern is defining the denominator by the
number of discharges rather than by the total number of beneficiaries. •
Denominator Total ASN believes that the number of discharges should not be the
determinant of the denominator, but rather that the number of readmissions
should be based on the total number of patients treated in a facility. The
society believes that this structure would be far more representative of
overall quality of care and far less vulnerable to the effect that one or two
complex patients could have on the SRR of an otherwise outstanding facility.
Critically, as the ASN has outlined in detail in previous position statements,
the SRR cannot be conceptualized independent of the SHR, reflecting that a
small number of patients frequently readmitted can result in a facility
appearing to be poor performing if that facility has a very low overall
hospitalization rate. This point was made by the chairperson of the TEP
charged with developing this measure when he withdrew his support for the
measure. (Submitted by: American Society of Nephrology (ASN))
- MUC 15-1167—Standardized Readmission Ratio (SRR) for Dialysis Facilities.
KCP does not concur with the MAP recommendation of “Conditional support.” The
information provided with the MUC list lacks the specificity required to fully
evaluate the measure. Absent this information, KCP cannot support the
measure, even conditionally, because we cannot evaluate it. Again, it is
essential that the full details of the risk model and specifications be made
transparent and available for comment during the MAP process through the CMS
list or an external link. Version details are critical: We know, for
example, that CMS stipulated to changes in the SRR measure (NQF 2496) that had
been recommended by KCP and others in the renal community on the issue of when
a readmission would count against a facility. Despite this agreement, the
most recent QIP Proposed Rule did not account for these changes, to which KCP
again called attention. Because no details on the risk model were available
with the MUC list, we are unable to determine what version of the measure is
being proposed and/or if new modifications not previously encountered are now
included in the MUC. Additionally, KCP opposes use of the SRR in the QIP
until CMS’ SRR/Standardized Transfusion Ratio Impact Study, included in its
Final Rule, has been completed and assessed. (Submitted by: Kidney Care
Partners)
- Comments on Draft Report of Hospital Workgroup In the section that
addresses the ESRD Quality Incentive Program (page 12), KCP has two comments.
1. The draft report notes: MAP also supported updates to two additional
measures with the condition that NQF review the measure updates and examine
SDS factors as part of the review. KCP recommends this sentence be clarified
to indicate the specific measures, and that not only must review occur, but
endorsement also must occur: MAP also supported updates to two additional
measures— Standardized Readmission Ratio for Dialysis Facilities (MUC 15-1167)
and Standardized Hospitalization Ratio (MUC 15-693)— with the condition that
the measures maintain endorsement following NQF review of the measure updates
and examination of SDS factors as part of the review. (Submitted by: Kidney
Care Partners)
- We are concerned with solely measuring readmissions, without considering
the competing risk of death. (Submitted by: Johns Hopkins Armstrong Institute
for Patient Safety and Quality)
- (Early public comment)MUC 15-1167—Standardized Readmission Ratio
for Dialysis Facilities. We note that NQF 2496 is the existing NQF-endorsed
SRR. CMS makes no reference to this (although it indicates NQF numbers for
other measures). We further note that the information provided by CMS in the
MUC list lacks the specificity required to evaluate it. Again, it is
essential that the full details of the risk model and specifications be made
transparent and available for comment during the MAP process through the CMS
list or an external link. We know, for example, that CMS stipulated to
changes in NQF 2496 that had been recommended by KCP and others in the renal
community on the issue of when a readmission would count against a facility.
Despite this agreement, the most recent QIP Proposed Rule did not account for
these changes, to which KCP again called attention. Because no details are
available here, the public is unable to determine whether CMS has made the
modifications it agreed to in order to receive NQF endorsement. Additionally,
KCP opposes use of the SRR in the QIP until CMS’ SRR/Standardized Transfusion
Ratio Impact Study has been completed and assessed. (Submitted by: Kidney Care
Partners)
(Program: Merit-Based Incentive Payment System (MIPS); MUC
ID: MUC15-1169) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Indian Health
Service)
- The New York City Department of Health and Mental Hygiene (DOHMH) is a
recognized leader in addressing the public health crisis of opioid analgesic
overdose deaths. After implementing a multi-pronged response to the crisis,
including promoting public awareness, access to treatment, overdose
prevention, and judicious prescribing, the rate of opioid analgesic overdose
deaths decreased 29% in NYC’s hardest hit county. We are encouraged by this
success, but acknowledge that more work needs to be done with respect to
promoting judicious prescribing practices, which the proposed measure will
advance. DOHMH supports CMS’s focus on limiting both high-dose prescribing and
opioid therapy for chronic non-end-of-life pain, since these practices are
associated with increased risk of opioid use disorder and overdose, and lack
evidence of effectiveness (see References below). Below are some key
recommendations for modifying this measure further: 1. We suggest separating
the proposed measure into two separate measures: one measure addressing
high-dose prescribing and a second measure addressing opioid therapy for
chronic non-end-of-life pain). We advocate for the reduction of each of these
practices and believe that combining the practices in one measure may result
in a significantly smaller impact 2. We find that many physicians do not know
how to calculate morphine milligram equivalents (MMEs). Therefore, we
recommend making available a tool available to calculate this value, which
will directly serve to support the goal of this measure to reduce opioid
overuse. One option is OpioidCalc, DOHMH’s free, mobile app for iOS and
Android that quickly calculates total daily MME based on type of opioid
analgesic, strength, and quantity. When using this mobile app, high-dose
prescriptions result in an alert, indicating an increased risk for overdose.
References *Dunn KM, Saunders KW, Rutter CM, et al. Opioid prescriptions for
chronic pain and overdose: a cohort study. Ann Intern Med. 2010 Jan
19;152(2):85–92. *Bohnert AS, Valenstein M, Bair MJ, et al. Association
between opioid prescribing patterns and opioid overdose-related deaths. JAMA.
2011;305(13):1315–21. *Boscarino JA, Rukstalis MR, Hoffman SN, et al.
Prevalence of prescription opioid-use disorder among chronic pain patients:
comparison of the DSM-5 vs. DSM-4 diagnostic criteria. J Addict Dis.
2011;30(3):185-94. *Trescot AM, Glaser SE, Hansen H, Benyamin R, Patel S,
Manchikanti L. Effectiveness of opioids in the treatment of chronic non-cancer
pain. Pain Physician. 2008 Mar;11(2 Suppl):S181–200. *Martell BA, O'Connor PG,
Kerns RD, et al. Systematic review: opioid treatment for chronic back pain:
prevalence, efficacy, and association with addiction. Ann Intern Med.
2007;146:116–27. *Manchikanti L, Ailinani H, Koyyalagunta D. A systematic
review of randomized trials of long-term opioid management for chronic
non-cancer pain. Pain Physician 2011; 14: 91–121. *Furlan AD,Sandoval JA,
Mailis-Gagnon A, et al. Opioids for chronic noncancer pain: a meta-analysis of
effectiveness and side effects. CMAJ 2006;174:1589–1594. *Noble M, Treadwell
JR, Tregear SJ. Long-term opioid management for chronic noncancer pain.
CochraneDatabase Syst Rev. 2010 Jan 20;(1):CD006605. (Submitted by: New York
City Department of Health and Mental Hygiene)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: American College
of Surgeons)
- AMCP appreciates the focus for measures to help curb the abuse of opioid
medications among Medicare beneficiaries. AMCP, however, has several concerns
with the proposed measures. The measure description of 90 milligrams morphine
equivalent daily dosage and number of prescription threshold are not in
alignment with other opioid measures under CMS' consideration. (Submitted by:
Academy of Managed Care Pharmacy)
- CAPC urges the MAP to change its preliminary recommendation for MUC15-1169
from “Encourage Continued Development” for the inclusion in the Merit-Based
Incentive Payment System (MIPS) to “Do Not Support”. As MIPS is a brand new
quality reporting program that will begin implementation in 2017, NQF and CMS
have a unique opportunity to ensure that the opening slate of measures
captures the quality of care delivered to patients across the spectrum of
illness. This holds especially true for the care provided to the most
seriously ill and vulnerable patients in the system through palliative care
and hospice. While we note that patients who are receiving palliative and
hospice care are excluded from the denominator, we nonetheless think it is
important to ensure that any measures included in quality reporting programs
do not accidentally penalize providers for appropriate use of opioids. We are
concerned that the specifications for this measure are unclear, and including
it in MIPS may create an environment of fear. (Submitted by: Center to Advance
Palliative Care)
- Without a doubt there is a problem with opioid abuse and measures are
certainly needed to target this problem. However, we believe that this
measure, as currently structured, could harm patients suffering from pain more
than it would help curb opioid abuse. As such, we recommend that the MAP NOT
support this measure as currently written. As the MAP notes in their comments,
this measure is both too narrow and too broad. Time and morphine equivalent
dosing (MED) cut-offs for opioids are never going to be a good indicator of
potential aberrant drug-related behavior and there is poor quality evidence
for both. Considerable resources need to be extended toward the development of
valid measures of aberrant drug-related behavior if this is to be an area of
focus. This is also more of a public health concern and tying it to MIPS will
almost certainly result in further primary care providers referring all pain
management out. While we appreciate that the measure excludes palliative care
and hospice patients, we worry that this measure could make it hard for
primary care doctors to provide good primary palliative care. It’s also note
clear what the plan would be for the loads of patients who screen positive for
"potential" opioid overuse. Overall, it is important to ensure that any
measures included in quality reporting programs do not accidentally penalize
providers for appropriate use of opioids. We are concerned that the
specifications for this measure are unclear, and including it in MIPS may
create an environment of fear. (Submitted by: American Academy of Hospice and
Palliative Medicine)
- (Early public comment)While the AMA supports the general concept
that this measure attempts to address-- opioid overuse, we are concerned that
the measure as currently specified is not actionable by the physician. We do
not consider reporting on the number of patients for whom the number and
frequency of opioid prescriptions could be potentially inappropriate to be a
quality measure that accurately reflects a physician's care for patients.
(Submitted by: American Medical Association)
- (Early public comment)Due to the national opioid epidemic, we
respectfully request clarification on the denominator for length of supply and
number of consecutive days. (Submitted by: American Society of Plastic
Surgeons)
- (Early public comment)While TFAH supports addressing the opioid
overuse epidemic in America, including through the Medicare program, we have
several questions regarding this measure. The nonmedical use of prescription
drugs, including opioids, and the corresponding injuries and deaths,
constitute a growing public health crisis. In a TFAH report on how states are
addressing the problem, we recommended, among a range of other steps, that
“all providers should receive education and continued training about
appropriate prescribing of commonly abused medications.” We do believe,
however, that a physician measure related to this topic must be implemented in
a way that appropriately balances limits on overuse with ensuring appropriate
access to pain management. The measure under consideration is defined as
“Patients of the Medicare prescribing provider whose daily morphine equivalent
dose (MED) is greater than 90 mg for at least 90 consecutive days.” It would
be helpful if CMS would provide further information about how this MED was
established. We also note that in a recent update on the Medicare Part D
Overutilization Monitoring System, CMS defines high-risk beneficiaries or
“potential opioid overutilizers” as those with cumulative MED of at least 120
mg for at least 90 consecutive days, (as opposed to 90 MED), and also adds the
criteria that the prescriptions are associated with more than 3 prescribers
and more than 3 pharmacies. Those additional criteria would presumably help
focus the program on beneficiaries whose prescriptions may not be well
coordinated among providers; they are not, however, reflected in the
“Potential Opioid Overuse” measure under consideration. In addition, while
the “Potential Opioid Overuse” measure includes some exceptions, they are
limited, and there is no indication of how “potential” overuse would be
assessed to determine if it is in fact medically inappropriate. We are
concerned that a measure based on the mere “potential” for overuse could have
a chilling effect on legitimate prescribing activities. We would like to see
further clarification, as the process moves along, of how the 90 MED for 90
days measure would be implemented in a way that is based on scientific
consensus and meaningfully reflects prescriber attention to potential opioid
overuse while maintaining appropriate access for pain patients with a
legitimate need for the medications. Relatedly, we note that the current
Physician Quality Reporting System (PQRS), which will be rolled into the new
MIPS program, includes a measure on “Pain Assessment and Followup.” We
strongly urge CMS to maintain this measure in MIPS, and to continue to develop
measures that reflect a meaningful balance between addressing opioid overuse
and assessing legitimate patient need for broad, comprehensive pain treatment
approaches. (Submitted by: Trust for America's Health)
- (Early public comment)Several NRHI members expressed support for
this measure. (Submitted by: Network for Regional Healthcare
Improvement)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program: Merit-Based
Incentive Payment System (MIPS); MUC ID: MUC15-177) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Academy of Managed
Care Pharmacy)
- The American Academy of Dermatology (AAD) encourages MAP to recommend
“conditional support” as the AAD disagrees with the view that this measures
would “not address the totality of care processes for transplant patients.” In
addition, this measure is not solely “focused on dermatologists.” This measure
focuses on a critical aspect of care for transplant recipients With skin
cancer now a frequent cause of morbidity and mortality in transplant patients
because of their immunosuppressed state, transplant patients need regular skin
cancer screenings as early detection is critical to their care. This fact is
not well known amongst clinicians as the focus on transplant patients has
traditionally been on graft rejection and infection. However, because
advancements in medicine have allowed for increased survival time in
transplants patients and serious infection rates are decreasing, skin cancer
has now become one of the primary issues for transplant patients. As such,
because transplant patients are seen be a wide variety of specialists and many
clinicians are skilled in performing total cutaneous skin exams (the measure
also allows for referral to dermatology if the provider is not skilled in
cutaneous exams), this measure becomes a valuable tool to improve the care of
transplant patients and engages all specialties that see transplant patients,
not just dermatology. (Submitted by: American Academy of
Dermatology)
- (Early public comment)We support the inclusion of this measure that
is part of the American Academy of Dermatology (AAD) strategy to provide a
comprehensive quality approach for patients with skin cancer. Including this
measure will further expand performance measurement through the entire skin
cancer care process. Each has been developed to address either a rate
limiting step to quality care or a significant waste/overuse issue This is a
measure of preventive care for people who have received organ transplants.
The life-saving medicines that prevent organ rejection suppress the immune
system, greatly increasing the risk of skin cancer. The chance of developing a
NMSC ranges from 10 to 60 percent at the 5 and 20 year marks post-transplant,
respectively. In organ-transplant recipients, skin cancer tends to be more
aggressive: it grows faster and spreads more quickly. Counseling, screening
and early treatment is critical to limiting the harm of skin cancer. This
measure also fills a critical program need for measures of skin care as there
are only 6 dermatology-specific measures in PQRS and none in the NQS category
of Best Practice of Healthy Living. The current six Dermatology-specific
measures are in Communication and Coordination and Resource Use. (Submitted
by: American Academy of Dermatology)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-178)
|
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- We encourage “conditional support” instead of “encourage continued
development.” This measures addresses gaps in high priority areas: 1)
appropriate use and resource use; and 2) care provided by several surgical
specialties, including plastic surgery and dermatology. Both measures are
fully specified and in testing for reliability, validity and feasibility with
results expected mid 2016. AAD anticipates submitting both measures for
endorsement at the next available opportunity after completion of testing.
Given the long timeframes for development and testing it is difficult to
synchronize testing with the scheduling of endorsement review committees and
CMS timelines for the consideration of measures for PQRS/MIPs. This mismatch
means that, it these measures are not “supported” now, they would need to
wait a full year for consideration for MIPS 2018. Meanwhile there are only 6
dermatology-specific measures in PQRS, none on basal or squamous cell
carcinoma; none on Mohs Surgery. Adding this measure to PQRS will help
dermatologists and other specialists continue to report successfully, avoid
penalties for under-reporting for programs such as PQRS and the Value Based
Payment Modifier, and more importantly, to contribute to the quality of
patient care and the performance goals of CMS. (Submitted by: American Academy
of Dermatology)
- The American College of Mohs Surgery (ACMS) represents more than 1,300
Mohs micrographic surgeons, the vast majority who have successfully completed
extensive fellowship-training in Mohs micrographic surgery (MMS) following
their dermatology residency training. We are writing in support of Measure
178, Use of Mohs Surgery for Superficial Basal Cell Carcinoma of the Trunk for
Immune Competent Patients, which is an important measure of care for basal
cell carcinoma, the most common skin cancer. We continue to believe this
measure is appropriate for use in the future Merit-Based Incentive Payment
System (MIPS) and urge the MAP to reconsider its current recommendation,
Encourage continued development, and replace it with Conditional Support. As
we noted in previous comments, this measure stems from the American Academy of
Dermatology (AAD) Mohs Micrographic Surgery (MMS) Appropriate Use Criteria
(AUC), which considered the expertise of more than 75 physicians, including
ACMS Fellows, and followed the rigorous Appropriateness Method developed by
RAND/UCLA. Our understanding of the MAP decision categories is that
Conditional Support is more appropriate for this measure given it meets a
critical program objective, addresses a significant measure gap in dermatology
and the Medicare program, and is a core measure that is not currently included
in CMS’ quality reporting programs, yet could benefit from testing which will
occur in advance of the 2017 reporting year for the 2019 MIPS program.
(Submitted by: The American College of Mohs Surgery)
- (Early public comment)We support the inclusion of this measure that
is part of the American Academy of Dermatology (AAD) strategy to provide a
comprehensive quality approach for patients with skin cancer. Including this
measure will further expand performance measurement through the entire skin
cancer care process. Each has been developed to address either a rate
limiting step to quality care or a significant waste/overuse issue. This is a
measure of care for basal cell carcinoma, the most common form of skin cancer,
affecting more than 2 million people each year. The measure will add value to
the MIPS measure set because it has the potential to improve patient outcomes,
ensure appropriate resource utilization and reduce overall healthcare costs by
reducing inappropriate use of Mohs surgery. This measure also fills a critical
program need for measures of skin care. There are only 6 dermatology-specific
measures in PQRS and none on basal or squamous cell carcinoma. Adding this
measure to PQRS will help dermatologists, particularly skin cancer
specialists, continue to report successfully, avoid penalties for
under-reporting for programs such as PQRS and the Value Based Payment
Modifier, and more importantly, to contribute to the quality of patient care
and the performance goals of CMS. (Submitted by: American Academy of
Dermatology)
- (Early public comment)ASPS is pleased to see meaningful and
relevant measures for plastic surgeons in the MIPS program. Going forward,
ASPS wishes to continue to see more relevant measures for specialties and
surgical specialties. (Submitted by: American Society of Plastic
Surgeons)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
- (Early public comment)The American College of Mohs Surgery (ACMS)
represents more than 1,300 Mohs micrographic surgeons, the vast majority who
have successfully completed extensive fellowship-training in Mohs micrographic
surgery (MMS) following their dermatology residency training. Today, we write
in support of Measure 178, Use of Mohs Surgery for Superficial Basal Cell
Carcinoma of the Trunk for Immune Competent Patients, which is an important
measure of care for basal cell carcinoma, the most common skin cancer. This
measure stems from the American Academy of Dermatology (AAD) Mohs
Micrographic Surgery (MMS) Appropriate Use Criteria (AUC), which considered
the expertise of more than 75 physicians, including ACMS Fellows, and followed
the rigorous Appropriateness Method developed by RAND/UCLA. This measure is
appropriate for use in the current PQRS program, as well as the future MIPS
program. (Submitted by: The American College of Mohs Surgery)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-179)
|
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- We encourage “conditional support” instead of “encourage continued
development.” This measure addresses gaps in high priority areas: 1)
appropriate use and resource use and 2) specialty care provided by several
surgical specialties, including plastic surgery and dermatology. This measure
is fully specified and in testing for reliability, validity and feasibility
with results expected mid 2016. AAD anticipates submitting both Mohs measures
for endorsement at the next available opportunity after completion of testing.
Given the long timeframes for development and testing it is difficult to
synchronize testing with the scheduling of endorsement review committees and
CMS timelines for the consideration of measures for PQRS/MIPs. This mismatch
means that these Mohs Surgery measures would need to wait a year for
consideration for MIPS 2018. Meanwhile there are only 6 dermatology-specific
measures in PQRS, none on basal or squamous cell carcinoma; none on Mohs
Surgery. Adding this measure to PQRS will help dermatologists and other
specialists continue to report successfully, avoid penalties for
under-reporting for programs such as PQRS and the Value Based Payment
Modifier, and more importantly, to contribute to the quality of patient care
and the performance goals of CMS. (Submitted by: American Academy of
Dermatology)
- The American College of Mohs Surgery (ACMS) represents more than 1,300
Mohs micrographic surgeons, the vast majority who have successfully completed
extensive fellowship-training in Mohs micrographic surgery (MMS) following
their dermatology residency training. Today, we write in support of Measure
179, Use of Mohs Surgery for Squamous Cell Carcinoma in Situ or
Keratoacanthoma Type Squamous Cell Carcinoma 1 cm or Smaller on the Trunk, is
an important measure of care for Squamous Cell Carcinoma, the second most
common skin cancer. We continue to believe this measure is appropriate for use
in the future Merit-Based Incentive Payment System (MIPS) and urge the MAP to
reconsider its current recommendation, Encourage Continued Development, and
replace it with Conditional Support. As we noted in previous comments, this
measure stems from the American Academy of Dermatology (AAD) Mohs Micrographic
Surgery (MMS) Appropriate Use Criteria (AUC), which considered the expertise
of more than 75 physicians, including ACMS Fellows, and followed the rigorous
Appropriateness Method developed by RAND/UCLA. Our understanding of the MAP
decision categories is that conditional support is more appropriate for this
measure given it meets a critical program objective, addresses a significant
measure gap in dermatology and the Medicare program, and is a core measure
that is not currently included in CMS’ quality reporting programs, yet could
benefit from testing which will occur in advance of the 2017 reporting year
for the 2019 MIPS program. (Submitted by: The American College of Mohs
Surgery)
- (Early public comment)We support the inclusion of this measure that
is part of the American Academy of Dermatology (AAD) strategy to provide a
comprehensive quality approach for patients with skin cancer. Including this
measure will further expand performance measurement through the entire skin
cancer care process. Each has been developed to address either a rate
limiting step to quality care or a significant waste/overuse issue. This is an
important measure of care for Squamous Cell Carcinoma, a skin cancer affecting
around 700,000 people a year. The measure will add value to the MIPS measure
set because it has the potential to improve patient outcomes, ensure
appropriate resource utilization and reduce overall healthcare costs by
reducing inappropriate use of Mohs surgery. This measure also fills a critical
program need for measures of skin care. There are only 6 dermatology-specific
measures in PQRS and none on basal or squamous cell carcinoma. Adding this
measure to PQRS will help dermatologists, particularly skin cancer
specialists, continue to report successfully, avoid penalties for
under-reporting for programs such as PQRS and the Value Based Payment
Modifier, and more importantly, to contribute to the quality of patient care
and the performance goals of CMS. (Submitted by: American Academy of
Dermatology)
- (Early public comment)ASPS is pleased to see meaningful and
relevant measures for plastic surgeons in the MIPS program. Going forward,
ASPS wishes to continue to see more relevant measures for specialties and
surgical specialties. (Submitted by: American Society of Plastic
Surgeons)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
- (Early public comment)The American College of Mohs Surgery (ACMS)
represents more than 1,300 Mohs micrographic surgeons, the vast majority who
have successfully completed extensive fellowship-training in Mohs micrographic
surgery (MMS) following their dermatology residency training. Today, we write
in support of Measure 179, Use of Mohs Surgery for Squamous Cell Carcinoma in
Situ or Keratoacanthoma Type Squamous Cell Carcinoma 1 cm or Smaller on the
Trunk, is an important measure of care for Squamous Cell Carcinoma, the second
most common skin cancer. This measure stems from the American Academy of
Dermatology (AAD) Mohs Micrographic Surgery (MMS) Appropriate Use Criteria
(AUC), which considered the expertise of more than 75 physicians, including
ACMS Fellows, and followed the rigorous Appropriateness Method developed by
RAND/UCLA. This measure is appropriate for use in the current PQRS program, as
well as the future MIPS program. (Submitted by: The American College of Mohs
Surgery)
(Program: Home Health Quality Reporting Program;
MUC ID: MUC15-207) |
- CAPC supports the MAP’s recommendation “Encourage Continued Development”
for the inclusion of MUC15-207 in the Home Health Quality Reporting Program
(HH QRP). Falls and fall risk are important indicators of the need for
palliative care in older adults, as they often signal an increase in
functional decline; yet patients over the age of 65 are not universally
screened for either. Safety risk an essential element of home health services
and affects hospital admissions. As this measure undergoes further
development with the potential for inclusion in the HH QRP, we encourage CMS
and NQF to explore how this measure might be aligned with existing falls
measures developed in other settings. (Submitted by: Center to Advance
Palliative Care)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- AAHPM supports the MAP’s recommendation to encourage continued development
of this measure. Falls and fall risk are important indicators of the need for
palliative care in older adults, as they often signal an increase in
functional decline; yet patients over the age of 65 are not universally
screened for either. Safety risk an essential element of home health services
and affects hospital admissions. As this measure undergoes further development
with the potential for inclusion in the HHQRP, we encourage CMS and NQF to
explore how this measure might be aligned with existing falls measures
developed in other settings. (Submitted by: American Academy of Hospice and
Palliative Medicine)
- How does one measure "implemented as appropriate?" Too much latitude here
questions the need or value for this MUC. This definition/measurable indices
should be addressed in the next presentation of this MUC. (Submitted by:
American Medical Group Association - KF)
- Third part should be eliminated (how do you implement) unless these is a
consistent, practical and accountable protocol to follow. (Submitted by:
American Medical Group Association - EB)
- The Alliance supports this measure, but is concerned about the overlap of
this measure with other existing measures. Currently, there are several home
health measures relating to falls risk. A measure on multi-risk fall risk
assessment conducted for all patients who can ambulate is in Home Health
Compare. Two other measures relating to falls (relating to having the care
plan reflect the falls risk assessment, and implementation of the care plan)
also appear in the home health CASPER reports. This measure appears to
combine aspects of the three existing measures into a single composite process
measure. As such, it will capture a subset of the patients included in the
existing falls-related process measures. The Alliance is concerned about the
overlap in the measures. The question is whether some measures will be retired
as appropriate. The growing number of overlapping measures has the potential
to be confusing for the general public and even those who are using the
measures as payers and policy-makers. The ideal is a streamlined, meaningful
measure set and the Alliance encourages CMS to make this a goal. Finally, the
Alliance urges testing of this measure and reconsideration before it is
finalized. Testing and validation should be no less than six months with an
opportunity to modify the measure prior to finalizing it. A similar approach
was used for many of the OASIS-based measures that CMS uses for home health
agencies. (Submitted by: Alliance for Home Health Quality and
Innovation)
- Falls are the leading cause of injury-related morbidity and mortality
among older adults. Falls result in physical injury, including high rates of
orthopedic and ocular injury, directly cause costly disability, and often
increase hospital readmissions. In addition, important psychological
consequences occur as a result of a fall, including depression, anxiety,
activity restriction, and fear of falling. There is a plethora of evidence
indicating that impaired vision is highly associated with and is an important
risk factor of falls. Importantly, reduced visual acuity, as currently
screened for, is not adequate to establish a falls risk associated with vision
problems. A comprehensive eye exam is needed to fully assess known
contributing factors to falls, including but not limited to, reduced contrast
sensitivity, poor stereopsis and visual field loss (e.g. especially in the
lower visual field) cataract, ptosis, and color vision deficiencies.
Comprehensive eye examination can also identify other changes in the eye that
can hinder daily function. As an example, a measured increase in sensitivity
to glare and sunlight known to decrease binocularity and can be measured and
subsequently compensated through optical correction. (Submitted by: American
Optometric Association)
- (Early public comment)• MUC15-207: Falls risk composite process
measure- Completion of a falls assessment, the incorporation of the results of
the falls assessment in the care plan, and the implementation of the care plan
are noted in the numerator. Most of this information can be obtained from
OASIS (M1910) that refers to a multi-factor falls risk assessment that
includes components of other measures, such as transferring, multiple
medications, mental impairment and falls history. The denominator is the total
number of patients discharged by the home health agencies. The implementation
of the care plan noted in the numerator would have to be determined by
multi-factors in the patient’s medical record. It is important to note that
this measure assesses the home health agencies ability to document in the care
plan the falls risk. The measure falls short of determining if the home health
agency is actually implementing an effective plan of care to reduce the risk
of falls. We believe this measure does not meet NQF National Quality
Strategies Priorities: Subcriterion 2.1 Safer care, and should be a measure
that requires continued development. It is a process measure that does not
reflect outcomes. (Submitted by: LeadingAge)
- (Early public comment)Based on the limited information regarding
the specifications for the measure, NAHC generally supports the measure.
(Submitted by: National Association for Home Care & Hospice
(NAHC))
- (Early public comment)The Alliance supports this measure, but is
concerned about the overlap of this measure with other existing measures.
Currently, there are several home health measures relating to falls risk. A
measure on multi-risk fall risk assessment conducted for all patients who can
ambulate is in Home Health Compare. Two other measures relating to falls
(relating to having the care plan reflect the falls risk assessment, and
implementation of the care plan) also appear in the home health CASPER
reports. This measure appears to combine aspects of the three existing
measures into a single composite process measure. As such, it will capture a
subset of the patients included in the existing falls-related process
measures. The Alliance is concerned about the overlap in the measures. The
question is whether some measures will be retired as appropriate. The growing
number of overlapping measures has the potential to be confusing for the
general public and even those who are using the measures as payers and
policy-makers. The ideal is a streamlined, meaningful measure set and the
Alliance encourages CMS to make this a goal. Finally, the Alliance urges
testing of this measure and reconsideration before it is finalized. Testing
and validation should be no less than six months with an opportunity to modify
the measure prior to finalizing it. A similar approach was used for many of
the OASIS-based measures that CMS uses for home health agencies. (Submitted
by: Alliance for Home Health Quality and Innovation)
- (Early public comment)This measure is in early stage of
development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)We support the development of a falls risk
composite measure that includes assessment, care plan development, and
implementation. We believe this type of measure is appropriate for home health
and across settings. (Submitted by: Association of Home & Hospice Care of
NC/SC Home Care & Hospice Association)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-208)
|
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- ACS believes the development of the seurveillance endoscopy for dysplasia
in Barrett's Esophagus measure is premature. Without interoperability, we
believe that this measure will be too burdensome for providers to report.
(Submitted by: American College of Surgeons)
- (Early public comment)While AGA agrees that the intent of this
measure has some merit, AGA does not at this time support inclusion of this
measure on the list of measures to be finalized for PQRS implementation
(Submitted by: American Gastroenterological Association)
- (Early public comment)While ASGE finds the inclusion of
surveillance measures in public reporting programs worthy of exploration, this
measure concept currently lacks sufficient evidence to show importance to
measure and variation in performance. Further, as currently specified, this
measure would not deter overutilization. (Submitted by: American Society for
Gastrointestinal Endoscopy)
- (Early public comment)Surveillance is an important tool in the
management of Barrett’s as studies support that early detection and treatment
of dysplastic Barrett’s lesions can reduce the incidence of esophageal
adenocarcinoma and is consistent with longstanding AGA guidelines as noted in
the Measure Rationale. However, this measure has never been submitted to NQF
for evaluation/endorsement. Thus, we would support inclusion of this measure
for consideration in MIPS – only pending future NQF-endorsement. If selected
for use, given the rapid pace of innovation in this area, we encourage MAP to
monitor CMS’ use of this measure to ensure that potential future FDA-approved
technologies that advance medicine and may further improve patient adherence
are considered in the numerator. (Submitted by: AdvaMed)
- (Early public comment)Surveillance is an important tool in the
management of Barrett’s as studies support that early detection and treatment
of dysplastic Barrett’s lesions can reduce the incidence of esophageal
adenocarcinoma and is consistent with longstanding AGA guidelines as noted in
the Measure Rationale. Thus, we support inclusion of this measure for
consideration in MIPS. However, given the rapid pace of innovation in this
area, we encourage MAP to monitor CMS’ use of this measure to ensure that
potential future FDA-approved technologies that advance medicine and may
further improve patient adherence are considered in the numerator. (Submitted
by: Medtronic)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-209)
|
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Academy of Managed
Care Pharmacy)
- (Early public comment)While AGA agrees that the intent of this
measure has some merit, AGA does not at this time support inclusion of this
measure on the list of measures to be finalized for PQRS implementation
(Submitted by: American Gastroenterological Association)
- (Early public comment)ASGE does not support advancement of this
measure concept as other equally effective treatments are available for
patients with esophageal varices. AASLD guidelines leave the treatment option
to the discretion of the provider. Further, 25% of patients taking beta
blockers have side effects precluding many patients from taking them.
(Submitted by: American Society for Gastrointestinal Endoscopy)
- (Early public comment)This measure is currently being field
tested,has never been submitted to NQF and thus is not NQF-endorsed (Submitted
by: AdvaMed)
(Program: Merit-Based
Incentive Payment System (MIPS); MUC ID: MUC15-210) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- This comment is for MUC 210,211 and 220. Optimal assessment of adequate
vaccination would be found in using titer levels to prove/disprove immunity.
Parsimony here is based on whether the costs of vaccination are qualified by
additional lab costs for titers. If the titers turn out to be minimal, then
vaccination costs are sunk and wasteful expenditures. (Submitted by: American
Medical Group Association)
- (Early public comment)While AGA agrees that the intent of this
measure has some merit, AGA does not at this time support inclusion of this
measure on the list of measures to be finalized for PQRS implementation
(Submitted by: American Gastroenterological Association)
- (Early public comment)ASGE does not support advancement of this
measure at this time as the measure concept lacks sufficient evidence to show
importance to measure and variation in performance. (Submitted by: American
Society for Gastrointestinal Endoscopy)
- (Early public comment)Inclusion of these measures will build on
existing immunization-related measures currently used in the Physician Quality
Reporting System to help ensure that Medicare beneficiaries benefit from these
important vaccinations. (Submitted by: Trust for America's
Health)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)On behalf of Hep B United, we appreciate the
opportunity to offer comments on the 2015 Measures Under Consideration by the
Measures Application Partnership at the National Quality Forum. Hep B United
is a national coalition comprised of 30 community-based coalitions and
national organizations with a reach of over 4 million, to address and
eliminate hepatitis B, the leading cause of liver cancer and a major health
disparity among Asian Americans and Pacific Islanders. Our collective goals
are to raise the profile of hepatitis B and liver cancer as an urgent public
health priority, increase hepatitis B testing and vaccination, and improve
access to care and treatment for individuals living with hepatitis B. We
strongly support the measures under consideration for Medicare beneficiaries
living with chronic viral hepatitis and liver disease, particularly the
following process and outcome measures under the Merit-Based Incentive Payment
System program: • MUC15-210: Hepatitis A vaccination for patients with
cirrhosis • MUC15-211: Hepatitis B vaccination for patients with cirrhosis
• MUC15-217: Screening for Hepatoma in patients with Chronic Hepatitis B
• MUC15-220: Hepatitis B vaccination for patients with Chronic Hepatitis C
• MUC15-229: Hepatitis C Virus (HCV)- Sustained Virological Response (SVR)
These measures align with our coalition’s priorities to increase hepatitis B
testing and vaccination in high-risk populations and improve access to care
and treatment for individuals living with chronic hepatitis B to prevent
end-stage liver disease and liver cancer. Of the identified and reported
cases of hepatitis B virus infection in the United States between 2007 and
2012, 15.6% were over the age of 65 and part of the Medicare covered
population. It is vital that seniors diagnosed with chronic hepatitis B be
linked to care and monitored for hepatocellular carcinoma, thus, we
particularly commend the inclusion of MUC15-217: Screening for Hepatoma in
patients with Chronic Hepatitis B. Additionally, we respectfully take this
opportunity to encourage the Centers for Medicare and Medicaid (CMS) to
consider measures for screening for hepatitis B virus infection for those
individuals at high risk. An estimated 67% of individuals do not know they
have chronic hepatitis B including those who are part of the Medicare covered
population. It is imperative that CMS consider a National Coverage
Determination for this service, to match the U.S. Preventive Services Task
Force “B” grade recommendation for hepatitis B screening in persons athigh
risk for infection. We thank the NQF Measures Application Partnership for
your work and consideration of our comments. HBU greatly appreciates this
opportunity to provide input to the 2015 Measures Under Consideration that
impact the health of Medicare beneficiaries living with chronic viral
hepatitis and liver disease. Please do not hesitate to contact Hep B United at
kate.moraras@hepb.org with any questions or further discussion on our
comments. (Submitted by: Hep B United)
- (Early public comment)December 7, 2015 RE: 2015 Measures under
Consideration by the National Quality Forum (NQF) Measure Applications
Partnership (MAP) On behalf of the Hepatitis B Foundation (HBF), we appreciate
the opportunity to offer comments on the 2015 Measures Under Consideration by
the Measures Application Partnership at the National Quality Forum. The
Hepatitis B Foundation is the only national nonprofit organization solely
dedicated to finding a cure for hepatitis B and improving the quality of life
for those affected worldwide through research, education and patient advocacy.
Our commitment includes funding focused research, promoting disease awareness,
supporting immunization and treatment initiatives, and serving as the primary
source of information for patients and their families, the medical and
scientific community, and the general public. We strongly support the measures
under consideration for Medicare beneficiaries living with chronic viral
hepatitis and liver disease, particularly the following process and outcome
measures under the Merit-Based Incentive Payment System program: -MUC15-210:
Hepatitis A vaccination for patients with cirrhosis -MUC15-211: Hepatitis B
vaccination for patients with cirrhosis -MUC15-217: Screening for Hepatoma in
patients with Chronic Hepatitis B -MUC15-220: Hepatitis B vaccination for
patients with Chronic Hepatitis C -MUC15-229: Hepatitis C Virus (HCV)-
Sustained Virological Response (SVR) These measures align with HBF’s
priorities to increase hepatitis B testing and vaccination in high-risk
populations and improve access to care and treatment for individuals living
with chronic hepatitis B to prevent end-stage liver disease and liver cancer.
Of the identified and reported cases of hepatitis B virus infection in the
United States between 2007 and 2012, 15.6% were over the age of 65 and part of
the Medicare covered population. It is vital that seniors diagnosed with
chronic hepatitis B be linked to care and monitored for hepatocellular
carcinoma, thus, we particularly commend the inclusion of MUC15-217: Screening
for Hepatoma in patients with Chronic Hepatitis B. Additionally, we
respectfully take this opportunity to encourage the Centers for Medicare and
Medicaid (CMS) to consider measures for screening for hepatitis B virus
infection for those individuals at high risk. An estimated 67% of individuals
do not know they have chronic hepatitis B including those who are part of the
Medicare covered population. It is imperative that CMS consider a National
Coverage Determination for this service, to match the U.S. Preventive Services
Task Force “B” grade recommendation for hepatitis B screening in persons at
high risk for infection. We thank the NQF Measures Application Partnership for
your work and consideration of our comments. HBU greatly appreciates this
opportunity to provide input to the 2015 Measures Under Consideration that
impact the health of Medicare beneficiaries living with chronic viral
hepatitis and liver disease. Please do not hesitate to contact the Hepatitis B
Foundation Executive Director at joan.block@hepb.org with any questions or
further discussion on our comments. Sincerely, Joan Block, Executive Director
Hepatitis B Foundation (Submitted by: Hepatitis B Foundation)
- (Early public comment)On behalf of the Association of Asian Pacific
Community Health Organizations (AAPCHO), we appreciate the opportunity to
provide comments on the 2015 Measures Under Consideration by the Measures
Application Partnership at the National Quality Forum. AAPCHO is a national
not-for-profit association of 35 community-based health care organizations, 29
of which are Federally Qualified Health Centers (FQHCs). AAPCHO members are
dedicated to promoting advocacy, collaboration, and leadership to improve the
health status and access of medically underserved AA&NHOPIs in the U.S.,
its territories, and its freely associated states. AAPCHO’s members provide
linguistically and culturally competent care to millions of vulnerable Asian
Americans, Native Hawaiians, and Other Pacific Islanders (AA & NHOPIs).
Many of our members serve a higher than average percentage of patients with
hepatitis B and C, as both diseases have high prevalence rates in Asian
Americans and Pacific Islanders. Because of the high rates of hepatitis B
found in many of our member centers, AAPCHO co-founded Hep B United, a
national coalition of over 30 local coalitions working to address hepatitis B
through education, screening, vaccination, and linkage-to-care efforts. As
such, we strongly support the measures under consideration for Medicare
beneficiaries living with chronic viral hepatitis and liver disease. We
particularly support the following process and outcome measures under the
Merit-Based Incentive Payment System program: • MUC15-210: Hepatitis A
vaccination for patients with cirrhosis • MUC15-211: Hepatitis B vaccination
for patients with cirrhosis • MUC15-217: Screening for Hepatoma in patients
with Chronic Hepatitis B • MUC15-220: Hepatitis B vaccination for patients
with Chronic Hepatitis C • MUC15-229: Hepatitis C Virus (HCV)- Sustained
Virological Response (SVR) These measures align with Hep B United and AAPCHO’s
priorities to increase hepatitis B testing and vaccination in the high-risk
populations that AAPCHO members serve, and improve access to care and
treatment for individuals living with chronic hepatitis B to prevent end-stage
liver disease and liver cancer. Of the identified and reported cases of
hepatitis B virus infection in the United States between 2007 and 2012, 15.6%
were over the age of 65 and part of the Medicare covered population. It is
vital that seniors diagnosed with chronic hepatitis B be linked to care and
monitored for hepatocellular carcinoma, thus, we particularly commend the
inclusion of MUC15-217: Screening for Hepatoma in patients with Chronic
Hepatitis B. We respectfully take this opportunity to encourage the Centers
for Medicare and Medicaid (CMS) to consider measures for screening for
hepatitis B virus infection for those individuals at high risk. An estimated
67% of individuals do not know they have chronic hepatitis B including those
who are part of the Medicare covered population. It is imperative that CMS
consider a National Coverage Determination to screen individuals at risk for
hepatitis B, matching the U.S. Preventive Services Task Force’s “B” grade
recommendation for hepatitis B screening in persons at high risk for
infection. We thank the NQF Measures Application Partnership for your work and
consideration of our comments. AAPCHO greatly appreciates this opportunity to
provide input to the 2015 Measures Under Consideration that impact the health
of Medicare beneficiaries living with chronic viral hepatitis and liver
disease. Please contact Isha Weerasinghe, AAPCHO’s Director of Policy and
Advocacy at isha@aapcho.org if you have any questions or comments. Thank you,
Jeffrey Caballero, MPH Executive Director (Submitted by: Association of Asian
Pacific Community Health Organizations)
(Program: Merit-Based
Incentive Payment System (MIPS); MUC ID: MUC15-211) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- (Early public comment)While AGA agrees that the intent of this
measure has some merit, AGA does not at this time support inclusion of this
measure on the list of measures to be finalized for PQRS implementation
(Submitted by: American Gastroenterological Association)
- (Early public comment)ASGE does not support advancement of this
measure at this time as the measure concept lacks sufficient evidence to show
importance to measure and variation in performance. (Submitted by: American
Society for Gastrointestinal Endoscopy)
- (Early public comment)Inclusion of these measures will build on
existing immunization-related measures currently used in the Physician Quality
Reporting System to help ensure that Medicare beneficiaries benefit from these
important vaccinations. (Submitted by: Trust for America's
Health)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)On behalf of Hep B United, we appreciate the
opportunity to offer comments on the 2015 Measures Under Consideration by the
Measures Application Partnership at the National Quality Forum. Hep B United
is a national coalition comprised of 30 community-based coalitions and
national organizations with a reach of over 4 million, to address and
eliminate hepatitis B, the leading cause of liver cancer and a major health
disparity among Asian Americans and Pacific Islanders. Our collective goals
are to raise the profile of hepatitis B and liver cancer as an urgent public
health priority, increase hepatitis B testing and vaccination, and improve
access to care and treatment for individuals living with hepatitis B. We
strongly support the measures under consideration for Medicare beneficiaries
living with chronic viral hepatitis and liver disease, particularly the
following process and outcome measures under the Merit-Based Incentive Payment
System program: • MUC15-210: Hepatitis A vaccination for patients with
cirrhosis • MUC15-211: Hepatitis B vaccination for patients with cirrhosis
• MUC15-217: Screening for Hepatoma in patients with Chronic Hepatitis B
• MUC15-220: Hepatitis B vaccination for patients with Chronic Hepatitis C
• MUC15-229: Hepatitis C Virus (HCV)- Sustained Virological Response (SVR)
These measures align with our coalition’s priorities to increase hepatitis B
testing and vaccination in high-risk populations and improve access to care
and treatment for individuals living with chronic hepatitis B to prevent
end-stage liver disease and liver cancer. Of the identified and reported
cases of hepatitis B virus infection in the United States between 2007 and
2012, 15.6% were over the age of 65 and part of the Medicare covered
population. It is vital that seniors diagnosed with chronic hepatitis B be
linked to care and monitored for hepatocellular carcinoma, thus, we
particularly commend the inclusion of MUC15-217: Screening for Hepatoma in
patients with Chronic Hepatitis B. Additionally, we respectfully take this
opportunity to encourage the Centers for Medicare and Medicaid (CMS) to
consider measures for screening for hepatitis B virus infection for those
individuals at high risk. An estimated 67% of individuals do not know they
have chronic hepatitis B including those who are part of the Medicare covered
population. It is imperative that CMS consider a National Coverage
Determination for this service, to match the U.S. Preventive Services Task
Force “B” grade recommendation for hepatitis B screening in persons at high
risk for infection. We thank the NQF Measures Application Partnership for
your work and consideration of our comments. HBU greatly appreciates this
opportunity to provide input to the 2015 Measures Under Consideration that
impact the health of Medicare beneficiaries living with chronic viral
hepatitis and liver disease. Please do not hesitate to contact Hep B United at
kate.moraras@hepb.org with any questions or further discussion on our
comments. (Submitted by: Hep B United)
- (Early public comment)December 7, 2015 RE: 2015 Measures under
Consideration by the National Quality Forum (NQF) Measure Applications
Partnership (MAP) On behalf of the Hepatitis B Foundation (HBF), we appreciate
the opportunity to offer comments on the 2015 Measures Under Consideration by
the Measures Application Partnership at the National Quality Forum. The
Hepatitis B Foundation is the only national nonprofit organization solely
dedicated to finding a cure for hepatitis B and improving the quality of life
for those affected worldwide through research, education and patient advocacy.
Our commitment includes funding focused research, promoting disease awareness,
supporting immunization and treatment initiatives, and serving as the primary
source of information for patients and their families, the medical and
scientific community, and the general public. We strongly support the measures
under consideration for Medicare beneficiaries living with chronic viral
hepatitis and liver disease, particularly the following process and outcome
measures under the Merit-Based Incentive Payment System program: -MUC15-210:
Hepatitis A vaccination for patients with cirrhosis -MUC15-211: Hepatitis B
vaccination for patients with cirrhosis -MUC15-217: Screening for Hepatoma in
patients with Chronic Hepatitis B -MUC15-220: Hepatitis B vaccination for
patients with Chronic Hepatitis C -MUC15-229: Hepatitis C Virus (HCV)-
Sustained Virological Response (SVR) These measures align with HBF’s
priorities to increase hepatitis B testing and vaccination in high-risk
populations and improve access to care and treatment for individuals living
with chronic hepatitis B to prevent end-stage liver disease and liver cancer.
Of the identified and reported cases of hepatitis B virus infection in the
United States between 2007 and 2012, 15.6% were over the age of 65 and part of
the Medicare covered population. It is vital that seniors diagnosed with
chronic hepatitis B be linked to care and monitored for hepatocellular
carcinoma, thus, we particularly commend the inclusion of MUC15-217: Screening
for Hepatoma in patients with Chronic Hepatitis B. Additionally, we
respectfully take this opportunity to encourage the Centers for Medicare and
Medicaid (CMS) to consider measures for screening for hepatitis B virus
infection for those individuals at high risk. An estimated 67% of individuals
do not know they have chronic hepatitis B including those who are part of the
Medicare covered population. It is imperative that CMS consider a National
Coverage Determination for this service, to match the U.S. Preventive Services
Task Force “B” grade recommendation for hepatitis B screening in persons at
high risk for infection. We thank the NQF Measures Application Partnership for
your work and consideration of our comments. HBU greatly appreciates this
opportunity to provide input to the 2015 Measures Under Consideration that
impact the health of Medicare beneficiaries living with chronic viral
hepatitis and liver disease. Please do not hesitate to contact the Hepatitis B
Foundation Executive Director at joan.block@hepb.org with any questions or
further discussion on our comments. Sincerely, Joan Block, Executive Director
Hepatitis B Foundation (Submitted by: Hepatitis B Foundation)
- (Early public comment)On behalf of the Association of Asian Pacific
Community Health Organizations (AAPCHO), we appreciate the opportunity to
provide comments on the 2015 Measures Under Consideration by the Measures
Application Partnership at the National Quality Forum. AAPCHO is a national
not-for-profit association of 35 community-based health care organizations, 29
of which are Federally Qualified Health Centers (FQHCs). AAPCHO members are
dedicated to promoting advocacy, collaboration, and leadership to improve the
health status and access of medically underserved AA&NHOPIs in the U.S.,
its territories, and its freely associated states. AAPCHO’s members provide
linguistically and culturally competent care to millions of vulnerable Asian
Americans, Native Hawaiians, and Other Pacific Islanders (AA & NHOPIs).
Many of our members serve a higher than average percentage of patients with
hepatitis B and C, as both diseases have high prevalence rates in Asian
Americans and Pacific Islanders. Because of the high rates of hepatitis B
found in many of our member centers, AAPCHO co-founded Hep B United, a
national coalition of over 30 local coalitions working to address hepatitis B
through education, screening, vaccination, and linkage-to-care efforts. As
such, we strongly support the measures under consideration for Medicare
beneficiaries living with chronic viral hepatitis and liver disease. We
particularly support the following process and outcome measures under the
Merit-Based Incentive Payment System program: • MUC15-210: Hepatitis A
vaccination for patients with cirrhosis • MUC15-211: Hepatitis B vaccination
for patients with cirrhosis • MUC15-217: Screening for Hepatoma in patients
with Chronic Hepatitis B • MUC15-220: Hepatitis B vaccination for patients
with Chronic Hepatitis C • MUC15-229: Hepatitis C Virus (HCV)- Sustained
Virological Response (SVR) These measures align with Hep B United and AAPCHO’s
priorities to increase hepatitis B testing and vaccination in the high-risk
populations that AAPCHO members serve, and improve access to care and
treatment for individuals living with chronic hepatitis B to prevent end-stage
liver disease and liver cancer. Of the identified and reported cases of
hepatitis B virus infection in the United States between 2007 and 2012, 15.6%
were over the age of 65 and part of the Medicare covered population. It is
vital that seniors diagnosed with chronic hepatitis B be linked to care and
monitored for hepatocellular carcinoma, thus, we particularly commend the
inclusion of MUC15-217: Screening for Hepatoma in patients with Chronic
Hepatitis B. We respectfully take this opportunity to encourage the Centers
for Medicare and Medicaid (CMS) to consider measures for screening for
hepatitis B virus infection for those individuals at high risk. An estimated
67% of individuals do not know they have chronic hepatitis B including those
who are part of the Medicare covered population. It is imperative that CMS
consider a National Coverage Determination to screen individuals at risk for
hepatitis B, matching the U.S. Preventive Services Task Force’s “B” grade
recommendation for hepatitis B screening in persons at high risk for
infection. We thank the NQF Measures Application Partnership for your work and
consideration of our comments. AAPCHO greatly appreciates this opportunity to
provide input to the 2015 Measures Under Consideration that impact the health
of Medicare beneficiaries living with chronic viral hepatitis and liver
disease. Please contact Isha Weerasinghe, AAPCHO’s Director of Policy and
Advocacy at isha@aapcho.org if you have any questions or comments. Thank you,
Jeffrey Caballero, MPH Executive Director (Submitted by: Association of Asian
Pacific Community Health Organizations)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-212)
|
- Medtronic fully supports quality care for patients with Crohn’s Disease;
however, we agree with MAP's recommendation that this measure is not
appropriate for consideration in MIPS. Colonoscopy is the only surveillance
modality included in the measure numerator. However, in addition to
colonoscopy, there are other diagnostics that can also be used for
surveillance of Crohn’s Disease. We encourage MAP to seek inclusion of other
guideline-supported technologies in the measure numerator before CMS considers
this measure for use in MIPS or other quality programs. (Submitted by:
Medtronic)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- ACS believes the development of the surveillance colonoscopy for
dysplasia in colonic Crohn's disease measure is premature. Without
interoperability, we believe that this measure will be too burdensome for
providers to report. (Submitted by: American College of Surgeons)
- Because of some common presentation/signs/symptoms, small bowel
localization should be ruled out before a definitive dx of Crohn's Disease.
This may require returning to the basics of manual chart and history review.
Subsequently, early observation and intervention of a documented Crohn's
ransitioning to colon cancer fits in the mode of prevention superceding
therapy. (Submitted by: American Medical Group Association - KF)
- (Early public comment)While AGA agrees that the intent of this
measure has some merit, AGA does not at this time support inclusion of this
measure on the list of measures to be finalized for PQRS implementation
(Submitted by: American Gastroenterological Association)
- (Early public comment)While ASGE finds the inclusion of
surveillance measures in public reporting programs worthy of exploration, this
measure, as specified, would not deter overutilization of colonoscopy. The
recommendations for surveillance colonoscopy in Crohn’s disease are based on
how long the patient has had the disease. (Submitted by: American Society for
Gastrointestinal Endoscopy)
- (Early public comment)AdvaMed fully supports quality care for
patients with Crohn’s Disease; however, we do not believe that this measure is
appropriate for consideration in MIPS. In addition, this measure has never
been submitted to NQF and thus is not NQF-endorsed. Colonoscopy is the only
surveillance modality included in the measure numerator. However, in addition
to colonoscopy, there are other diagnostics that can also be used for
surveillance of Crohn’s Disease. We encourage MAP to seek inclusion of other
guideline-supported technologies in the measure numerator before CMS considers
this measure for use in MIPS or other quality programs. (Submitted by:
AdvaMed)
- (Early public comment)Medtronic fully supports quality care for
patients with Crohn’s Disease; however, we do not believe that this measure is
appropriate for consideration in MIPS. Colonoscopy is the only surveillance
modality included in the measure numerator. However, in addition to
colonoscopy, there are other diagnostics that can also be used for
surveillance of Crohn’s Disease. We encourage MAP to seek inclusion of other
guideline-supported technologies in the measure numerator before CMS considers
this measure for use in MIPS or other quality programs. (Submitted by:
Medtronic)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-215)
|
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- We encourage “conditional support” instead of “encourage continued
development.” We agree that timely reporting of results to patients is
important. We disagree with the MAP recommendation that this measure should
not be limited to skin cancer biopsies for several reasons. First, the focus
of this measure limits the reporting burden on clinicians. Until registry
reporting is streamlined and manual input of individual case information is no
longer required for reporting, we need to design measures that use
denominators that are representative of a clinician’s performance - this is
very similar to a research project in which a sample population is chosen and
is deemed representative of the entire population as it is not always
practical or useful to evaluate the entire population. Also, the vast majority
of skin biopsies performed by clinicians will be to evaluate for skin cancer.
While the focus on NMSC might appear narrow, in reality this measure is broad
in its reach as skin biopsies for skin cancer are performed by a range of
providers including dermatologists and non-dermatologists. Therefore its
impact will be far reaching and this measure will be broadly applicable across
different providers and clinical settings. Second, melanoma reporting was
excluded as unlike NMSC (specifically, Basal Cell Carcinoma and Squamous Cell
Carcinoma as specified in the measure) where a second opinion, special
staining, or advanced treatment planning is rarely needed, melanoma biopsies
frequently need additional work-up/reviewers and multidisciplinary review;
thus potentially delaying reporting time to the patient. As such, creating a
time restriction may inadvertently negatively impact diagnostic accuracy and
treatment planning for a high-risk disease. This measure is fully specified
and in testing for reliability, validity and feasibility with results expected
mid 2016. AAD anticipates submitting the measure for endorsement at the next
available opportunity after completion of testing. Given the long timeframes
for development and testing it is difficult to synchronize testing with the
scheduling of endorsement review committees and CMS timelines for the
consideration of measures for PQRS/MIPs. This mismatch means that, if this
measure is not “supported” now, it would need to wait a full year for
consideration for MIPS 2018. This measure fills a critical program need for
measures of skin care as there are only 6 dermatology-specific measures in
PQRS; none for care for basal or squamous cell carcinoma and none on the
timeliness of reporting biopsy results. Adding this measure to PQRS will help
dermatologists and other skin care specialists report successfully, avoid
penalties for under-reporting for programs such as PQRS and the Value Based
Payment Modifier, and more importantly, to contribute to the quality of
patient care and the performance goals of CMS. (Submitted by: American Academy
of Dermatology)
- (Early public comment)We support the inclusion of this measure that
is part of the American Academy of Dermatology (AAD) strategy to provide a
comprehensive quality approach for patients with skin cancer. Including this
measure will further expand performance measurement through the entire skin
cancer care process. Each has been developed to address either a rate
limiting step to quality care or a significant waste/overuse issue. This is an
important measure of care for basal or squamous cell carcinoma, the most
common types of skin cancer, affecting more than 3 million people each year.
This measure will add value to the MIPS measure set because it addresses the
fragmented communication between physicians and patients about biopsy results.
This measure encourages timely notification to patients of the final biopsy
results to ensure effective treatment. Lack of timely delivery can increase
the cost of medical care, error and the anxiety the patient experiences in
waiting for results. This measure also fills a critical program need for
measures of skin care as there are only 6 dermatology-specific measures in
PQRS and none for care for basal or squamous cell carcinoma. Adding this
measure to PQRS will help dermatologists, continue to report successfully,
avoid penalties for under-reporting for programs such as PQRS and the Value
Based Payment Modifier, and more importantly, to contribute to the quality of
patient care and the performance goals of CMS. (Submitted by: American Academy
of Dermatology)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
(Program: Merit-Based Incentive
Payment System (MIPS); MUC ID: MUC15-216) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- his reflects on both MUC 215 and 216. Under MIPS and ACO's, there are
few/limited measures for specialties beyond primary care. And yet MUC 215
holds the biopsy clinician responsible for being timely in reporting to the
patient. By not developing MUC 216 further, should one assume that the full
burden of timeliness from biopsy to path report to patient debrief is solely
the quality measure of the biopsy clinician? One can control only so much out
side of one's own examining room. Seems this needs further resolve so as to
not unfairly penalize the biopsy clinician. (Submitted by: American Medical
Group Association - KF)
- We encourage the MAP Coordinating Committee to “conditionally support”
this measure. We appreciate the discussion of the Clinician Workgroup about
general versus specialized measures and encourage CMS and NQF to engage in
deeper dialogue with medical societies about this topic. The Council on
Pathology concerns about some pathology tests taking longer than the 5
business days highlight the need for specialized pathology reporting measures.
This measure focuses on skin pathologies that can and should be reported
within that time frame. In essence, this is a good example of an area where a
specialized, rather than general measure, is needed. For complex cases that do
need additional time, the benchmark was set at a rate that should accommodate
the infrequent case in which a basal cell carcinoma or squamous cell carcinoma
would need further work-up. Further more, because the histologic diagnosis of
these conditions is, for a large proportion of cases, relatively straight
forward, this measure drives the added dimension of preventing unnecessary
costly and time consuming tests that are not typically needed. This measure
also fills a critical program need for measures of skin care as there are only
6 dermatology-specific measures in PQRS; none for care for basal or squamous
cell carcinoma and none on the timeliness of reporting biopsy results. Adding
this measure to PQRS will help dermatologists, particularly
dermatopathologists, report successfully, avoid penalties for under-reporting
for programs such as PQRS and the Value Based Payment Modifier, and more
importantly, to contribute to the quality of patient care and the performance
goals of CMS. (Submitted by: American Academy of Dermatology)
- (Early public comment)We support the inclusion of this measure that
is part of the American Academy of Dermatology (AAD) strategy to provide a
comprehensive quality approach for patients with skin cancer. Including this
measure will further expand performance measurement through the entire skin
cancer care process. Each has been developed to address either a rate
limiting step to quality care or a significant waste/overuse issue. This is an
important measure of care for basal or squamous cell carcinoma, the most
common types of skin cancer, affecting more than 3 million people each year.
This measure will add value to the MIPS measure set because it addresses the
fragmented communication between pathologists and physicians about patient
outcomes. Effective communication through the biopsy report between the two
practitioners is essential; as delay may directly affect patient care.
Furthermore, lack of timely delivery of biopsy results can increase the cost
of medical care, error and the anxiety the patient experiences in waiting for
results. This measure also fills a critical program need for measures of skin
care as there are only 6 dermatology-specific measures in PQRS, none for care
for basal or squamous cell carcinoma and only one for dermatopathologists.
Adding this measure to PQRS will help dermatologists, particularly
dermatopathologists, report successfully, avoid penalties for under-reporting
for programs such as PQRS and the Value Based Payment Modifier, and more
importantly, to contribute to the quality of patient care and the performance
goals of CMS. (Submitted by: American Academy of Dermatology)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)At this time, the College of American
Pathologists (CAP) cannot support MUC 216: Biopsy Reporting Time – Pathologist
to Clinician. While we believe that timely communication of laboratory results
is important to patient satisfaction, we do not think that this measure is
clinically relevant or a fair representation of quality. The measure may have
unintended consequences if providers aim to meet the stated specimen
turnaround time but do so at the detriment of complete reports. Further, the
rationale for the measure is that there is fragmented communication between
pathologists and physicians about patient outcomes. We agree that timely
communication is important to patient satisfaction, but are worried that a
focus on turn-around time may increase fragmentation. However, in many cases
the challenge exists in communication between electronic or paper health
records and not necessarily in the actual specimen result turnaround time. For
these reasons, we are unable to provide our support for this measure.
(Submitted by: The College of American Pathologists)
- (Early public comment)Pathology has very few indicators and this
appears to be a reasonable one. The objectives align with better patient care
outcomes, better communication among providers, and less errors due to
incomplete information in the hands of the treating physicians. Most lab
information systems should be able to generate these data without undue
programming issues. There is no equivalent measure in the current set.
(Submitted by: American Society of Dermatopathology)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-217)
|
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- (Early public comment)While AGA agrees that the intent of this
measure has some merit, AGA does not at this time support inclusion of this
measure on the list of measures to be finalized for PQRS implementation
(Submitted by: American Gastroenterological Association)
- (Early public comment)ASGE does not support advancement of this
measure at this time as the measure concept lacks sufficient evidence to show
importance to measure and variation in performance. (Submitted by: American
Society for Gastrointestinal Endoscopy)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)On behalf of Hep B United, we appreciate the
opportunity to offer comments on the 2015 Measures Under Consideration by the
Measures Application Partnership at the National Quality Forum. Hep B United
is a national coalition comprised of 30 community-based coalitions and
national organizations with a reach of over 4 million, to address and
eliminate hepatitis B, the leading cause of liver cancer and a major health
disparity among Asian Americans and Pacific Islanders. Our collective goals
are to raise the profile of hepatitis B and liver cancer as an urgent public
health priority, increase hepatitis B testing and vaccination, and improve
access to care and treatment for individuals living with hepatitis B. We
strongly support the measures under consideration for Medicare beneficiaries
living with chronic viral hepatitis and liver disease, particularly the
following process and outcome measures under the Merit-Based Incentive Payment
System program: • MUC15-210: Hepatitis A vaccination for patients with
cirrhosis • MUC15-211: Hepatitis B vaccination for patients with cirrhosis
• MUC15-217: Screening for Hepatoma in patients with Chronic Hepatitis B
• MUC15-220: Hepatitis B vaccination for patients with Chronic Hepatitis C
• MUC15-229: Hepatitis C Virus (HCV)- Sustained Virological Response (SVR)
These measures align with our coalition’s priorities to increase hepatitis B
testing and vaccination in high-risk populations and improve access to care
and treatment for individuals living with chronic hepatitis B to prevent
end-stage liver disease and liver cancer. Of the identified and reported
cases of hepatitis B virus infection in the United States between 2007 and
2012, 15.6% were over the age of 65 and part of the Medicare covered
population. It is vital that seniors diagnosed with chronic hepatitis B be
linked to care and monitored for hepatocellular carcinoma, thus, we
particularly commend the inclusion of MUC15-217: Screening for Hepatoma in
patients with Chronic Hepatitis B. Additionally, we respectfully take this
opportunity to encourage the Centers for Medicare and Medicaid (CMS) to
consider measures for screening for hepatitis B virus infection for those
individuals at high risk. An estimated 67% of individuals do not know they
have chronic hepatitis B including those who are part of the Medicare covered
population. It is imperative that CMS consider a National Coverage
Determination for this service, to match the U.S. Preventive Services Task
Force “B” grade recommendation for hepatitis B screening in persons at high
risk for infection. We thank the NQF Measures Application Partnership for
your work and consideration of our comments. HBU greatly appreciates this
opportunity to provide input to the 2015 Measures Under Consideration that
impact the health of Medicare beneficiaries living with chronic viral
hepatitis and liver disease. Please do not hesitate to contact Hep B United at
kate.moraras@hepb.org with any questions or further discussion on our
comments. (Submitted by: Hep B United)
- (Early public comment)December 7, 2015 RE: 2015 Measures under
Consideration by the National Quality Forum (NQF) Measure Applications
Partnership (MAP) On behalf of the Hepatitis B Foundation (HBF), we appreciate
the opportunity to offer comments on the 2015 Measures Under Consideration by
the Measures Application Partnership at the National Quality Forum. The
Hepatitis B Foundation is the only national nonprofit organization solely
dedicated to finding a cure for hepatitis B and improving the quality of life
for those affected worldwide through research, education and patient advocacy.
Our commitment includes funding focused research, promoting disease awareness,
supporting immunization and treatment initiatives, and serving as the primary
source of information for patients and their families, the medical and
scientific community, and the general public. We strongly support the measures
under consideration for Medicare beneficiaries living with chronic viral
hepatitis and liver disease, particularly the following process and outcome
measures under the Merit-Based Incentive Payment System program: ? MUC15-210:
Hepatitis A vaccination for patients with cirrhosis -MUC15-211: Hepatitis B
vaccination for patients with cirrhosis -MUC15-217: Screening for Hepatoma in
patients with Chronic Hepatitis B -MUC15-220: Hepatitis B vaccination for
patients with Chronic Hepatitis C -MUC15-229: Hepatitis C Virus (HCV)-
Sustained Virological Response (SVR) These measures align with HBF’s
priorities to increase hepatitis B testing and vaccination in high-risk
populations and improve access to care and treatment for individuals living
with chronic hepatitis B to prevent end-stage liver disease and liver cancer.
Of the identified and reported cases of hepatitis B virus infection in the
United States between 2007 and 2012, 15.6% were over the age of 65 and part of
the Medicare covered population. It is vital that seniors diagnosed with
chronic hepatitis B be linked to care and monitored for hepatocellular
carcinoma, thus, we particularly commend the inclusion of MUC15-217: Screening
for Hepatoma in patients with Chronic Hepatitis B. Additionally, we
respectfully take this opportunity to encourage the Centers for Medicare and
Medicaid (CMS) to consider measures for screening for hepatitis B virus
infection for those individuals at high risk. An estimated 67% of individuals
do not know they have chronic hepatitis B including those who are part of the
Medicare covered population. It is imperative that CMS consider a National
Coverage Determination for this service, to match the U.S. Preventive Services
Task Force “B” grade recommendation for hepatitis B screening in persons at
high risk for infection. We thank the NQF Measures Application Partnership for
your work and consideration of our comments. HBU greatly appreciates this
opportunity to provide input to the 2015 Measures Under Consideration that
impact the health of Medicare beneficiaries living with chronic viral
hepatitis and liver disease. Please do not hesitate to contact the Hepatitis B
Foundation Executive Director at joan.block@hepb.org with any questions or
further discussion on our comments. Sincerely, Joan Block, Executive Director
Hepatitis B Foundation (Submitted by: Hepatitis B Foundation)
- (Early public comment)RE: 2015 Measures under Consideration As
participants in the Adult Vaccine Access Coalition (AVAC), we are grateful for
the opportunity to offer our comments on Measures under Consideration by the
Measure Applications Partnership (MAP) at the National Quality Forum (NQF).
AVAC consists of more than 40 organizational leaders in health and public
health that are committed to tackling the range of barriers to adult
immunization and to raising awareness of the importance of adult immunization.
AVAC works towards common legislative and regulatory solutions that will
strengthen and enhance access to adult immunization across the health care
system. Our mission is informed by a growing body of scientific and empirical
evidence in support of the benefits immunizations provide by improving health,
protecting lives against a variety of debilitating and potentially deadly
conditions and saving costs to the healthcare system and to society as a
whole. We appreciate NQF’s leadership in the area of adult vaccines,
particularly the August 2014 report, "Priority Setting for Healthcare
Performance Measurement: Addressing Performance Measure Gaps for Adult
Immunizations." One of AVAC’s key coalition priorities is to advocate for
federal benchmarks and measures to encourage health plans to track, report and
achieve increased adult immunization rates. We believe the vaccine related
measures under MAP consideration make progress toward closing the measure gaps
identified in the report: First, we commend NQF for considering process
measures for Medicare beneficiaries with liver diseases, including Hepatitis A
and Hepatitis B measures for cirrhosis patients (MUC15-210 and MUC15-211) and
Hep B vaccination for patients with chronic Hepatitis C (MUC15-220), as well
as a flu vaccine measure for end stage renal disease (ESRD) patients
(MUC15-761). Our coalition strongly believes that consistent and improved
access to the range of Advisory Committee on Immunization Practices (ACIP)
recommended vaccines for adults will result in improved health outcomes and
better quality of life for Medicare beneficiaries. As such, the vaccine
process measures under consideration by NQF for the MIPS build upon core
immunization measures currently employed by CMS under the Physician Quality
Reporting System (PQRS). We urge NQF to continue its work with CMS to ensure
that the core set of immunization process measures included in the Medicare
Incentive Payment System (MIPS) are up-to-date and reflect current ACIP
recommendations. We also encourage NQF to continue to identify, develop and
test immunization process measures that will improve the overall health for
Medicare patients living with other chronic conditions such as heart disease
and diabetes under the new MIPS. Additionally, we support the inclusion of
MUC15-1132, Percent of Skilled Nursing Facility Residents Who Were Assessed
and Appropriately Given the Influenza Vaccine. This important process measure
complements and reinforces CMS’ efforts to improve education and awareness of
long-term care facility residents and their representatives of the risks and
benefits of immunization against a variety of preventable conditions .
Long-term care facility residents, especially those with chronic conditions,
are at increased risk for influenza and disproportionately suffer from
influenza-related complications such as pneumonia, making immunization
particularly important for patient health and safety. We would also encourage
NQF to prioritize the development of an updated pneumococcal immunization
measures that reflects the current Advisory Committee for Immunization
Practice (ACIP) recommendations for PCV13 and PPSV23 vaccination in adults age
65 and older as well as at risk adults ages 19-64 for use across various
health care settings. The Health and Well-Being Committee for the National
Quality Forum (NQF) recently proposed standards specifications for
pneumococcal measures in order to better align measures across healthcare
settings and to bring measures in accordance with ACIP recommendations. AVAC
encourages NQF to work with CMS toward that end since it reflects CMS' broader
goals around quality measure alignment. Lastly, we would ask NQF to further
coordinate with CMS and prioritize the identification, development testing and
endorsement of vaccine measures for application by other CMS programs in
addition to the ones listed for 2015. For example, the recently finalized CMS
rule on Medicare home health value-based purchasing includes a new measure
entitled, “Herpes Zoster (Shingles) Vaccination: Has the Patient Ever Received
the Shingles Vaccination?) . Zoster vaccination measurement was identified as
an age-specific gap priority in NQF’s August 2014 adult immunization measure
gap report . Shingles affects a million Americans each year, half of whom are
adults age 60 and older. This extremely debilitating condition takes a
significant toll on Medicare beneficiaries’ health and quality of life and
also costs millions in health care dollars annually. Thank you for your work
to advance health and wellbeing through your stewardship and leadership in
quality measure identification, development and deployment. We greatly
appreciate the opportunity to share our perspective on the vaccine related
process measures currently under consideration. Should you have any questions
or would like to discuss our comments or adult immunization issues, please
contact the AVAC Coalition Manager at (202) 540-1070 or
info@adultvaccinesnow.org. Sincerely, American College of Preventive Medicine
Asian & Pacific Islander American Health Forum Association for
Professionals in Infection Control and Epidemiology GSK Hepatitis B
Foundation Hep B United National Association of County and City Health
Officials National Alliance of State & Territorial AIDS Directors National
Foundation for Infectious Diseases National Viral Hepatitis Roundtable
Novavax Sanofi Pasteur The Gerontological Society of America Trust for
America’s Health (Submitted by: Adult Vaccine Access Coalition)
- (Early public comment)On behalf of the Association of Asian Pacific
Community Health Organizations (AAPCHO), we appreciate the opportunity to
provide comments on the 2015 Measures Under Consideration by the Measures
Application Partnership at the National Quality Forum. AAPCHO is a national
not-for-profit association of 35 community-based health care organizations, 29
of which are Federally Qualified Health Centers (FQHCs). AAPCHO members are
dedicated to promoting advocacy, collaboration, and leadership to improve the
health status and access of medically underserved AA&NHOPIs in the U.S.,
its territories, and its freely associated states. AAPCHO’s members provide
linguistically and culturally competent care to millions of vulnerable Asian
Americans, Native Hawaiians, and Other Pacific Islanders (AA & NHOPIs).
Many of our members serve a higher than average percentage of patients with
hepatitis B and C, as both diseases have high prevalence rates in Asian
Americans and Pacific Islanders. Because of the high rates of hepatitis B
found in many of our member centers, AAPCHO co-founded Hep B United, a
national coalition of over 30 local coalitions working to address hepatitis B
through education, screening, vaccination, and linkage-to-care efforts. As
such, we strongly support the measures under consideration for Medicare
beneficiaries living with chronic viral hepatitis and liver disease. We
particularly support the following process and outcome measures under the
Merit-Based Incentive Payment System program: • MUC15-210: Hepatitis A
vaccination for patients with cirrhosis • MUC15-211: Hepatitis B vaccination
for patients with cirrhosis • MUC15-217: Screening for Hepatoma in patients
with Chronic Hepatitis B • MUC15-220: Hepatitis B vaccination for patients
with Chronic Hepatitis C • MUC15-229: Hepatitis C Virus (HCV)- Sustained
Virological Response (SVR) These measures align with Hep B United and AAPCHO’s
priorities to increase hepatitis B testing and vaccination in the high-risk
populations that AAPCHO members serve, and improve access to care and
treatment for individuals living with chronic hepatitis B to prevent end-stage
liver disease and liver cancer. Of the identified and reported cases of
hepatitis B virus infection in the United States between 2007 and 2012, 15.6%
were over the age of 65 and part of the Medicare covered population. It is
vital that seniors diagnosed with chronic hepatitis B be linked to care and
monitored for hepatocellular carcinoma, thus, we particularly commend the
inclusion of MUC15-217: Screening for Hepatoma in patients with Chronic
Hepatitis B. We respectfully take this opportunity to encourage the Centers
for Medicare and Medicaid (CMS) to consider measures for screening for
hepatitis B virus infection for those individuals at high risk. An estimated
67% of individuals do not know they have chronic hepatitis B including those
who are part of the Medicare covered population. It is imperative that CMS
consider a National Coverage Determination to screen individuals at risk for
hepatitis B, matching the U.S. Preventive Services Task Force’s “B” grade
recommendation for hepatitis B screening in persons at high risk for
infection. We thank the NQF Measures Application Partnership for your work and
consideration of our comments. AAPCHO greatly appreciates this opportunity to
provide input to the 2015 Measures Under Consideration that impact the health
of Medicare beneficiaries living with chronic viral hepatitis and liver
disease. Please contact Isha Weerasinghe, AAPCHO’s Director of Policy and
Advocacy at isha@aapcho.org if you have any questions or comments. Thank you,
Jeffrey Caballero, MPH Executive Director (Submitted by: Association of Asian
Pacific Community Health Organizations)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-220)
|
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- (Early public comment)While AGA agrees that the intent of this
measure has some merit, AGA does not at this time support inclusion of this
measure on the list of measures to be finalized for PQRS implementation
(Submitted by: American Gastroenterological Association)
- (Early public comment)Inclusion of these measures will build on
existing immunization-related measures currently used in the Physician Quality
Reporting System to help ensure that Medicare beneficiaries benefit from these
important vaccinations. (Submitted by: Trust for America's
Health)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)On behalf of Hep B United, we appreciate the
opportunity to offer comments on the 2015 Measures Under Consideration by the
Measures Application Partnership at the National Quality Forum. Hep B United
is a national coalition comprised of 30 community-based coalitions and
national organizations with a reach of over 4 million, to address and
eliminate hepatitis B, the leading cause of liver cancer and a major health
disparity among Asian Americans and Pacific Islanders. Our collective goals
are to raise the profile of hepatitis B and liver cancer as an urgent public
health priority, increase hepatitis B testing and vaccination, and improve
access to care and treatment for individuals living with hepatitis B. We
strongly support the measures under consideration for Medicare beneficiaries
living with chronic viral hepatitis and liver disease, particularly the
following process and outcome measures under the Merit-Based Incentive Payment
System program: • MUC15-210: Hepatitis A vaccination for patients with
cirrhosis • MUC15-211: Hepatitis B vaccination for patients with cirrhosis
• MUC15-217: Screening for Hepatoma in patients with Chronic Hepatitis B
• MUC15-220: Hepatitis B vaccination for patients with Chronic Hepatitis C
• MUC15-229: Hepatitis C Virus (HCV)- Sustained Virological Response (SVR)
These measures align with our coalition’s priorities to increase hepatitis B
testing and vaccination in high-risk populations and improve access to care
and treatment for individuals living with chronic hepatitis B to prevent
end-stage liver disease and liver cancer. Of the identified and reported
cases of hepatitis B virus infection in the United States between 2007 and
2012, 15.6% were over the age of 65 and part of the Medicare covered
population. It is vital that seniors diagnosed with chronic hepatitis B be
linked to care and monitored for hepatocellular carcinoma, thus, we
particularly commend the inclusion of MUC15-217: Screening for Hepatoma in
patients with Chronic Hepatitis B. Additionally, we respectfully take this
opportunity to encourage the Centers for Medicare and Medicaid (CMS) to
consider measures for screening for hepatitis B virus infection for those
individuals at high risk. An estimated 67% of individuals do not know they
have chronic hepatitis B including those who are part of the Medicare covered
population. It is imperative that CMS consider a National Coverage
Determination for this service, to match the U.S. Preventive Services Task
Force “B” grade recommendation for hepatitis B screening in persons at high
risk for infection. We thank the NQF Measures Application Partnership for
your work and consideration of our comments. HBU greatly appreciates this
opportunity to provide input to the 2015 Measures Under Consideration that
impact the health of Medicare beneficiaries living with chronic viral
hepatitis and liver disease. Please do not hesitate to contact Hep B United at
kate.moraras@hepb.org with any questions or further discussion on our
comments. (Submitted by: Hep B United)
- (Early public comment)December 7, 2015 RE: 2015 Measures under
Consideration by the National Quality Forum (NQF) Measure Applications
Partnership (MAP) On behalf of the Hepatitis B Foundation (HBF), we appreciate
the opportunity to offer comments on the 2015 Measures Under Consideration by
the Measures Application Partnership at the National Quality Forum. The
Hepatitis B Foundation is the only national nonprofit organization solely
dedicated to finding a cure for hepatitis B and improving the quality of life
for those affected worldwide through research, education and patient advocacy.
Our commitment includes funding focused research, promoting disease awareness,
supporting immunization and treatment initiatives, and serving as the primary
source of information for patients and their families, the medical and
scientific community, and the general public. We strongly support the measures
under consideration for Medicare beneficiaries living with chronic viral
hepatitis and liver disease, particularly the following process and outcome
measures under the Merit-Based Incentive Payment System program: -MUC15-210:
Hepatitis A vaccination for patients with cirrhosis -MUC15-211: Hepatitis B
vaccination for patients with cirrhosis -MUC15-217: Screening for Hepatoma in
patients with Chronic Hepatitis B -MUC15-220: Hepatitis B vaccination for
patients with Chronic Hepatitis C -MUC15-229: Hepatitis C Virus (HCV)-
Sustained Virological Response (SVR) These measures align with HBF’s
priorities to increase hepatitis B testing and vaccination in high-risk
populations and improve access to care and treatment for individuals living
with chronic hepatitis B to prevent end-stage liver disease and liver cancer.
Of the identified and reported cases of hepatitis B virus infection in the
United States between 2007 and 2012, 15.6% were over the age of 65 and part of
the Medicare covered population. It is vital that seniors diagnosed with
chronic hepatitis B be linked to care and monitored for hepatocellular
carcinoma, thus, we particularly commend the inclusion of MUC15-217: Screening
for Hepatoma in patients with Chronic Hepatitis B. Additionally, we
respectfully take this opportunity to encourage the Centers for Medicare and
Medicaid (CMS) to consider measures for screening for hepatitis B virus
infection for those individuals at high risk. An estimated 67% of individuals
do not know they have chronic hepatitis B including those who are part of the
Medicare covered population. It is imperative that CMS consider a National
Coverage Determination for this service, to match the U.S. Preventive Services
Task Force “B” grade recommendation for hepatitis B screening in persons at
high risk for infection. We thank the NQF Measures Application Partnership for
your work and consideration of our comments. HBU greatly appreciates this
opportunity to provide input to the 2015 Measures Under Consideration that
impact the health of Medicare beneficiaries living with chronic viral
hepatitis and liver disease. Please do not hesitate to contact the Hepatitis B
Foundation Executive Director at joan.block@hepb.org with any questions or
further discussion on our comments. Sincerely, Joan Block, Executive Director
Hepatitis B Foundation (Submitted by: Hepatitis B Foundation)
- (Early public comment)On behalf of the Association of Asian Pacific
Community Health Organizations (AAPCHO), we appreciate the opportunity to
provide comments on the 2015 Measures Under Consideration by the Measures
Application Partnership at the National Quality Forum. AAPCHO is a national
not-for-profit association of 35 community-based health care organizations, 29
of which are Federally Qualified Health Centers (FQHCs). AAPCHO members are
dedicated to promoting advocacy, collaboration, and leadership to improve the
health status and access of medically underserved AA&NHOPIs in the U.S.,
its territories, and its freely associated states. AAPCHO’s members provide
linguistically and culturally competent care to millions of vulnerable Asian
Americans, Native Hawaiians, and Other Pacific Islanders (AA & NHOPIs).
Many of our members serve a higher than average percentage of patients with
hepatitis B and C, as both diseases have high prevalence rates in Asian
Americans and Pacific Islanders. Because of the high rates of hepatitis B
found in many of our member centers, AAPCHO co-founded Hep B United, a
national coalition of over 30 local coalitions working to address hepatitis B
through education, screening, vaccination, and linkage-to-care efforts. As
such, we strongly support the measures under consideration for Medicare
beneficiaries living with chronic viral hepatitis and liver disease. We
particularly support the following process and outcome measures under the
Merit-Based Incentive Payment System program: • MUC15-210: Hepatitis A
vaccination for patients with cirrhosis • MUC15-211: Hepatitis B vaccination
for patients with cirrhosis • MUC15-217: Screening for Hepatoma in patients
with Chronic Hepatitis B • MUC15-220: Hepatitis B vaccination for patients
with Chronic Hepatitis C • MUC15-229: Hepatitis C Virus (HCV)- Sustained
Virological Response (SVR) These measures align with Hep B United and AAPCHO’s
priorities to increase hepatitis B testing and vaccination in the high-risk
populations that AAPCHO members serve, and improve access to care and
treatment for individuals living with chronic hepatitis B to prevent end-stage
liver disease and liver cancer. Of the identified and reported cases of
hepatitis B virus infection in the United States between 2007 and 2012, 15.6%
were over the age of 65 and part of the Medicare covered population. It is
vital that seniors diagnosed with chronic hepatitis B be linked to care and
monitored for hepatocellular carcinoma, thus, we particularly commend the
inclusion of MUC15-217: Screening for Hepatoma in patients with Chronic
Hepatitis B. We respectfully take this opportunity to encourage the Centers
for Medicare and Medicaid (CMS) to consider measures for screening for
hepatitis B virus infection for those individuals at high risk. An estimated
67% of individuals do not know they have chronic hepatitis B including those
who are part of the Medicare covered population. It is imperative that CMS
consider a National Coverage Determination to screen individuals at risk for
hepatitis B, matching the U.S. Preventive Services Task Force’s “B” grade
recommendation for hepatitis B screening in persons at high risk for
infection. We thank the NQF Measures Application Partnership for your work and
consideration of our comments. AAPCHO greatly appreciates this opportunity to
provide input to the 2015 Measures Under Consideration that impact the health
of Medicare beneficiaries living with chronic viral hepatitis and liver
disease. Please contact Isha Weerasinghe, AAPCHO’s Director of Policy and
Advocacy at isha@aapcho.org if you have any questions or comments. Thank you,
Jeffrey Caballero, MPH Executive Director (Submitted by: Association of Asian
Pacific Community Health Organizations)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-221)
|
- Medtronic fully supports quality care for patients with Ulcerative
colitis. However, we agree with MAP's recommendation that this measure is not
appropriate for consideration in MIPS. Colonoscopy is the only surveillance
modality included in the measure numerator. In addition to colonoscopy, there
are other diagnostics that can also be used for surveillance of Ulcerative
colitis. We encourage MAP to seek inclusion of other guideline-supported
technologies in the measure numerator before CMS considers this measure for
use in MIPS or other quality programs. (Submitted by: Medtronic)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- ACS believes the development of the surveillance colonoscopy for dysplasia
in ulcerative colitis measure is premature. Without interoperability, we
believe that this measure will be too burdensome for providers to report.
(Submitted by: American College of Surgeons)
- (Early public comment)While AGA agrees that the intent of this
measure has some merit, AGA does not at this time support inclusion of this
measure on the list of measures to be finalized for PQRS implementation
(Submitted by: American Gastroenterological Association)
- (Early public comment)While ASGE finds the inclusion of
surveillance measures in public reporting programs worthy of exploration, this
measure, as specified, would not deter overutilization of colonoscopy. The
recommendations for surveillance colonoscopy in Ulcerative Colitis are based
on how long the patient has had the disease. (Submitted by: American Society
for Gastrointestinal Endoscopy)
- (Early public comment)AdvaMed fully supports quality care for
patients with Ulcerative colitis; however, we do not believe that this measure
is appropriate for consideration in MIPS. In addition, this measure has never
been submitted to NQF and thus is not NQF-endorsed. Colonoscopy is the only
surveillance modality included in the measure numerator. In addition to
colonoscopy, there are other diagnostics that can also be used for
surveillance of Ulcerative colitis. We encourage MAP to seek inclusion of
other guideline-supported technologies in the measure numerator before CMS
considers this measure for use in MIPS or other quality programs. (Submitted
by: AdvaMed)
- (Early public comment)Medtronic fully supports quality care for
patients with Ulcerative colitis; however, we do not believe that this measure
is appropriate for consideration in MIPS. Colonoscopy is the only
surveillance modality included in the measure numerator. In addition to
colonoscopy, there are other diagnostics that can also be used for
surveillance of Ulcerative colitis. We encourage MAP to seek inclusion of
other guideline-supported technologies in the measure numerator before CMS
considers this measure for use in MIPS or other quality programs. (Submitted
by: Medtronic)
(Program: Hospice Quality Reporting Program; MUC
ID: MUC15-227) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Alive
Hospice)
- We encourage this measure to be tested in Medicaid and other payers, and
across age-bands. Hospice care when death is imminent is important to all age
populations. (Submitted by: Children's Hospital Association)
- While NPHI understands and supports the need to capture appropriate,
timely patient care during the last the days of life, this retrospective
measure does not accurately assess or encourage high quality hospice care.
“Imminence of death” represents a critical period in the life of a patient,
however neither the time frame nor the quality (e.g., patient safety, symptom
management, level of comfort, spiritual and/or psychosocial resolution) of
that period is adequately captured by this measure. While NPHI appreciates the
recognition of the diverse scope of individuals visiting hospice patients
during the last days of life, capturing one visit by a medical professional in
the last three days of life as compared to at least two visits from
non-medical professionals in the last seven days of life are arbitrary
assessments of sufficient or quality visits that do not take into account the
needs or preferences of the patient, family, or caregiver. NPHI strongly
agrees that this measure requires further testing and analytics and supports
the preliminary recommendation that the measure continue to be developed.
Beyond testing these measures, NPHI urges that additional efforts be made to
develop more meaningful measures that capture the quality of patient care
throughout their hospice experience. (Submitted by: National Partnership for
Hospice Innovation (NPHI))
- For the imminent death hospice visits metrics, I'm not sure any value will
be gained by knowing, in hindsight, whether or not we made visits. Will this
change our practice? Doubtful, since none of us can accurately predict death.
This kind of retrospective indicator seems to be pretty pointless. (Submitted
by: Alive Hospice, Inc)
- This is a tough one because we believe and research has shown that
patients and families do benefit from visits within the last week of life.
Several significant difficulties however make it a challenge to get into
patient's home during this time; 1) prognosticating the last 7 days is not
impossible, but is highly unreliable, 2) patients and families have choice and
rights, and may not allow or request visits, 3) cultural and spiritual beliefs
and values also may prevent visits from any or specific members of the
interdisciplinary team. The 7-day vs 3-day timeframe is definitely less
constrictive in terms of the prognostication piece. Setting a 2-visit
threshold seems excessive. (Submitted by: Delaware Hospice,
Inc.)
- Support and symptom management for imminently dying patients is a high
priority and given the unique and critical role of family caregivers in
hospice, ensuring that caregivers are prepared and supported at this time is
equally important. A comprehensive and holistic assessment of the needs of
the imminently dying patient and his/her family caregivers is the
responsibility of the entire interdisciplinary team – and each member of the
team may have a role/contribution at that time. This measure has the
potential to capture the breadth and depth of care provided for the imminently
dying patient/family unit. However, there are some issues that need
thoughtful consideration as CMS proceeds with further development. 1) A
high proportion of patients die within 7 days of admission to hospice services
and virtually all patients will have an initial assessment by a RN.
Consequently, a ceiling effect for Measure 1 is likely. Consequently, we
recommend increasing the number of visits in the numerator to 2 for Measure 1
and excluding patients with a LOS of 1 day. 2. Patients with a LOS of 1 day
should also be excluded from Measure 2 Note: The numerator description and
the MAP rationale as presented in the MUC list Excel spreadsheet are not
consistent. The numerator description includes visits from therapists and
volunteers as eligible for the measure and the MAP rationale does not. Nor is
the distinction between the two measures, particularly the two time frames,
included in the numerator description. PA's are also listed, but at this time
PA's cannot provide hospice care. That these discrepancies exist is
unfortunate and need to be taken into consideration when interpreting comments
on these measures. (Submitted by: National Hospice & Palliative Care
Organization )
- We support MAP’s preliminary decision to encourage continued development
of this measure. This measure has been proposed to be divided into two
separate measures: Measure 1 would assess the percent of patients receiving at
least one visit from registered nurses, physicians, nurse practitioners or
physician assistants in the last three days of life. Measure 2 would assess
the percent of patients receiving at least two visits from medical social
workers, chaplains or spiritual counselors, licensed practical nurses,
therapists, hospice aides and volunteers in the last seven days of life. We
support the determination that visits are an important service to patients at
the end of life. Prudent hospice programs provide support to patients via
on-site visits and phone calls to ensure that pain and other symptoms are
managed well for the patient and that caregivers are coping well with meeting
the patient’s needs at the end of life. However, the quantity of visits
provided does not necessarily translate to quality of care. Also, patients and
families may not draw such a conclusion either as it is not uncommon when a
patient is actively dying for a family who is coping well to limit hospice
visits to only those staff they consider the most pertinent. It is always the
focus of the hospice to honor the expressed personal, cultural and spiritual
wishes of the patient and family during such a sensitive time. 1. We
recommend a clarification or expansion of the definition of “visits” as a
quality measure during the last 7 days of life. Are visits only those made
in-person or can telephone calls be counted for some disciplines, such as
social workers and chaplains? As the patient’s condition declines many
families want to limit the number of “outsiders” that come into the home so
that family and close friends can maximize their time with the patient. Phone
support may be all that they will accept from any discipline other than the
nurse. It would not be typical for therapy staff or hospice aides to provide
services by phone, but most other disciplines can. We note that the MAP
Rationale does not include volunteers, but the numerator does include them.
This inconsistency needs to be addressed as the measure development
progresses. The measure includes nurse practitioners, but many hospices do not
employ nurse practitioners and this needs to be considered. Physician
assistants are included in the measure, but at this time CMS does not
recognize PAs in hospice care, and in fact, PAs cannot prescribe drugs for
hospice patients per the Medicare Hospice Conditions of Participation. We are
aware of initiatives to change regulations to allow PAs to be involved. We
suggest that the measure add qualifying language to address this issue. The
measure language needs to be written in such a manner that if PAs are
authorized to serve as the attending physician in the future their visits can
be counted. We request clarity on this so that hospices are not misled into
thinking that PA visits are allowed in the last 7 days of life. 2. We
recommend that hospices be given ample time to develop new systems or revise
current processes, and that their EMR vendors be given time to make system
upgrades to ensure the feasibility of reporting volunteer visits. We
acknowledge that volunteers are an important part of the hospice team.
However, there are administrative burdens that most hospices would face to be
able to report volunteer visits. In many hospice programs, volunteer
documentation is not integrated into the electronic medical record (EMR). Many
EMR systems are not accessible to volunteers by nature of their design as they
require remote access into the agency’s server and this is not logistically
feasible. Many hospices have to manually scan volunteer documentation into the
medical record. The time of visits is captured for purposes of reporting the
level of activity as required by the Medicare Conditions of Participation, but
the visit data is not reported in a manner that would allow it to easily flow
to the claims for reporting purposes. In addition, the lag time for volunteer
visit notes to be received in the office can be more than just a few days.
Claims would have to be held until the information is received which would
delay reimbursement. The manual entry of these visits would add an additional
administrative burden on top of many others that have been added over the last
several years. 3. We recommend the development of a mechanism where hospices
can report the refusal of services so that quality scores are not impacted by
a patient’s choice of services they choose to have, or not to have. For all
disciplines, except nursing, we request that MAP and CMS be cognizant of the
patient’s right to refuse visits. Many patients choose not to have volunteer
services or chaplain services. A significant number of hospice patients cannot
benefit from the services of a physical, occupational or speech therapist.
Some patients have family or hired caregivers that provide personal care
services so that the hospice aide is not needed. If a patient chooses only to
have visits from the social worker, most hospices would not meet Measure 2 as
it is not likely that a social worker would need to visit twice in a week.
Those patients that refuse all services except for nursing would not meet
Measure 2 at all. We request the development of a mechanism where hospices can
report the refusal of services so that quality scores are not impacted by a
patient’s choice of services or lack thereof. 4. We recommend additional study
of the exclusions for the measures. The exclusions for these measures are
“Patients who received any continuous home care, respite care, or general
inpatient care in the last seven days of life,” and Measure 2 adds “Patients
with a length of stay of one day” as well. We do not understand the “one day”
length of stay exclusion. If the measures are to address visits in the last
week of life then patients who die in less than 7 days should be excluded or
hospices will be unfairly penalized. The Medicare Conditions of Participation
provide a timeframe of 5 days for hospices to complete a comprehensive
assessment. At a minimum 5 days should be the shortest length of stay
considered for inclusion. Many short stay patients only want the nurse and
possibly the social worker. A patient who is imminently dying would rarely
have therapy. Many have their own spiritual support and families would not be
leaving the patient so a volunteer for respite or support would not be
utilized. Thus, if the LOS is less than 7 days then only one visit may have
been made by non-nursing, non-MD disciplines. Another option would be to
increase the lookback period to 10 days instead of 7 days. It is important to
recognize that a certain number of patients die unexpectedly due to sudden
events and the frequency of visits made to them will not have likely increased
in the prior 7 days. There needs to be a way to report unexpected deaths.
Another exclusion is for patients needing GIP or CHC at any time during the
last week of life. This means that many of the patients with the most acute
symptom management needs are being excluded. The remaining patients are apt to
need fewer visits and that needs to be weighed in determining what scores are
expected and considered a sign of quality. 5. We recommend that the measures
be properly vetted to ensure they truly reflect the quality of hospice care.
Inappropriate conclusions may be drawn from the measure scores. Visit
measures do not take into account the characteristics of the population served
by the hospice. And as stated earlier, quantity does not equal quality. The
actual care provided during the visits is not reflected in the number of
visits made by various disciplines. Any utilization of visit measures would
have to be explained clearly to consumers so they can understand what
conclusions to draw from the data. In addition to the utilization of measures
for gauging quality of care and public reporting, measures need to be assessed
and reported in a manner that allows the hospice agency to utilize the data in
their performance improvement measures. The variance of Measure 1 at 3 days
and Measure 2 at 7 days can make tracking more difficult for hospices. More
granular measures may have less usefulness to quality improvement efforts.
(Submitted by: The Carolinas Center)
- We appreciate the MAP’s preliminary recommendation to encourage continued
development of this measure and assume the inconsistency between the numerator
and the description of the two measures would be resolved with continued
development. We believe the development of the measure will bring to light
some of the concerns with this measure. For instance, currently there is
difficulty in obtaining the visit data for some of the disciplines, a visit is
not yet defined for the measure, and not all hospices utilize all of the
disciplines (i.e. physician’s assistant, nurse practitioner). This is a fact
even with the recent publication of G-codes for some of the visit types
proposed for this measure (see CMS Change Request 9459) as not all of the
visit types have a corresponding G-code and there is not a
description/definition of the G-codes. Additionally, currently under
Medicare, physician assistants do not have an explicitly defined role. It
would be helpful if the MAP and CMS could provide clarification as to how this
would be addressed should the measure be implemented. Furthermore, hospice
providers have indicated that including such a measure could induce a practice
of unnecessary visits at the end of life in some hospices. We understand that
a purpose of this measure could be to induce necessary visits that may not be
made currently. Any visit measure should not be used in the HQRP unless its
direct relationship to hospice quality has been proven, and the public can
readily draw that connection. The definition of a visit that hospices are
most used to currently is that found in the Medicare Claims Processing Manual,
Chapter 11. Here a visit is described as: The total number of visits does not
imply the total number of activities or interventions provided. To constitute
a visit, the discipline, (as defined above) must have provided care to the
beneficiary. Services provided by a social worker to the beneficiary’s family
also constitute a visit. For example, phone calls, documentation in the
medical/clinical record, interdisciplinary group meetings, obtaining physician
orders, rounds in a facility or any other activity that is not related to the
provision of items or services to a beneficiary, do not count towards a visit
to be placed on the claim. In addition, the visit must be reasonable and
necessary for the palliation and management of the terminal illness and
related conditions as described in the patient’s plan of care. As CMS
acknowledges in this Manual, a visit does not imply the total number of
activities or interventions provided. There are many activities and
interventions that the disciplines listed for this measure provide that we
believe directly impact quality but are not currently counted by hospices as
visits. These include interventions such as hospice physicians consulting
with the attending physician regarding the plan of care, chaplains making
calls to the patient’s established clergy for assistance with implementation
of the plan of care, volunteers providing supportive services to the patient’s
family that reduce caregiver stress while not actually visiting the patient
(i.e. running errands, planting a garden, organizing outstanding bills,
cleaning out a garage and other such items that are causing stress for the
caregiver/patient, etc.). Again, any visit measure should not be used in the
HQRP unless its direct relationship to hospice quality has been proven, and
the public can readily draw that connection. (Submitted by: National
Association for Home & Hospice Care)
- We appreciate the MAP’s preliminary recommendation to encourage continued
development of this measure and assume the inconsistency between the numerator
and the description of the two measures would be resolved with continued
development. Hospices do not currently collect and report all the visit data
that is included in this measure. Some is captured on the Medicare hospice
claims, but even with the additional G-codes CMS published for hospices (see
change request 9459) not all visit types for this measure can be captured
consistently across hospices and there is no definitions/descriptions for the
new G-codes. This leaves some of the codes open to interpretation. Moreover,
a visit measure does just that – measure the quantity of visits. If this
measure were implemented, it would create a burden for those programs not
having the capability/infrastructure to collect and report this visit data.
For instance, in many hospices, volunteers document on paper and their visits
are not captured electronically for collection and reporting. The same is true
of chaplain visits in some hospices. Regardless, any claims-based or visit
measure utilized in the HQRP must be properly vetted to ensure that it is, in
fact, related to quality of hospice care. We believe claims-based measures are
practice indicators that do not take into account the condition and other
characteristics of the population served by a hospice. A claims-based measure
should not be used in the HQRP unless its direct relationship to hospice
quality has been proven, and that connection is evident to the public. The
definition of a visit that hospices are most used to currently is that found
in the Medicare Claims Processing Manual, Chapter 11. Here a visit is
described as: The total number of visits does not imply the total number of
activities or interventions provided. To constitute a visit, the discipline,
(as defined above) must have provided care to the beneficiary. Services
provided by a social worker to the beneficiary’s family also constitute a
visit. For example, phone calls, documentation in the medical/clinical
record, interdisciplinary group meetings, obtaining physician orders, rounds
in a facility or any other activity that is not related to the provision of
items or services to a beneficiary, do not count towards a visit to be placed
on the claim. In addition, the visit must be reasonable and necessary for the
palliation and management of the terminal illness and related conditions as
described in the patient’s plan of care. As CMS acknowledges in this Manual, a
visit does not imply the total number of activities or interventions provided.
There are many activities and interventions that the disciplines listed for
this measure provide that we believe directly impact quality but are not
currently counted by hospices as visits. These include interventions such as
hospice physicians consulting with the attending physician regarding the plan
of care, chaplains making calls to the patient’s established clergy for
assistance with implementation of the plan of care, volunteers providing
supportive services to the patient’s family that reduce caregiver stress while
not actually visiting the patient (i.e. running errands, planting a garden,
organizing outstanding bills, cleaning out a garage and other such items that
are causing stress for the caregiver/patient, etc.). Again, any visit measure
should not be used in the HQRP unless its direct relationship to hospice
quality has been proven, and that connection is evident by the public.
(Submitted by: The Home Care & Hospice Association of New
Jersey)
- We appreciate the MAP’s preliminary recommendation to encourage continued
development of this measure and assume the inconsistency between the numerator
and the description of the two measures would be resolved with continued
development. Hospices do not currently collect and report all the visit data
that is included in this measure. Some is captured on the Medicare hospice
claims. Some is captured on the Medicare hospice claims, but even with the
additional G-codes CMS published for hospices (see change request 9459) not
all visit types for this measure can be captured consistently across hospices
and there is no definitions/descriptions for the new G-codes. This leaves
some of the codes open to interpretation. Moreover, a visit measure does just
that – measure the quantity of visits. If this measure were implemented, it
would create a burden for those programs not having the
capability/infrastructure to collect and report this visit data. For instance,
in many hospices, volunteers document on paper and their visits are not
captured electronically for collection and reporting. The same is true of
chaplain visits in some hospices. Regardless, any claims-based or visit
measure utilized in the HQRP must be properly vetted to ensure that it is, in
fact, related to quality of hospice care. We believe claims-based measures are
practice indicators that do not take into account the condition and other
characteristics of the population served by a hospice. A claims-based measure
should not be used in the HQRP unless its direct relationship to hospice
quality has been proven, and that connection can be readily drawn by the
public. (Submitted by: Ohio Council for Home Care & Hospice)
- The way the Hospice Item Set is configured at this time, it does not
include the measure specified in the numerator. I don't understand how this
measure was derived from the current data source. Also, the number of visits
that a patient receives is not necessarily a reflection of the quality of the
care given. This is a measure that could be manipulated to appear "good" that
has no bearing on the actual care provided. (Submitted by: Hospice of
Northeast Georgia Medical Center)
- CAPC urges the MAP to change its preliminary recommendation for MUC15-227
from “Encourage Continued Development” for the inclusion in the Hospice
Quality Reporting Program (HQRP) to “Support”. This measure fills a key gap in
the HQRP, and the literature cited in the HHS rationale clearly demonstrates
the importance of hospice visits for patients in their last week of life to
address their physical, psychological, social, and spiritual needs.
Furthermore, clinicians are familiar with the indicators of imminent death and
it is reasonable that patients should receive and providers be able to
document visits in the last week of like. Therefore, we think this measure
should be recommended for inclusion in the HQRP. (Submitted by: Center to
Advance Palliative Care)
- AAHPM supports this measure set and finds it very reasonable. We encourage
the MAP to change its recommendation and “support” this measure for inclusion
in the Hospice Quality Reporting Program. This measure fills a key gap in the
HQRP, and the literature cited in the HHS rationale clearly demonstrates the
importance of hospice visits for patients in their last week of life to
address their physical, psychological, social, and spiritual needs.
Furthermore, clinicians are familiar with the indicators of imminent death and
it is reasonable that patients should receive and providers be able to
document visits in the last week of like. We would even favor modifying the
measure so that it captures the last 48 or 24 hours of life (as opposed to 72
hours). (Submitted by: American Academy of Hospice and Palliative
Medicine)
- (Early public comment)• MUC15- 227: Hospice Visits When Death Is
Imminent- This measure under consideration does not take into account a number
of factors that will impact outcomes. First, rural and frontier hospice
agencies serve a large geographic area resulting in long travel times for
hospice staff. Many times visits are supplemented by telephone calls from the
hospice staff. Second, there is no differentiation or note in the exclusion
that addresses if the hospice patient is a resident of a nursing home. We
believe that these two factors should be included in the measure, and for that
reason we recommend this measure requires continued development. (Submitted
by: LeadingAge)
- (Early public comment)Hospices do not currently collect and report
all the visit data that is included in this measure and only some of it is
captured on the Medicare hospice claims. The visits for nurses (registered
nurse, licensed professional nurse or nurse practitioner if acting in the role
of a nurse), hospice aides, physicians (or nurse practitioner or physician
assistant if acting as the attending physician), therapists (physical
therapist, occupational therapist or speech language therapist), and medical
social workers are reported on hospice claims but chaplains or spiritual
counselors and volunteers are not. This creates a burden for hospices as they
do not currently have the infrastructure to capture and report this data.
Regardless, any measure utilized in the HQRP must be properly vetted to ensure
that it is, in fact, related to quality of hospice care to reduce the
incidence of inappropriate conclusions that might be drawn from the measure.
We believe visit measures are practice indicators that do not take into
account the condition and other characteristics of the population served by a
hospice nor the quality of care delivered during the visit. A visit measure
should not be used in the HQRP unless its direct relationship to hospice
quality has been proven, and that connection can be readily drawn by the
public. (Submitted by: National Association for Home Care & Hospice
(NAHC))
- (Early public comment)We support the inclusion of all staff
included in the patient's plan of care as part of the calculation of the
quality measure. (Submitted by: Association of Home & Hospice Care of
NC/SC Home Care & Hospice Association)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)Hospices do not currently collect and report
all the visit data that is included in this measure. Some is captured on the
Medicare hospice claims. Specifically, visits for chaplains or spiritual
counselors and volunteers are not currently collected and reported by
hospices. Moreover, a visit measure does just that – measure the quantity of
visits. If this measure were implemented, it would create a burden for those
programs not having the capability/infrastructure to collect and report this
visit data. For instance, in many hospices, volunteers document on paper and
their visits are not captured electronically for collection and reporting. The
same is true of chaplain visits in some hospices. Regardless, any claims-based
or visit measure utilized in the HQRP must be properly vetted to ensure that
it is, in fact, related to quality of hospice care. We believe claims-based
measures are practice indicators that do not take into account the condition
and other characteristics of the population served by a hospice. A
claims-based measure should not be used in the HQRP unless its direct
relationship to hospice quality has been proven, and that connection can be
readily drawn by the public. (Submitted by: The Home Care & Hospice
Association of NJ)
- (Early public comment)Hospices do not currently collect and report
all the visit data that is included in this measure. Some is captured on the
Medicare hospice claims. Specifically, visits for chaplains or spiritual
counselors and volunteers are not currently collected and reported by
hospices. Moreover, a visit measure does just that – measure the quantity of
visits. If this measure were implemented, it would create a burden for those
programs not having the capability/infrastructure to collect and report this
visit data. For instance, in many hospices, volunteers document on paper and
their visits are not captured electronically for collection and reporting. The
same is true of chaplain visits in some hospices. Regardless, any claims-based
or visit measure utilized in the HQRP must be properly vetted to ensure that
it is, in fact, related to quality of hospice care. We believe claims-based
measures are practice indicators that do not take into account the condition
and other characteristics of the population served by a hospice. A
claims-based measure should not be used in the HQRP unless its direct
relationship to hospice quality has been proven, and that connection can be
readily drawn by the public. (Submitted by: Ohio Council for Home Care &
Hospice)
(Program: Merit-Based
Incentive Payment System (MIPS); MUC ID: MUC15-229) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: The Infectious
Diseases Society of America)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- (Early public comment)ASGE supports the advancement of this
measure. (Submitted by: American Society for Gastrointestinal
Endoscopy)
- (Early public comment)We support the inclusion of this measure,
reflecting effective treatment of Hepatitis C (HCV), in the new Medicare
Merit-Based Incentive Payment System (MIPS). The past several years have seen
significant changes in the public health response to the challenge of HCV.
Recognizing that “Baby Boomers” born between 1945 and 1965 account for
three-quarters of the 3.2 million people in the U.S. infected with HCV, the
Centers for Disease Control and Prevention (CDC) in 2012 began recommending
one-time screening of this entire cohort. In the meantime, this population
has begun aging into Medicare. In addition, the heroin epidemic and
heightened detection efforts have contributed to new acute hepatitis C
infections increasing by 151.5 percent in reported cases from 2010 to 2013.
And, over the past several years, newer and more effective HCV treatments have
become available, leading to far higher rates of cure with fewer side effects,
ultimately decreasing the risk of serious outcomes such as liver cancer and
death. To address this epidemic, it is vitally important that increased
screening efforts and improved treatments translate into improved health for
patients, and this measure will help support that goal. (Submitted by: Trust
for America's Health)
- (Early public comment)Unclear why the period of measurement is 11
weeks, rather than 12 weeks. (Submitted by: California Department of Public
Health)
- (Early public comment)On behalf of Hep B United, we appreciate the
opportunity to offer comments on the 2015 Measures Under Consideration by the
Measures Application Partnership at the National Quality Forum. Hep B United
is a national coalition comprised of 30 community-based coalitions and
national organizations with a reach of over 4 million, to address and
eliminate hepatitis B, the leading cause of liver cancer and a major health
disparity among Asian Americans and Pacific Islanders. Our collective goals
are to raise the profile of hepatitis B and liver cancer as an urgent public
health priority, increase hepatitis B testing and vaccination, and improve
access to care and treatment for individuals living with hepatitis B. We
strongly support the measures under consideration for Medicare beneficiaries
living with chronic viral hepatitis and liver disease, particularly the
following process and outcome measures under the Merit-Based Incentive Payment
System program: • MUC15-210: Hepatitis A vaccination for patients with
cirrhosis • MUC15-211: Hepatitis B vaccination for patients with cirrhosis
• MUC15-217: Screening for Hepatoma in patients with Chronic Hepatitis B
• MUC15-220: Hepatitis B vaccination for patients with Chronic Hepatitis C
• MUC15-229: Hepatitis C Virus (HCV)- Sustained Virological Response (SVR)
These measures align with our coalition’s priorities to increase hepatitis B
testing and vaccination in high-risk populations and improve access to care
and treatment for individuals living with chronic hepatitis B to prevent
end-stage liver disease and liver cancer. Of the identified and reported
cases of hepatitis B virus infection in the United States between 2007 and
2012, 15.6% were over the age of 65 and part of the Medicare covered
population. It is vital that seniors diagnosed with chronic hepatitis B be
linked to care and monitored for hepatocellular carcinoma, thus, we
particularly commend the inclusion of MUC15-217: Screening for Hepatoma in
patients with Chronic Hepatitis B. Additionally, we respectfully take this
opportunity to encourage the Centers for Medicare and Medicaid (CMS) to
consider measures for screening for hepatitis B virus infection for those
individuals at high risk. An estimated 67% of individuals do not know they
have chronic hepatitis B including those who are part of the Medicare covered
population. It is imperative that CMS consider a National Coverage
Determination for this service, to match the U.S. Preventive Services Task
Force “B” grade recommendation for hepatitis B screening in persons at high
risk for infection. We thank the NQF Measures Application Partnership for
your work and consideration of our comments. HBU greatly appreciates this
opportunity to provide input to the 2015 Measures Under Consideration that
impact the health of Medicare beneficiaries living with chronic viral
hepatitis and liver disease. Please do not hesitate to contact Hep B United at
kate.moraras@hepb.org with any questions or further discussion on our
comments. (Submitted by: Hep B United)
- (Early public comment)December 7, 2015 RE: 2015 Measures under
Consideration by the National Quality Forum (NQF) Measure Applications
Partnership (MAP) On behalf of the Hepatitis B Foundation (HBF), we appreciate
the opportunity to offer comments on the 2015 Measures Under Consideration by
the Measures Application Partnership at the National Quality Forum. The
Hepatitis B Foundation is the only national nonprofit organization solely
dedicated to finding a cure for hepatitis B and improving the quality of life
for those affected worldwide through research, education and patient advocacy.
Our commitment includes funding focused research, promoting disease awareness,
supporting immunization and treatment initiatives, and serving as the primary
source of information for patients and their families, the medical and
scientific community, and the general public. We strongly support the measures
under consideration for Medicare beneficiaries living with chronic viral
hepatitis and liver disease, particularly the following process and outcome
measures under the Merit-Based Incentive Payment System program: -MUC15-210:
Hepatitis A vaccination for patients with cirrhosis -MUC15-211: Hepatitis B
vaccination for patients with cirrhosis -MUC15-217: Screening for Hepatoma in
patients with Chronic Hepatitis B -MUC15-220: Hepatitis B vaccination for
patients with Chronic Hepatitis C -MUC15-229: Hepatitis C Virus (HCV)-
Sustained Virological Response (SVR) These measures align with HBF’s
priorities to increase hepatitis B testing and vaccination in high-risk
populations and improve access to care and treatment for individuals living
with chronic hepatitis B to prevent end-stage liver disease and liver cancer.
Of the identified and reported cases of hepatitis B virus infection in the
United States between 2007 and 2012, 15.6% were over the age of 65 and part of
the Medicare covered population. It is vital that seniors diagnosed with
chronic hepatitis B be linked to care and monitored for hepatocellular
carcinoma, thus, we particularly commend the inclusion of MUC15-217: Screening
for Hepatoma in patients with Chronic Hepatitis B. Additionally, we
respectfully take this opportunity to encourage the Centers for Medicare and
Medicaid (CMS) to consider measures for screening for hepatitis B virus
infection for those individuals at high risk. An estimated 67% of individuals
do not know they have chronic hepatitis B including those who are part of the
Medicare covered population. It is imperative that CMS consider a National
Coverage Determination for this service, to match the U.S. Preventive Services
Task Force “B” grade recommendation for hepatitis B screening in persons at
high risk for infection. We thank the NQF Measures Application Partnership for
your work and consideration of our comments. HBU greatly appreciates this
opportunity to provide input to the 2015 Measures Under Consideration that
impact the health of Medicare beneficiaries living with chronic viral
hepatitis and liver disease. Please do not hesitate to contact the Hepatitis B
Foundation Executive Director at joan.block@hepb.org with any questions or
further discussion on our comments. Sincerely, Joan Block, Executive Director
Hepatitis B Foundation (Submitted by: Hepatitis B Foundation)
- (Early public comment)On behalf of the Association of Asian Pacific
Community Health Organizations (AAPCHO), we appreciate the opportunity to
provide comments on the 2015 Measures Under Consideration by the Measures
Application Partnership at the National Quality Forum. AAPCHO is a national
not-for-profit association of 35 community-based health care organizations, 29
of which are Federally Qualified Health Centers (FQHCs). AAPCHO members are
dedicated to promoting advocacy, collaboration, and leadership to improve the
health status and access of medically underserved AA&NHOPIs in the U.S.,
its territories, and its freely associated states. AAPCHO’s members provide
linguistically and culturally competent care to millions of vulnerable Asian
Americans, Native Hawaiians, and Other Pacific Islanders (AA & NHOPIs).
Many of our members serve a higher than average percentage of patients with
hepatitis B and C, as both diseases have high prevalence rates in Asian
Americans and Pacific Islanders. Because of the high rates of hepatitis B
found in many of our member centers, AAPCHO co-founded Hep B United, a
national coalition of over 30 local coalitions working to address hepatitis B
through education, screening, vaccination, and linkage-to-care efforts. As
such, we strongly support the measures under consideration for Medicare
beneficiaries living with chronic viral hepatitis and liver disease. We
particularly support the following process and outcome measures under the
Merit-Based Incentive Payment System program: • MUC15-210: Hepatitis A
vaccination for patients with cirrhosis • MUC15-211: Hepatitis B vaccination
for patients with cirrhosis • MUC15-217: Screening for Hepatoma in patients
with Chronic Hepatitis B • MUC15-220: Hepatitis B vaccination for patients
with Chronic Hepatitis C • MUC15-229: Hepatitis C Virus (HCV)- Sustained
Virological Response (SVR) These measures align with Hep B United and AAPCHO’s
priorities to increase hepatitis B testing and vaccination in the high-risk
populations that AAPCHO members serve, and improve access to care and
treatment for individuals living with chronic hepatitis B to prevent end-stage
liver disease and liver cancer. Of the identified and reported cases of
hepatitis B virus infection in the United States between 2007 and 2012, 15.6%
were over the age of 65 and part of the Medicare covered population. It is
vital that seniors diagnosed with chronic hepatitis B be linked to care and
monitored for hepatocellular carcinoma, thus, we particularly commend the
inclusion of MUC15-217: Screening for Hepatoma in patients with Chronic
Hepatitis B. We respectfully take this opportunity to encourage the Centers
for Medicare and Medicaid (CMS) to consider measures for screening for
hepatitis B virus infection for those individuals at high risk. An estimated
67% of individuals do not know they have chronic hepatitis B including those
who are part of the Medicare covered population. It is imperative that CMS
consider a National Coverage Determination to screen individuals at risk for
hepatitis B, matching the U.S. Preventive Services Task Force’s “B” grade
recommendation for hepatitis B screening in persons at high risk for
infection. We thank the NQF Measures Application Partnership for your work and
consideration of our comments. AAPCHO greatly appreciates this opportunity to
provide input to the 2015 Measures Under Consideration that impact the health
of Medicare beneficiaries living with chronic viral hepatitis and liver
disease. Please contact Isha Weerasinghe, AAPCHO’s Director of Policy and
Advocacy at isha@aapcho.org if you have any questions or comments. Thank you,
Jeffrey Caballero, MPH Executive Director (Submitted by: Association of Asian
Pacific Community Health Organizations)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-230)
|
- 1. The numerator for this measure is described as “patients with an HIV
test during period extending from 30 days before STD diagnosis to 30 days
after STD diagnosis.” We suggest this measure’s numerator be specific about
which STDs should prompt HIV testing rather than using the permissive but
non-specific language that is currently employed (“STDs include: syphilis and
gonorrhea”). Moreover, the measure’s description refers to “acute STD
indicative of elevated risk for HIV exposure.” However, we have found that
elevated risk is relative across populations and certain types of infections
may indicate greater or lesser relative risks based on anatomic site or sex.
For example, for men who have sex with men, anorectal Chlamydia trachomatis
(Ct) infection can be indicative of an elevated risk for HIV exposure (Pathela
et al, CID 2013) . In addition, in 2013, New York City saw a 4.4% HIV
co-infection rate among females of all ages with Ct and only a 1.5% HIV
coinfection rate among women with Neisseria gonorrhea (GC). Recommendation:
In keeping with the goal of maintaining simplicity within the measures, for
example by not stratifying by sex or anatomic site of specimen collection, we
recommend screening all persons with syphilis, gonorrhea or chlamydia for HIV.
2. This measure excludes “patients who have HIV infection” from its
denominator, “patients diagnosed with an acute STD during the one year period
ending 30 days prior to the end of the measurement year. STDs include:
syphilis and gonorrhea.” By excluding all people diagnosed with HIV, this
measure will exclude the very people the measure is meant to detect: people
who are HIV infected and are detected because of testing at or around the time
of STD diagnosis. Recommendation: Please consider revising the exclusions to:
“HIV infection detected more than 30 days before the acute STD diagnosis” to
differentiate individuals with previous positive HIV test results, who are
intended to be excluded from this measure, from those whose HIV is detected by
the testing put forth in this measure. Reference: Pathela P, Braunstein SL,
Blank S, Schillinger JA. HIV incidence among men with and those without
sexually transmitted rectal infections: estimates from matching against an HIV
case registry. CID. 2013. (Submitted by: New York City Department of Health
and Mental Hygiene)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- (Early public comment)We support the inclusion of HIV screening for
patients with STDs in MIPS. In general, CDC recommends HIV testing at each
new visit where a patient either requests STI testing or tests positive for an
STI , among other criteria. There is a distinct need to encourage providers
to test among Medicare beneficiaries, especially those at high risk including
those with STIs. While many older people are sexually active, they are less
likely to be tested for HIV than younger populations, and, if diagnosed, they
are likely to be diagnosed later in the course of the disease. This measure
could encourage an improved response to HIV among both senior citizens and
adults with disabilities enrolled in Medicare. (Submitted by: Trust for
America's Health)
- (Early public comment)While written comments were not provided, the
commenter indicated their support for this measure in this program. (Submitted
by: California Department of Public Health)
- (Early public comment)The American College of Obstetricians and
Gynecologists supports the measure concept for adult women. Adolescent
confidentiality, especially in the realm of reproductive and sexual health
care, is of utmost importance to obstetricians and gynecologists. Measurement
of adolescents when many providers may be referring to Title X clinics or
other providers to maintain confidentiality because of a health insurance
plan's Explanation of Benefits. With the Affordable Care Act, these
workarounds for confidentiality may continue through 26 years of age. We do
not believe health care providers will be measured accurately or fairly in the
adolescent (through 26) population. Please see our Committee Opinion 599 (MAY
2014) for more information.
http://www.acog.org/Resources-And-Publications/Committee-Opinions/Committee-on-Adolescent-Health-Care/Adolescent-Confidentiality-and-Electronic-Health-Records
(Submitted by: American College of Obstetricians and
Gynecologists)
(Program: Hospice
Quality Reporting Program; MUC ID: MUC15-231) |
- CAPC supports the MAP’s recommendation “Encourage Continued Development”
for the inclusion of MUC15-231 in the Hospice Quality Reporting Program
(HQRP). This quality composite measure from the existing Hospice Item Set
(HIS) quality measures is closely aligned with hospice processes directly
impacting quality of care, and the use of this measure could help create
consistent guidelines for hospice and palliative care. In addition to
supporting this measure for inclusion in the HQRP, we encourage CMS and NQF to
consider where this measure could be applied in other settings, as all the
individual measures (with the exception of #1647) have been validated in the
Hospital/Acute Care settings. (Submitted by: Center to Advance Palliative
Care)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- We appreciate MAP’s preliminary recommendation to encourage continued
development of this measure and the recognition that this measure be balanced
with what is relevant to the patient, and not limit to only check box quality
measures. (Submitted by: National Association for Home & Hospice
Care)
- Concerned with the removal of the 7 day exclusion period. Although we
understand the intent and agree that the time should be shortened, we believe
that the period should be shortened to 5 days to coincide with the COPs period
for visit by Chaplains and Social Workers. Would recommend that patients with
LOS < 5 days be excluded from the metric. (Submitted by: Alive
Hospice)
- We believe this measure will add value, but to a limited extent as the
measures are not based in outcomes. The HIS measures ask, did you or did you
not do these things. So, they only guide care, they don't measure quality of
actual care given. The recommendation is that the 7 HIS measures be scored as
a single composite measure. All or none scoring seems inherently unfair - in
some scenarios a "no" value is allowed, i.e, when the patient is unable to
discuss their preferences, and there is no care giver with whom to have the
discussion. How will the threshold be determined given that sometimes there
will be a "no"? Currently it says the numerator is patients who meet ALL of
the criteria. (Submitted by: Delaware Hospice, Inc)
- Hospice Measure MUC15-231 – Composite Process Measure Measure: Hospice
and palliative care composite process measure – Assess percentage of hospice
patients who received care processes consistent with guidelines at admission.
We support the efforts to utilize the Hospice Item Set data in the quality
reporting program as hospices are expending significant resources on capturing
and reporting this data set. The HIS data can give insight into how well the
hospice is able to address a defined set of assessment points during the
initial days of care. But, this is a process measure and consumers are more
interested in outcome measures and that needs to be considered. MAP proposes a
composite measure calculated on the number of patients who meet the numerator
criteria for all of the select measures. We agree that this measure needs
continued development to ensure that it is a valid measure of quality. The
Carolinas Center encourages MAP to consider if a composite score is the most
meaningful way to report the HIS data. Many patients and families would be
more interested in individual scores as this would allow them to drill down to
the areas that are the most important to them. For instance, pain screening
and assessment will be much more important to many than a discussion of values
and beliefs. And for those patients of different cultures, attention to their
beliefs may be the most important. Both individual and composite scores need
to be made available to consumers. It will be important for the scores to be
clearly explained to patients and families. If the score is based on an “all
or none” approach then consumers must understand that a lower score in 1 of
the 7 areas can bring down the composite score, but that is not a reflection
of the overall quality of care. (Submitted by: The Carolinas
Center)
- The seven measures included in this composite are the measures currently
included in the HIS data collection. CMS has not released any results for
hospice performance on these measures (e.g. degree of variability of scores,
ceiling effects, etc.) so it is difficult to know definitively whether a
composite measure comprised of all seven measures is scientifically sound and
usable for quality improvement purposes. However, given that it is likely
that overall hospice performance on these measures is likely to be very high,
creation of a composite measure makes sense. The denominator in the
specifications for 6 of the seven measures (as endorsed by NQF) excludes
patients with a LOS of < 7days. The proposed composite measure only
excludes patient under 18 years of age. Eliminating this exclusion will be
problematic because of the high proportion of hospice patients with a LOS of
less than 7 days. Without this exclusion, hospices will be highly
incentivized to collect data on all of the measures in the composite. But
this data collection may not be appropriate for patients and families in
situations where the patient is in crisis and/or close to death on admission.
Optimum quality care means that the hospice team must focus on identifying and
meeting the needs of the patient and family -- and without the 7 day exclusion
for these measures the danger exists of making data collection the priority
ahead of the needs of the patients and families. (Submitted by: National
Hospice &Palliative Care Organization)
- We appreciate MAP’s preliminary recommendation to encourage continued
development of this measure and the recognition that this measure be balanced
with what is relevant to the patient, and not limit to only check box quality
measures. (Submitted by: The Home Care & Hospice Association of New
Jersey)
- We appreciate MAP’s preliminary recommendation to encourage continued
development of this measure and the recognition that this measure be balanced
with what is relevant to the patient, and not limit to only check box quality
measures. (Submitted by: Ohio Council for Home Care &
Hospice)
- AAHPM supports this quality composite measure from the existing Hospice
Item Set (HIS). It is closely aligned with hospice processes directly
impacting quality of care, and the use of this measure could help create
consistent guidelines for hospice and palliative care. In addition to
supporting this measure for inclusion in the HQRP, we encourage CMS and NQF to
consider where this measure could be applied in other settings, as all the
individual measures (with the exception of #1647) have been validated in the
Hospital/Acute Care setting. (Submitted by: American Academy of Hospice and
Palliative Medicine)
- The measures under the composite metric are individual and unique to a
patient's condition. Lumping these measures into one metric really has no
value in predicting quality of care. For this metric, there would no longer be
an exclusion for patients with LOS < 7 days. This would mean for a patient
with very short LOS, a Chaplain or SW will likely NOT have visited. Although
the COPs state that those disciplines should have an assessment within 5 days,
this composite metric would essentially require that those visits be made much
sooner. I understand that the intent is to include GIP patients that may
currently be excluded, but this metric will not be representative of CMS
guidelines. (Submitted by: Alive Hospice, Inc)
- I am not in agreement with no longer excluding patients with a length of
stay of less than 7 days from the HIS process measure. I understand the
dilemma of excluding approximately one-third of all hospice patients from the
data collection to ascertain hospice quality; however, asking the preference
questions and spiritual/existential concerns regardless of length of stay
deviates from the conditions of participation. Also, it may not always be in
the patient's or family's interest to ask those questions when the patient is
imminent. In 2015, of our patients who died with less than 7 days of care,
9.1% died the same day they were admitted, another 23.4% died the next day,
and another 22.1% died the following day. (Submitted by: Hospice at Home,
Inc.)
- NPHI understands the benefits of a composite measure for hospice quality,
but does not think that this measure includes a sufficient or comprehensive
range of indicators to demonstrate high quality hospice care. NPHI asserts
that additional, more patient-centered and meaningful measures be developed,
tested, and implemented before creating a composite measure. Premature
creation of a composite score from a limited range of process-based quality
measures may stifle additional measurement development. Rather than
consolidating existing measures, measure development should focus on
indicators that more closely and more comprehensively reflect robust,
patient-centered care that matter to patients and families. NPHI does not
support further development of this measure, but rather encourages efforts be
focused towards measure development towards more meaningful measures.
(Submitted by: National Partnership for Hospice Innovation
(NPHI))
- (Early public comment)• MUC15-231: Hospice and Palliative Care
Composite Process Measure- This is a composite measure based on select
measures from 7 NQF endorsed measures: NQF #1641(treatment preferences), NQF
#1647 (beliefs/values addressed), NQF #1634, NQF #1637 (Pain screening), NQF
#1639 (Dyspnea screening), NQF #1638 Dyspnea Treatment), NQF #1617 (Patients
Treated with an Opioid who are Given a Bowel Regiment). All of these
components of this composite measure are already included in the Hospice Item
set. We support this composite process measure. (Submitted by:
LeadingAge)
- (Early public comment)We support the composite quality measure from
the existing HIS quality measures. (Submitted by: Association of Home &
Hospice Care of NC/SC Home Care & Hospice Association)
- (Early public comment)This measure uses existing and readily
available data and is more closely aligned with hospice processes directly
impacting quality of care. (Submitted by: National Association for Home Care
& Hospice (NAHC))
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)This measure uses existing and readily
available data and more closely aligned with hospice processes directly
impacting quality of care. (Submitted by: The Home Care & Hospice
Association of New Jersey)
- (Early public comment)This measure uses existing and readily
available data and more closely aligned with hospice processes directly
impacting quality of care. (Submitted by: Ohio Council for Home Care &
Hospice)
(Program: Home Health Quality Reporting Program; MUC ID: MUC15-234)
|
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- NAHC agrees with the comments presented by the MAP. NAHC strongly urges
that the measure be tested and validated for home health care prior to
implementation. In addition, the measure, as with any readmission measure,
should be risk adjusted for socio- economic status. (Submitted by:
NAHC)
- The Alliance is concerned about the evidence used to support this measure.
The evidence regarding post-acute care potentially preventable readmissions is
limited (see p. 5 of the measure specifications document that CMS shared on
its website). The diagnosis codes identified as potentially preventable in the
measure specifications are based on the ambulatory care sensitive conditions
that the Agency for Healthcare Research and Quality (AHRQ) has developed.
AHRQ’s list identifies conditions for which hospitalizations should be
preventable if such conditions are well managed in ambulatory care settings.
However, the list is not specifically targeted at conditions for which
readmissions should be preventable. In other words, it is not clear whether
after a hospitalization such conditions are ones for which readmissions should
be considered preventable. Hospitalization significantly changes the condition
of a patient and may in itself make the patient more likely to experience
health risks that make the patient more likely to be readmitted. We are
concerned that there is little evidence regarding the ability to prevent a
subsequent post-acute care readmission for the ambulatory care sensitive
conditions that are the basis of the list of diagnosis codes in the measure
specifications. The Alliance recommends close analysis of the evidence base
for this measure, and that modifications be made accordingly. In addition,
patients that have used other post-acute care settings before using home
health care tend to have higher severity and are more likely to be at risk for
readmission. The measure as described in the specifications would not
distinguish among patients that have been to only one post-acute care setting
(home health) or three or more different post-acute care settings. The
Alliance recommends considering this factor in the risk adjustment for the
measure. In addition, the Alliance urges testing of this measure and
reconsideration before it is finalized. Both this measure and the discharge to
community measure are based on risk-adjusted estimates. Testing and validating
this measure will be critical. Testing and validation should be no less than
six months with an opportunity to modify the measure prior to finalizing it. A
similar approach was used for many of the OASIS-based measures that CMS uses
for home health agencies. If finalized, the potentially preventable
readmission measure will be the third measure for home health care that
involves readmissions. There is already a measure for acute care
hospitalization (during the 60-day home health episode), as well as a measure
for readmissions from home health care within 30 days of discharge from the
acute care hospital. There is overlap among these multiple measures that each
capture readmissions. The Alliance recommends that CMS provide context for how
it anticipates using or applying each measure. Increasingly, there are
different applications for measures and it is unclear as yet how CMS plans to
use each one. The Alliance’s full comments on this measure’s specifications
can be found at:
http://ahhqi.org/images/uploads/Alliance_Comments_on_Potentially_Preventable_Readmissions_111615.pdf
(Submitted by: Alliance for Home Health Quality and Innovation)
- This measure includes admissions with a principal diagnosis of one of the
following conditions: dehydration, bacterial pneumonia, or urinary tract
infection. It encourages appropriate care of acute conditions in the
ambulatory setting to avoid hospitalization which is highly desirable for
patients and families. We do not agree with MAP members who suggest that this
measure would discourage facilities from accepting more complex patients. The
requirements under this measure are appropriate for all patients in a home
health setting and should not require unreasonable effort for home health
agencies to meet, even for more complex patients. Moreover, this is the best
measure available at this time to meet IMPACT Act requirements and thus we
support its use. (Submitted by: Medtronic)
- (Early public comment)NAHC is concerned that the measure could
unfairly hold HHAs accountable for readmissions for which they have little or
no control in preventing. Based on the specifications known for this measure
NAHC offers the following recommendations: • Limit the number of PPR
conditions to those conditions where evidence supports that a readmission
could be prevented for 30 days by a home health treatment plan. • Crosswalk
the selected conditions with ICD-10 diagnoses codes and ensure the diagnoses
are tested and validated for inclusion in the measure prior to implementation.
• Ensure the addition of the PPR measure does not conflict with the current
home health re-hospitalization and acute care hospitalization measures.
• Include in the risk adjustment model for home heath prior to implementation:
o Socioeconomic status o Caregiver support o Prior PAC setting stay and
the length of stay (Submitted by: National Association for Home Care &
Hospice (NAHC))
- (Early public comment)APTA supports the goal of improving the
quality of health care. Physical therapists are committed to providing
high-quality, timely care and to the promotion of evidence-based and
patient-centered practice. Furthermore, APTA feels that it is essential that
we move towards a common set of quality measures across the across the
continuum of care. APTA supports the implementation of readmissions measures
across the care settings, as approximately 20% of all Medicare patients are
readmitted within 30 days of an acute care discharge and readmissions account
for an estimated $17 billion in health care spending. APTA is pleased to see
that the draft specifications for these measures align with existing
methodologies of other readmissions measures. We believe that potentially
preventable readmissions measures will focus providers on those patients who
are expected to have successful transitions to the community follow in
discharge from the respective post-acute care settings. However, the APTA
does have some concerns regarding the proposed measure methodology. These
concerns are discussed below. APTA believes that a patient’s level of function
does impact the potential for readmissions. Recent evidence indicates that
patient function is associated with increased risk of 30-day all-cause
hospital readmissions and may be an important factor in preventing
readmissions for Medicare seniors that is not currently accounted for in
measure methodologies1. APTA is pleased to see “activity of daily living”
scores included in the risk adjustment methodology, however, we note that this
is only included for those patients in the home health setting. We would
encourage measure developers to include this as a risk adjustment variable in
all readmissions measures. APTA appreciates that CMS has strict deadlines
for the implementation of measures under the IMPACT act, however, as these
measures will be new to the respective post-acute care settings we encourage
that settings have the ability to review this data as early as possible in
order to understand the data and, more importantly, so that the respective
setting have time to implement strategies to decrease readmissions where
necessary. As many of these settings do not always receive feedback on the
readmissions of their patients post-discharge, this data will be new to many
facilities. Additionally, skilled nursing facilities and inpatient
rehabilitation facilities will be trying to manage two measures, one within
stay, and one post-discharge. APTA recognizes that the overall goal of
IMPACT is for PAC providers (HH, IRF, SNF and LTCH) to collect and report
standardized and interoperable patient assessment data, quality and resource
use measures. We acknowledge that during the initial IMPACT implementation
years that there will be a transition period which will include the addition
of new measures into all of the post-acute care settings. We believe that
achieving a standardized and interoperable patient assessment data set and
stable quality measures as quickly as possible will allow for better
cross-setting comparisons as well as the evolution of better quality measures
with uniform risk standardization, thus achieving the true aim of IMPACT. 1
Greysen SR, Cenzer IS, Auerbach AD, Covinsky KE. Functional Impairment and
Hospital Readmission in Medicare Seniors. JAMA Intern Med.
2015;175(4):559-565. (Submitted by: American Physical Therapy
Association)
- (Early public comment)• MUC15-234: Potentially Preventable 30- Day
Post-Discharge Readmission Measure for Home Health Quality Reporting Program
(Required under the IMPACT Act). There are a couple of concerns with this
measure. First, there is not enough information on what CMS would determine to
be a potentially preventable readmission. MedPAC has estimated that 76 percent
of 30-day readmissions for Medicare beneficiaries overall were due to five
potentially preventable conditions (heart failure, electrolyte imbalance,
respiratory infection, sepsis, and urinary tract infection (MedPAC 2007). In
the exclusions, treatment of cancer and primary psychiatric diseases are
listed. The numerator includes risk adjustment for patient characteristics.
There is not enough information available to assess if the exceptions, the
risk adjustment and the determination of what disease or co-morbidities should
be considered potentially preventable. The uncertainty of defining a
potentially preventable readmission leads us to recommend that this measure
require continued development. (Submitted by: LeadingAge)
- (Early public comment)We would like to note the following concerns
regarding the development of these measures: 1. Measure development for the
IMPACT Act appears to create 4 separate measures that are site specific with
their own set of criteria and risk adjustment factors. The IMPACT Act aims to
create quality measurement within Post-Acute Care (PAC) that is "standardized
and interoperable". By developing measures which differ in their calculation,
such as site-specific inclusion/exclusion criteria or risk-adjustment factors,
PAC sites will be subjected to comparisons of quality that do not differ based
upon the quality of care provided, but rather the differences inherent in the
measure calculations. We strongly recommend that CMS and the measure
developers produce a measure that is calculated in a "standardized and
interoperable" manner with inclusion/exclusion criteria and risk-adjustment
factors the are applied consistently across all PAC sites. 2. The measures
developed for the IMPACT Act hold PAC providers responsible for circumstances
that occur outside of their control. While PAC providers are responsible for
providing care that allows patients safe transitions to their next setting or
home, holding these providers accountable fora time period in which they are
not furnishing care should not differentiate the quality of care they actually
provided. In Appendix A, Table A1 lists various conditions that define
potentially preventable hospital readmission for 30-days post-PAC discharge.
In this list, conditions such as Asthma, Congestive Heart Failure, and
Dehydration are listed as a reason for a potentially preventable readmission.
So if the patient fails to care for themselves post-discharge (against the
advice and discharge instructions provided by a PAC provider) and requires
readmission to Acute Care for one of these conditions, the PAC provider is
penalized even though the patient is no longer being cared for by the PAC
provider. We strongly recommend that CMS and the measure developers produce a
measure that represents the quality of care provided by PAC providers while
the patient is in their care. (Submitted by: UDSMR)
- (Early public comment)This measure will encourage post-acute care
providers to optimize care for patients before discharge. (Submitted by:
Smith & Nephew )
- (Early public comment)The Alliance is concerned about the evidence
used to support this measure. The evidence regarding post-acute care
potentially preventable readmissions is limited (see p. 5 of the measure
specifications document that CMS shared on its website). The diagnosis codes
identified as potentially preventable in the measure specifications are based
on the ambulatory care sensitive conditions that the Agency for Healthcare
Research and Quality (AHRQ) has developed. AHRQ’s list identifies conditions
for which hospitalizations should be preventable if such conditions are well
managed in ambulatory care settings. However, the list is not specifically
targeted at conditions for which readmissions should be preventable. In other
words, it is not clear whether after a hospitalization such conditions are
ones for which readmissions should be considered preventable. Hospitalization
significantly changes the condition of a patient and may in itself make the
patient more likely to experience health risks that make the patient more
likely to be readmitted. We are concerned that there is little evidence
regarding the ability to prevent a subsequent post-acute care readmission for
the ambulatory care sensitive conditions that are the basis of the list of
diagnosis codes in the measure specifications. The Alliance recommends close
analysis of the evidence base for this measure, and that modifications be made
accordingly. In addition, patients that have used other post-acute care
settings before using home health care tend to have higher severity and are
more likely to be at risk for readmission. The measure as described in the
specifications would not distinguish among patients that have been to only one
post-acute care setting (home health) or three or more different post-acute
care settings. The Alliance recommends considering this factor in the risk
adjustment for the measure. In addition, the Alliance urges testing of this
measure and reconsideration before it is finalized. Both this measure and the
discharge to community measure are based on risk-adjusted estimates. Testing
and validating this measure will be critical. Testing and validation should be
no less than six months with an opportunity to modify the measure prior to
finalizing it. A similar approach was used for many of the OASIS-based
measures that CMS uses for home health agencies. If finalized, the
potentially preventable readmission measure will be the third measure for home
health care that involves readmissions. There is already a measure for acute
care hospitalization (during the 60-day home health episode), as well as a
measure for readmissions from home health care within 30 days of discharge
from the acute care hospital. There is overlap among these multiple measures
that each capture readmissions. The Alliance recommends that CMS provide
context for how it anticipates using or applying each measure. Increasingly,
there are different applications for measures and it is unclear as yet how CMS
plans to use each one. The Alliance’s full comments on this measure’s
specifications can be found at:
http://ahhqi.org/images/uploads/Alliance_Comments_on_Potentially_Preventable_Readmissions_111615.pdf
(Submitted by: Alliance for Home Health Quality and Innovation)
- (Early public comment)Our home health agencies have long strived to
keep patients independent at home and prevent costly, unnecessary
hospitalizations. We support the goal of the IMPACT act to align quality
measures across post-acute providers and to promote patient-centeredness in
quality efforts. We support the designation of a single hospital
admission/readmission measure as the target for home health agencies that
would be available on their CASPER reports, publically reported on Home Health
Compare, and considered for Medicare value-based purchasing initiatives. The
availability of multiple quality measures derived from OASIS and Medicare
claims is confusing for agencies as the calculations of these measures are
complex and it is time consuming for agencies to understand and to be able to
educate their staff and referral sources on them. For the draft measure
developed by RTI we support appropriate risk-adjustment of this quality
measure to take into account the unique characteristics of the agency’s
patient population. We support the inclusion prior emergency department use in
the calculation specifically for home health agencies as we believe that it is
an appropriate indication of patient stability. We support the further study
of risk adjusters specifically dual eligibility as we believe that it is a
good proxy for other social demographic determinants. We support the
inclusion of this measure in the CASPER reports to provide agencies with data
on their performance. (Submitted by: Association of Home & Hospice Care
of NC/SC Home Care & Hospice Association)
- (Early public comment)We recommend that CMS ensure the data
collection time frame is the same for all PAC settings. Currently, the time
frame for the initial data collection for the project varies from one year
(SNFs), two years (IRFs and LTCHs), and three years (HHAs), we urge the Agency
to implement one standard reporting time frame across PAC providers. While
reporting may be based on either one year of data, two years of data, etc., we
strongly recommend CMS and its subcontractors address the inconsistent
reporting periods. (Submitted by: Association of Rehabilitation
Nurses)
- (Early public comment)This set of potentially preventable
readmission (PPR) measures for post-acute care (PAC) estimates the
risk-standardized rate of unplanned, potentially preventable readmissions for
patients (Medicare fee-for-service [FFS] beneficiaries) who receive services
in one of the following post-acute care provider types: skilled nursing
facilities (SNFs), inpatient rehabilitation facilities (IRFs), long-term care
hospitals (LTCH), and home health agencies (HHA). These outcome measures
reflect readmission rates for patients who are readmitted to a short-stay
acute-care hospital or an LTCH with a principal diagnosis considered to be
unplanned and potentially preventable. Six PPR PAC measures are being
developed: • Four of these measures assess PPR within a 30-day window
following discharge from PAC—one measure for each PAC setting (i.e., SNF,
IRF, LTCH, and HH)—and are being developed to meet the requirements of the
IMPACT Act. • An additional SNF measure (SNF PPR), which is being developed
to meet the PAMA requirements, assesses PPR during the 30-day period following
a hospital discharge to a SNF setting. • An additional IRF measure assesses
PPR during the IRF stay (referred to as the within-stay window) which is being
developed for use in the IRF Quality Reporting Program. Of note with respect
to potentially preventable readmissions and a patient’s occupational therapy
needs, several recent studies consider whether returning to the community from
a recent hospitalization with unmet activities of daily living (ADL) need was
associated with probability of readmission. The findings from these studies
indicate that this indeed may be a considerable risk factor. The studies
reveal that any older patients are discharged from the hospital with ADL
disability. Those who report unmet need for new ADL disabilities after they
return home from the hospital are particularly vulnerable to readmission. This
area is not typically addressed in a thorough manner through current discharge
practices. This needs to change. Patients' functional needs after discharge
should be carefully evaluated and addressed. Factors such as enabling
self-management and ensuring appropriate medication management and ADLs, such
as cooking and eating are addressed, can have a direct effect on readmissions
The profession of occupational therapy is built on delivering
patient-centered care, seeking to keep the patient at the highest functional
level in the least restrictive setting and to reduce caregiver burden and
health care system resource utilization. Occupational therapy directly
addresses the enablement of successful performance of ADLs. This focus,
experience and research base in occupational therapy must be fully tapped to
address this component of readmission prevention. A further issue is that
Self-management is a key element in successful care, and occupational
therapists are experts in motivation, task analysis, and psychosocial
contexts, which all contribute to enabling positive outcomes. In order to
successfully re-establish or establish new routines and habits to meet health
care needs, such as medication management, proper sleep hygiene, and following
other medical directives, is within the scope and proven effectiveness of
occupational therapy. AOTA would encourage CMS to examine more fully,
perhaps through pilot testing, the value of occupational therapy evaluation
and intervention participation as part of discharge planning. This could
identify more clearly specific ADL limitations prior to and after discharge
and assure proper interventions are provided that address fully and completely
the range of ADL and other activity restrictions and capacities to enable
optimum recovery from the condition as well as optimum participation of the
client in their own care. AOTA has reviewed the readmissions measures
released for comment and makes the following general comments: • The PPR
measures Numerator and Denominator definition language are consistent from
previous materials. • The Readmissions Measures are based on two years of
claims data. Use of multiple years is acceptable in the measure review
process. • The exclusion criteria for the various measures are associated
with the Yale/New Haven readmission measures. Co-developed by the Centers for
Medicare & Medicaid Services (CMS) and researchers at Yale University,
estimates the risk-standardized rate of unplanned, all-cause readmissions to a
hospital for any eligible condition within 30 days of hospital discharge for
patients aged 18 and older. The CMS/Yale measure is specified for evaluating
hospital performance. AOTA would prefer for the exclusion criteria to be
specified for evaluating performance in post-acute care settings. (Submitted
by: American Occupational Therapy Association)
- (Early public comment)At least one NRHI member has expressed
concerns regarding this measure. Specifically, clinical staff at
HealthInsight have concerns with inclusion of this measure due to the validity
of and complicated methodologies used for "risk adjustment for patient
characteristics and a statistical estimate of the facility effect beyond
patient mix." This methodology is frequently cited as the basis for
determining potentially avoidable hospital facility admissions. This
methodology is not well-established. (Submitted by: Network for Regional
Healthcare Improvement)
- (Early public comment)At least one NRHI member has expressed
concerns regarding this measure. Specifically, clinical staff at
HealthInsight have concerns with inclusion of this measure due to the validity
of and complicated methodologies used for "risk adjustment for patient
characteristics and a statistical estimate of the facility effect beyond
patient mix." This methodology is frequently cited as the basis for
determining potentially avoidable hospital facility admissions. This
methodology is not well-established. (Submitted by: Network for Regional
Healthcare Improvement)
(Program: Home
Health Quality Reporting Program; MUC ID: MUC15-235) |
- CAPC supports the MAP’s recommendation “Do Not Encourage Continued
Development” for the inclusion of MUC15-235 in the Home Health Quality
Reporting Program (HH QRP). For patients receiving palliative care, many of
whom are receiving care in the home, we have found that it is not fair to hold
clinicians to the standard of eliminating symptoms such as shortness of
breath. All drugs have side effects, and patients may decide that the
tradeoffs for relieving symptoms are intolerable (e.g., a patient would rather
have difficulty breathing if it means staying conscious). Rather than
measuring a reduction in symptoms, we encourage CMS and NQF to consider
dyspnea screening, assessment, and plan of care measures (with dyspnea as the
primary diagnosis) for inclusion in this program as well as hospice, long term
care and hospital reporting programs. (Submitted by: Center to Advance
Palliative Care)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- The Alliance is supportive of this measure, but is concerned about overlap
with existing measures and the absence of measures involving stabilization of
function. At present, there is a home health compare measure for improvement
in dyspnea for all home health patients. This will provide more specific
measurement for CHF, asthma and COPD patients. This measure will capture a
subset of the patients included in the existing improvement in dyspnea
measure. The Alliance is concerned about the overlap in the measures and these
measures raise the issue of whether some measures will be retired where new
measures are becoming more focused on subsets of patients. The growing number
of overlapping measures has the potential to be confusing for the general
public and even those who are using the measures as payers and policy-makers.
The ideal is a streamlined, meaningful measure set and the Alliance encourages
CMS to make this a goal. In addition, the Alliance continues to be concerned
about the exclusive focus of measurement on improvement, to the exclusion of
measurement of stabilization. Many home health patients have multiple chronic
conditions and two or more ADL limitations. For some, stabilization of
function is a legitimate goal of treatment. The Alliance believes this is an
important measure gap that must be addressed in the future. Finally, the
Alliance urges testing of this measure and reconsideration before it is
finalized. Testing and validation should be no less than six months with an
opportunity to modify the measure prior to finalizing it. A similar approach
was used for many of the OASIS-based measures that CMS uses for home health
agencies. (Submitted by: Alliance for Home Health Quality and
Innovation)
- It is not clear how "shortness of breath" is measured? There are varied
tiers of "shortness of breath" and perhaps some level of pulmonary function
test scores should be introduced for both baselines and
improvement/deterioration. While dyspnea may be a finding across "...a
broader population approach,.." for patients with severe CHF, COPD, acute
Asthma - breathing adequately is a priority and fondest wish in daily
functions! Suggest CONTINUED DEVELOPMENT. Thank you. (Submitted by: American
Medical Group Association - KF)
- This measure has some merit and we instead encourage that MAP recommend
“continued development” with some recommended changes. We agree with the MAP
that this measure should not be limited to specific diagnoses. We also
recommend assessing for dyspnea during a specific unit of exertion, or
exertion tolerance instead, because if patients are feeling more dyspneic, but
this is because they are able to do much more rather than remain confined to
bed/chair, this is clearly a success. (Submitted by: American Academy of
Hospice and Palliative Medicine)
- (Early public comment)NAHC supports the measure for improvement in
dyspnea targeted for patients with a primary diagnosis of CHF, COPD and/or
Asthma. (Submitted by: National Association for Home Care & Hospice
(NAHC))
- (Early public comment)• MUC15-235: Improvement in Dyspnea in
Patients with a Primary Diagnosis of Congestive Heart Failure, Chronic
Obstructive Pulmonary Disease and/or Asthma – In the 2015 National Impact
Assessment of the Centers for Medicare & Medicaid Services (CMS) Quality
Measures Report, it is noted that Improvement in Dyspnea rates decreased, so
there is room for improvement in this area. We believe that there needs to be
more detailed assessment of why there is less of an improvement in dyspnea.
The exclusions for this measure and the specifications in the numerator and
denominator do not address co-morbidities and if the patient smokes. The
omission of key factors that would impact dyspnea leads us to recommend that
this measure require continued development. (Submitted by:
LeadingAge)
- (Early public comment)The Alliance is supportive of this measure,
but is concerned about overlap with existing measures and the absence of
measures involving stabilization of function. At present, there is a home
health compare measure for improvement in dyspnea for all home health
patients. This will provide more specific measurement for CHF, asthma and COPD
patients. This measure will capture a subset of the patients included in the
existing improvement in dyspnea measure. The Alliance is concerned about the
overlap in the measures and these measures raise the issue of whether some
measures will be retired where new measures are becoming more focused on
subsets of patients. The growing number of overlapping measures has the
potential to be confusing for the general public and even those who are using
the measures as payers and policy-makers. The ideal is a streamlined,
meaningful measure set and the Alliance encourages CMS to make this a goal. In
addition, the Alliance continues to be concerned about the exclusive focus of
measurement on improvement, to the exclusion of measurement of stabilization.
Many home health patients have multiple chronic conditions and two or more ADL
limitations. For some, stabilization of function is a legitimate goal of
treatment. The Alliance believes this is an important measure gap that must be
addressed in the future. Finally, the Alliance urges testing of this measure
and reconsideration before it is finalized. Testing and validation should be
no less than six months with an opportunity to modify the measure prior to
finalizing it. A similar approach was used for many of the OASIS-based
measures that CMS uses for home health agencies. (Submitted by: Alliance for
Home Health Quality and Innovation)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)We support the inclusion of a quality measure
that specifically addresses dyspnea for these diagnoses. We believe that a
stabilization measure is a more appropriate target for the quality reporting
program. Not all patients have the ability to improve. We believe that
stabilization is in line with the goal of home health to maintain or improve a
patient's ability. (Submitted by: Association of Home & Hospice Care of
NC/SC Home Care & Hospice Association)
(Program: Skilled Nursing
Facility Quality Reporting System; MUC ID: MUC15-236) |
- Clarification needed as to when and how the 'self-case score' is collected
AND whether or not there is better measure of self-care that the IRF can track
over time. (Submitted by: American Medical Group Association -
EB)
- FAH supports the workgroup's recommendation and rationale. In addition,
we strongly encourage CMS to conduct robust widespread testing of the measure
before further consideration of its inclusion in payment programs. (Submitted
by: Federation of American Hospitals)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. AHCA is pleased to have the opportunity to comment on the MAP
Preliminary Decisions and MAP Draft Report ”. Thank you again for the
opportunity to provide these comments. Please contact me at DGifford@ahca.org
with any questions or for additional information. We support the MAP’s
preliminary decision to “encourage continued development” of this measure.
However, in the draft report, the MAP must clearly state that encouraging
continued development of this measures should not be taken as support of
inclusion of this measure in the SNF QRP. We also think the report needs to
include the comments and recommendations made by the MAP workgroup on each
measure since that is the primary role of the MAP to provide DHHS with
feedback on the MUC list and DHHS needs to respond to those comments in any
proposed rule. Without inclusion of these comments, if DHHS decided to
implement this measure for rule making via the Federal Register process, CMS
does not need to provide a rationale for their decision. In the draft report,
the MAP should also include a statement that before a measure from one setting
is implemented into another setting, it must be tested in the new setting.
Additionally, for the sake of transparency and enhanced stakeholder feedback
the draft report should include the specific public comments submitted. Our
specific comments on this measure are as follows. 1. While this measure has
been endorsed by NQF, it was developed, tested and validated in the IRF
setting for IRF patients. It was not developed for SNF setting. We do not
think it is appropriate to take a measure from one setting and assume it is
reliable and valid in another setting. If this logic is to be followed
through, there are several other NQF endorsed functional measure that rely on
the CARE tool item set, which is what is used for this measure. We believe,
the MAP process must review and consider all NQF endorsed measures that are
similar, in particular NQF measure 2613 and 2286. 2. In addition, the
proposed measure relies on CARE tool items that were not added to section GG
in the IRF, SNF or LTCH setting. As such, the specifications of this measure
do not match the available data in the PAC assessment tools for SNF, IRF, and
LTCH setting. 3. AHCA recommends that, before a measure developed in one
setting is applied to another, that cross-setting measure testing be
performed. Such testing is critically important because of the clinical
sorting that goes on between the settings, with benefit rules, Medicare
enrollment requirements, and the general suitability of the settings resulting
in certain kinds of patients tending to go to SNFs, and other patients tending
to go to IRFs. For example, the IRF benefit rule that patients can receive
three or more hours of therapy each day means that certain groups of patients
who would have difficulty walking will tend to sort into the SNF setting
rather than the IRF setting. This phenomena will also occur on self-care
domains. For example, differences in the proportion and types of stroke
patients between SNF and IRF make application of an IRF measure inaccurate in
the SNF setting. Because CMS has not tested whether the distribution of risk
adjusted measure scores in the SNF setting are the same or widely different
from those in the IRF setting, we are left with a serious concern that the
measure’s distribution will be shifted up in the IRF setting and down in the
SNF setting, without anything to do with the quality of care being provided in
each setting. Last, we recognize that it is entirely possible that the
measures perform adequately after cross-setting measure testing; however, if
this testing is not performed before the measures are rolled out into live
public use, CMS risks promoting a risk adjustment model that does not work as
well for the SNFs compared to the IRF Quality Reporting Programs. 4. The
specifications are based on ICD-9 but all providers as of October 2015 are
required to use ICD-10 and no cross walk with ICD-10 is provided, yet the
measure will be used during time periods when only ICD-10 data is available.
(Submitted by: American Health Care Association )
- ARN is supportive of the IRF functional measures; however, there are
several key differences between the existing and new proposed function items
that may result in variation in the resident assessment results including: (1)
data collection and associated data collection instructions; (2) rating scales
used to score a resident’s level of independence; and (3) item definitions.
Utilizing multiple data collection systems and instruments as well as a
different rating scale and item definitions is both cumbersome and burdensome.
Additionally, functional measures are not a “one size fits all,” and measures
should account for the benefits of the quality of life domain for patients
with these extreme conditions. ARN encourages the Agency to revise the
measures to reflect the following attributes: a low collection burden for
providers and beneficiaries; comprehensibility for beneficiaries; a high level
of significance to patients and providers; and data that is routinely
captured. While we are supportive of functional outcome measures, we are
concerned with that several of these quality indicators are nearly identical
that were submitted and approved by NQF for use by different vendors.
(Submitted by: Association of Rehabilitation Nurses)
- AAPM&R commends NQF for evolving its work to understand how measures
are being developed and implemented across settings and how they impact
payment reform. This is a huge endeavor that AAPM&R stands behind in
concept. However, AAPM&R cautions NQF to ensure their processes and
review of measures are adequately reported back to CMS and other rule-making
entities to ensure the NQF’s measurement expertise is realized in rule making.
AAPM&R believes that the exclusions listed are too broad to make this a
meaningful form of measurement (Submitted by: American Academy of Physical
Medicine and Rehabilitation )
- AAHPM worries that this measure is too complicated to be useful in
clinical practice. However, it this measure is eventually adopted, it should
maintain the hospice exclusion. (Submitted by: American Academy of Hospice
and Palliative Medicine)
- (Early public comment)This measure is currently in early
development and measure specifications are in preliminary stages of
clarification. The proposed application could definitely create inaccuracy in
measurement of patient condition when used in other PAC settings. Terms have
not been defined within the exclusions (i.e. "incomplete stays"). No testing
of the measure in non-IRF settings has been done. These could create
inaccurate data capture throughout PAC venues. The Technical Expert Panel
indicated that this measure needs extensive work to assure accuracy and to
meet the purpose for which it was intended. Because there is potential for
accuracy this measure should continue to be developed. (Submitted by: Geneis
Health Care)
- (Early public comment)AHCA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. Thank you again for the opportunity to provide these comments. Please
contact me at DGifford@ahca.org with any questions or for additional
information. 1. While this measure has been endorsed by NQF, it was
developed, tested and validated in the IRF setting for IRF patients. It was
not developed for SNF setting. We do not think it is appropriate to take a
measure from one setting and assume it is reliable and valid in another
setting. If this logic is to be followed through, there are several other NQF
endorsed functional measure that rely on the CARE tool item set, which is what
is used for this measure. We believe, the MAP process must review and consider
all NQF endorsed measures that are similar. In particular, NQF measure 2613
and 2286 which rely on the CARE tool items. 2. In addition, the proposed
measure relies on CARE tool items that were not added to section GG in the
IRF, SNF or LTCH setting. As such, the specifications of this measure do not
match the available data in the PAC assessment tools for SNF, IRF, and LTCH
setting. 3. AHCA recommends that, before a measure developed in one setting
is applied to another, that cross-setting measure testing be performed. Such
testing is critically important because of the clinical sorting that goes on
between the settings, with benefit rules, Medicare enrollment requirements,
and the general suitability of the settings resulting in certain kinds of
patients tending to go to SNFs, and other patients tending to go to IRFs. For
example, the IRF benefit rule that patients can receive three or more hours of
therapy each day means that certain groups of patients who would have
difficulty walking will tend to sort into the SNF setting rather than the IRF
setting. This phenomena will also occur on self-care domains. For example,
differences in the proportion and types of stroke patients between SNF and IRF
make application of an IRF measure inaccurate in the SNF setting. Because CMS
has not tested whether the distribution of risk adjusted measure scores in the
SNF setting are the same or widely different from those in the IRF setting, we
are left with a serious concern that the measure’s distribution will be
shifted up in the IRF setting and down in the SNF setting, without anything to
do with the quality of care being provided in each setting. Last, we recognize
that it is entirely possible that the measures perform adequately after
cross-setting measure testing; however, if this testing is not performed
before the measures are rolled out into live public use, CMS risks promoting
a risk adjustment model that does not work as well for the SNFs compared to
the IRF Quality Reporting Programs. 4. The specifications are based on ICD-9
but all providers as of October 2015 are required to use ICD-10 and no cross
walk with ICD-10 is provided, yet the measure will be used during time periods
when only ICD-10 data is available. Therefore, for these reasons, we believe
this measure does not meet NQF MAP criteria for endorsement but rather should
receive a vote of “encourage continued development” only after NQF MAP process
has reviewed the other NQF endorsed functional measures to determine which the
best to be recommended. (Submitted by: American Health Care Association
)
- (Early public comment)This measure was validated and tested for an
in-patient rehab population. it cannot be assumed that these populations are
alike, or that this is a valid measure for SNF settings. Goal setting, that is
driven by patient-centered goals, is likely very different in the SNF from an
IRF. This would also need to be risk adjusted for co-morbidities and
pre-morbid function (Submitted by: leadingage)
- (Early public comment)First, the IRF endorsement of this measure
was conditional, requiring updates when data is available (after October 2016)
to display the reliability and validity of the measure, among other things.
We strongly urge the MAP PAC/LTC committee to consider whether or not to
approve and/or implement a measure that has not been shown to meet NQF
requirements for reliability and validity. Second, this measure should be
identified as a competing measure with NQF #2613 - CARE: Improvement in Self
Care, developed by AHCA and endorsed earlier this year by NQF. These measures
are similar in that they utilize functional items creates as part of the CARE
tool development project or PAC-PRD, but have differences in the functional
items included, inclusion/exclusion criteria, and risk-adjustment
methodologies. Third, a "best-in-class" determination related to the
functional improvement or change in self-care is required and necessary. This
measure has already been found to compete with a UDSMR developed measure (NQF
#2286), and NQF staff chose not to make a "best-in-class" decision until such
a time as additional measure testing was available. With the additional
consideration for the AHCA measure that is already NQF endorsed noted
previously, there exist 3 different ways for measuring the same functional
construct. The IMPACT Act requirements indicate that measures for PAC
settings should be "standardized and interoperable", yet implementation of the
IMPACT Act is burdening PAC providers with the data collection of functional
items for payment and similar but different functional items for quality. PAC
providers should not bear the burden of data collection for measures that may
not be identified as "best-in-class". (Submitted by: UDSMR)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)This measure was developed for the IRF and as
such may not be usable in the SNF without further development and testing.
The admission criteria for a patient entering an IRF is different than a SNF,
therefore IRF patients may be different than SNF patients. Therefore,
measuring self-care could use different items for a SNF patient than measuring
self-care for an IRF patient. This measure requires testing and validation
before it could be used for SNF patients. (Submitted by: National
Association for the Support of Long Term Care)
- (Early public comment)ARN is supportive of the IRF functional
measures; however, there are several key differences between the existing and
new proposed function items that may result in variation in the resident
assessment results including: (1) data collection and associated data
collection instructions; (2) rating scales used to score a resident’s level of
independence; and (3) item definitions. Utilizing multiple data collection
systems and instruments as well as a different rating scale and item
definitions is both cumbersome and burdensome. Additionally, functional
measures are not a “one size fits all,” and measures should account for the
benefits of the quality of life domain for patients with these extreme
conditions. ARN encourages the Agency to revise the measures to reflect the
following attributes: a low collection burden for providers and beneficiaries;
comprehensibility for beneficiaries; a high level of significance to patients
and providers; and data that is routinely captured. (Submitted by: Association
of Rehabilitation Nurses)
- (Early public comment)AMDA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
AMDA - The Society for Post-Acute and Long-Term Care Medicine (AMDA)
represents over 5,500 physician medical directors, attending physicians, and
other practitioners who work in post-acute and long-term care settings.
Thank you again for the opportunity to provide these comments. Please contact
me at abardakh@amda.com with any questions or for additional information.
1. While this measure has been endorsed by NQF, it was developed, tested and
validated in the IRF setting for IRF patients. It was not developed for SNF
setting. We do not think it is appropriate to take a measure from one setting
and assume it is reliable and valid in another setting. If this logic is to be
followed through, there are several other NQF endorsed functional measure that
rely on the CARE tool item set, which is what is used for this measure. We
believe, the MAP process must review and consider all NQF endorsed measures
that are similar. In particular, NQF measure 2613 and 2686 which rely on the
CARE tool items. 2. In addition, the proposed measure relies on CARE tool
items that were not added to section GG in the IRF, SNF or LTCH setting. As
such, the specifications of this measure does not match the available data in
the PAC assessment tools for SNF, IRF, and LTCH setting. 3. AMDA recommends
that, before a measure developed in one setting is applied to another, that
cross-setting measure testing be performed. Such testing is critically
important because of the clinical sorting that goes on between the settings,
with benefit rules, Medicare enrollment requirements, and the general
suitability of the settings resulting in certain kinds of patients tending to
go to SNFs, and other patients tending to go to IRFs. For example, the IRF
benefit rule that patients can receive three or more hours of therapy each day
means that certain groups of patients who would have difficulty walking,
and/or significant deconditioning, functional quadriplegia, dysphagia, or
gastrostomy, will tend to sort into the SNF setting rather than the IRF
setting. This phenomena will also occur on self-care domains. For example,
differences in the proportion and types of stroke patients between SNF and IRF
make application of an IRF measure inaccurate in the SNF setting. Because CMS
has not tested whether the distribution of risk adjusted measure scores in the
SNF setting are the same or widely different from those in the IRF setting, we
are left with a serious concern that the measure’s distribution will be
shifted up in the IRF setting and down in the SNF setting, without anything to
do with the quality of care being provided in each setting. Last, we recognize
that it is entirely possible that the measures perform adequately after
cross-setting measure testing; however, if this testing is not performed
before the measures are rolled out into live public use, CMS risks promoting
a risk adjustment model that does not work as well for the SNFs compared to
the IRF Quality Reporting Programs. 4. The specifications are based on ICD-9
but all providers as of October 2015 are required to use ICD-10 and no cross
walk with ICD-10 is provided, yet the measure will be used during time periods
when only ICD-10 data is available. Therefore, for these reasons, we believe
this measure does not meet NQF MAP criteria for endorsement but rather should
receive a vote of “encourage continued development” only after NQF MAP process
has reviewed the other NQF endorsed functional measure to determine which the
best to be recommended is. (Submitted by: AMDA-The Society for Post-Acute and
Long-Term Care Medicine)
- (Early public comment)the measure does not appear to consider
functional outcomes to include the performance skills and cognitive
capacities of self-care such as sequencing, problem-solving, temporal
appropriateness (e.g., whether to dress for day or bed), memory, and activity
planning. Nor does the measure consider performance of activities of daily
living, including the broader instrumental activities of daily living (IADLs),
which significantly impact a patient’s ability to function and live
independently in the community. (Submitted by: American Occupational Therapy
Association)
- (Early public comment)At least one NRHI member has expressed
concerns regarding this measure. Specifically, clinical staff at
HealthInsight have concerns with designation of functional status scores such
as "self-care score" and "mobility score" that will rate the performance of
facilities. (Submitted by: Network for Regional Healthcare
Improvement)
(Program: Merit-Based
Incentive Payment System (MIPS); MUC ID: MUC15-251) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Children's
Hospital Association)
- Seems this MUC is calling for a documented baseline screening endoscopy,
both to verify presence or absence and to verify size of varices. Progression
or regression of the patients health status is measured from a baseline and
timeline - no matter if the patient symptomatically improves and never has
ensuring endoscopies. (Submitted by: American Medical Group Association -
KF)
- (Early public comment)While AGA agrees that the intent of this
measure has some merit, AGA does not at this time support inclusion of this
measure on the list of measures to be finalized for PQRS implementation
(Submitted by: American Gastroenterological Association)
- (Early public comment)ASGE does not support advancement of this
measure as specified. This measure would not deter overutilization of
colonoscopy. Most guidelines suggest screening every 3 years in cirrhotics and
within a year if they are decompensated. (Submitted by: American Society for
Gastrointestinal Endoscopy)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)This is a question regarding portal
hypertension. I am not sure of the value of endoscopy surveys of all patients
with cirrhosis so I have no comments on the value of this measure. (Submitted
by: Society of Interventional Radiology)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-275)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- We are resubmitting our preliminary comments as we believe they are still
relevant to the discussion. We are in agreement that this measure needs to be
reviewed by NQF within the context of the current PQRS/NQF composite measure.
We cannot support this measure as it has been revised to only require
prescription of a statin to address risk due to hyperlipidemia as a change
from the original version in which cholesterol risk was addressed by the
criteria of ‘LDL less than 100’ as part of the numerator. The rationale for
the removal of the LDL level was provided in the NQF May 2014 update of the
measure: the removal was based on the 2013 AHA/ACC guidelines and the MN
Community indicated that it intended to revise the measure in 2016 to be more
consistent with the 2013 guidelines. This measure had been introduced by the
Wisconsin Collaborative for Healthcare Quality (WCHQ) with the addition of
‘statin use” as the 4th criteria. We have two objections. A. We believe the
retirement of the LDL-C criteria was based upon a misunderstanding of the
ACC/AHA Guidelines and is not supported by recent evidence or recommendations
from other medical societies. B. The requirement for use of a statin without
regard for the matching the patient’s level of risk with the dosing is not
consistent with national guidelines and will not achieve optimal desired
reduction in ASCVD events. A: LDL-C Criteria is an appropriate intermediate
outcome measurement First, Dr. Knowles and Dr. Stone’s paper, “Familial
Hypercholesterolemia and the 2013 American College of Cardiology/ American
Heart Association Guidelines: Myths, Oversimplification and Misinterpretation
versus Facts” American Journal of Cardiology, Aug. 1, 2015 Vol. 116, Issue 3,
pgs 481-484 (http://www.ajconline.org/article/S0002-9149(15)01260-6/abstract)
established the import of LDLs in the management of ASCVD risk in all
patients, highlighting the recommendation in the guidelines and the need for
periodic monitoring of the LDL-C level to determine adequacy of response to
therapy and adherence and the need to adjust the treatment regimen. It also
pointed out that statins alone do not provide the outcomes needed to protect
FH and high risk patients. This is further supported by the recommendations
and guidelines published by NLA, AACE and other societies. LDL levels are
critical to achieving intermediate and long term outcomes and the totality of
evidence does not support the omission of the LDL-C as a threshold or target.
Second, although specific LDL-C treatment goals are not recommended in the
guideline, the statin intensity recommendations are benchmarked against
expected LDL-C reductions in those initially being started on statins (i.e.
>50% high; 30% to <50% moderate) and includes guidance for LDL-C levels
for all patients. Considering heterogenic response in the natural setting
with statin tolerability, adherence, etc., measuring LDL-C (either directly or
calculated) is necessary to confirm patients are achieving treatment goals. To
this end, the guideline recommends monitoring response with lipid panels every
3 to 12 months (IA recommendation) and appropriate treatment adjustment).
2013 ACC/AHA Guideline on the Treatment of Blood Cholesterol to Reduce
Atherosclerotic Cardiovascular Risk in Adults: A Report of the American
College of Cardiology/American Heart Association Task Force on Practice
Guidelines, available at:
http://circ.ahajournals.org/content/early/2013/11/11/01.cir.0000437738.63853.7a.citation.
Third, we do not believe the focus on choice of therapy to the exclusion of
LDL levels is consistent with the guidelines and their intent. The charge of
CMS is to address treatment of blood cholesterol levels to reduce ASCVD risk.
They have provided an ASCVD risk calculator to determine a patient’s initial
risk and reduction in risk based on improved parameters. The parameters used
in calculating a person’s risk do not include use of statins or any other
reference to treatment methods. The parameters are clinical: they include
the patient’s LDL and HDL level. We cannot avoid measuring and considering the
absolute LDL if the intent is to reduce risk and ASCVD outcomes. In
addition, ACC/AHA has recognized that there has been some confusion arising
from the language used in the 2013 Guidelines and they have established
committees to address, refine or modify their recommendations to provide
additional clarity. We believe that the issue of LDL-C thresholds may be part
of this conversation and that any proposed changes to measures should be
delayed until the ACC/AHA have clarified their position. Fourth, we believe
it is not warranted to change LDL-C quality measures based on a single
guideline; and a guideline that is not endorsed by other key expert groups and
societies dedicated to diseases of metabolism, including the National Lipid
Association (NLA), American Academy of Clinical Endocrinologists (AACE), and
American Diabetes Association (ADA). AACE and ADA have separate cholesterol
guidelines that currently recommend LDL-C <100 mg/dL in high risk patients
including those with diabetes and those with prior ischemic events. Fifth, the
measure as written is contrary to CMS objectives to measure outcomes. New
legislation directed CMS to develop a strategic plan to integrate quality of
care into Pay for Performance. CMS recently published the PQRS Strategic
Vision, which presents a long-term vision to optimize quality measurements and
align physicians, professionals, and public reporting programs to support
better decision-making across the healthcare system. "CMS will continue to
move beyond 'check box' process measures. PQRS will be dominated by
patient-centered outcome and longitudinal measures that reflect change to
health status over time." The use of this measure would misdirect the VISION
objective to measure outcomes, impinge on dealing with socio-demographic
factors and women’s cardiovascular disease, and hamper CDC data needs for
achieving Million Hearts. In summary, we do not support the use of this
measure with the change to this measure as the new referenced guideline is
controversial and not endorsed by all relevant specialty medicine professions,
including the American Association of Clinical Endocrinologists. Removal of
the LDL screening and control components of the measure without adding any
means of evaluating hyperlipidemia treatment seems counterproductive and
harmful to patients. While the ACC/ AHA guidelines do not identify a target
LDL goal, they do state that once statin therapy is initiated, monitoring
should occur using LDL levels to ensure optimal treatment selection and
appropriate decrease in LDL levels. We think it is important to maintain a
measure component to evaluate lipid treatment and monitoring in this patient
population. B. Why ‘statin use’ alone is not sufficient to achieve optimal
results. Matching the appropriate dose of the statin (and achieving the
desired therapeutic response) for the individual patient’s level of ASCVD risk
is the fundamental recommendation of the AHA/ACC 2013 guidelines, it is the
matching of risk to dose/treatment that is responsible for the desired
reduction in ASCVD events premise. The recommendation of the ACC/AHA
guidelines and other national guidance (e.g. NLA, AACEE), is not to just
prescribe any statin at any dose, as evidenced by the specificity of
recommendations for the intensity of dosing by patient population and the
grouping of drugs with dosing into the different intensity recommendations.
Our concern is that this measure will give a passing mark to everyone who
orders a statin for a patient and will not have the intended effect of
providing patients with the intensity of therapy appropriate for their level
of risk which is what is required to achieve maximum reduction in ASCVD risk.
In addition, we have not seen the specifications and are concerned that the
numerator will not include other lipid-lowering agents which may be required
for appropriate, optimal management of many patients who are either statin
intolerant or resistant. This may impact up 40-60% of the patients. For
many, the combination of a statin with another drug (ezetimibe or niacin) is
needed to achieve the desired reduction. (Karalis 2012.
doi:10.1155/2012/861924). This is supported by the positive results of the
IMProved Reduction of Outcomes: Vytorin Efficacy International Trial
(IMPROVE-IT). This trial evaluated the potential benefit for reduction in
major cardiovascular (CV) events from the addition of ezetimibe versus placebo
to statin therapy (Blazing, 2014: 205-212). IMPROVE-IT results were presented
at the AHA Scientific Sessions 2014, including separate analyses of the
intent-to-treat and on-treatment patient populations. Trial results met
primary endpoint, showing ~ 2% reduction in CV events with Vytorin
(ezetimibe/simvastatin) vs. simvastatin (HR=0.936, p=0.016; 6.4% relative risk
reduction). IMPROVE-IT results are consistent with the established
relationship between absolute reductions in LDL-C and reductions in major CV
events (Baigent, 2010: 167-81). It is the first trial to show that adding a
non-statin to a statin to further reduce LDL-C levels can help to reduce CV
events. Because of the need for combination therapy to achieve therapeutic
results and the time lag in incorporating new evidence and drugs in the
guidelines, the addition of “statins and other lipid-lowering drugs” would
allow the measure to be timely as new evidence and drugs become available.
(Submitted by: SMT, Inc)
- Reasonable composite measurement - as long as parsimony oversees the
Burden of measurement (Submitted by: American Medical Group Association -
KF)
- The draft MAP report includes a discussion of the composite measure for
optimal control of cardiovascular disease under consideration for the MIPs and
MSSP programs. The draft report describes the potential redundancy between
this measure and other measures, such as the “Million Hearts” measure
currently used in both programs. The MAP supported the value of the composite
measure and supported the use of NQF to ultimately decide after thorough
review which measure related to quality of cardiovascular care is “best in
class” and should be used in the quality programs. We recognize the importance
of this composite measure, but once again emphasize the importance of
appropriate risk adjustment to account for providers caring for high risk
populations from both a clinical and socio-demographic standpoint. (Submitted
by: Association of American Medical Colleges (AAMC))
- (Early public comment)We support the composite approach with this
measure and the description of the measure with four criteria required to
achieve compliance. We cannot support the measure as it has been revised from
the original version in which cholesterol risk was addressed by the criteria
of ‘LDL less than 100’ as part of the numerator. The rationale for the
removal of the LDL level was provided in the NQF May 2014 update of the
measure: the removal was based on the 2013 AHA/ACC guidelines and the MN
Community indicated that it intended to revise the measure in 2016 to be more
consistent with the 2013 guidelines. This measure had been introduced by the
Wisconsin Collaborative for Healthcare Quality (WCHQ) with the addition of
‘statin use” as the 4th criteria. We have two objections. A. We believe the
retirement of the LDL-C criteria was based upon a misunderstanding of the
ACC/AHA Guidelines and is not supported by recent evidence or recommendations
from other medical societies. B. The requirement for use of a statin without
regard for the matching the patient’s level of risk with the dosing is not
consistent with national guidelines and will not achieve optimal desired
reduction in ASCVD events. A: LDL-C Criteria is an appropriate intermediate
outcome measurement First, Dr. Knowles and Dr. Stone’s paper, “Familial
Hypercholesterolemia and the 2013 American College of Cardiology/ American
Heart Association Guidelines: Myths, Oversimplification and Misinterpretation
versus Facts” American Journal of Cardiology, Aug. 1, 2015 Vol. 116, Issue 3,
pgs 481-484 (http://www.ajconline.org/article/S0002-9149(15)01260-6/abstract)
established the import of LDLs in the management of ASCVD risk in all
patients, highlighting the recommendation in the guidelines and the need for
periodic monitoring of the LDL-C level to determine adequacy of response to
therapy and adherence and the need to adjust the treatment regimen. It also
pointed out that statins alone do not provide the outcomes needed to protect
FH and high risk patients. This is further supported by the recommendations
and guidelines published by NLA, AACE and other societies. LDL levels are
critical to achieving intermediate and long term outcomes and the totality of
evidence does not support the omission of the LDL-C as a threshold or target.
Second, although specific LDL-C treatment goals are not recommended in the
guideline, the statin intensity recommendations are benchmarked against
expected LDL-C reductions in those initially being started on statins (i.e.
>50% high; 30% to <50% moderate) and includes guidance for LDL-C levels
for all patients. Considering heterogenic response in the natural setting
with statin tolerability, adherence, etc., measuring LDL-C (either directly or
calculated) is necessary to confirm patients are achieving treatment goals. To
this end, the guideline recommends monitoring response with lipid panels every
3 to 12 months (IA recommendation) and appropriate treatment adjustment).
2013 ACC/AHA Guideline on the Treatment of Blood Cholesterol to Reduce
Atherosclerotic Cardiovascular Risk in Adults: A Report of the American
College of Cardiology/American Heart Association Task Force on Practice
Guidelines, available at:
http://circ.ahajournals.org/content/early/2013/11/11/01.cir.0000437738.63853.7a.citation.
Third, we do not believe the focus on choice of therapy to the exclusion of
LDL levels is consistent with the guidelines and their intent. The charge of
CMS is to address treatment of blood cholesterol levels to reduce ASCVD risk.
They have provided an ASCVD risk calculator to determine a patient’s initial
risk and reduction in risk based on improved parameters. The parameters used
in calculating a person’s risk do not include use of statins or any other
reference to treatment methods. The parameters are clinical: they include
the patient’s LDL and HDL level. We cannot avoid measuring and considering the
absolute LDL if the intent is to reduce risk and ASCVD outcomes. In
addition, ACC/AHA has recognized that there has been some confusion arising
from the language used in the 2013 Guidelines and they have established
committees to address, refine or modify their recommendations to provide
additional clarity. We believe that the issue of LDL-C thresholds may be part
of this conversation and that any proposed changes to measures should be
delayed until the ACC/AHA have clarified their position. Fourth, we believe
it is not warranted to change LDL-C quality measures based on a single
guideline; and a guideline that is not endorsed by other key expert groups and
societies dedicated to diseases of metabolism, including the National Lipid
Association (NLA), American Academy of Clinical Endocrinologists (AACE), and
American Diabetes Association (ADA). AACE and ADA have separate cholesterol
guidelines that currently recommend LDL-C <100 mg/dL in high risk patients
including those with diabetes and those with prior ischemic events. Fifth, the
measure as written is contrary to CMS objectives to measure outcomes. New
legislation directed CMS to develop a strategic plan to integrate quality of
care into Pay for Performance. CMS recently published the PQRS Strategic
Vision, which presents a long-term vision to optimize quality measurements and
align physicians, professionals, and public reporting programs to support
better decision-making across the healthcare system. "CMS will continue to
move beyond 'check box' process measures. PQRS will be dominated by
patient-centered outcome and longitudinal measures that reflect change to
health status over time." The use of this measure would misdirect the VISION
objective to measure outcomes, impinge on dealing with socio-demographic
factors and women’s cardiovascular disease, and hamper CDC data needs for
achieving Million Hearts. In summary, we do not support the use of this
measure with the change to this measure as the new referenced guideline is
controversial and not endorsed by all relevant specialty medicine professions,
including the American Association of Clinical Endocrinologists. Removal of
the LDL screening and control components of the measure without adding any
means of evaluating hyperlipidemia treatment seems counterproductive and
harmful to patients. While the ACC/ AHA guidelines do not identify a target
LDL goal, they do state that once statin therapy is initiated, monitoring
should occur using LDL levels to ensure optimal treatment selection and
appropriate decrease in LDL levels. We think it is important to maintain a
measure component to evaluate lipid treatment and monitoring in this patient
population. B. Why ‘statin use’ alone is not sufficient to achieve optimal
results. Matching the appropriate dose of the statin (and achieving the
desired therapeutic response) for the individual patient’s level of ASCVD risk
is the fundamental recommendation of the AHA/ACC 2013 guidelines, it is the
matching of risk to dose/treatment that is responsible for the desired
reduction in ASCVD events premise. The recommendation of the ACC/AHA
guidelines and other national guidance (e.g. NLA, AACEE), is not to just
prescribe any statin at any dose, as evidenced by the specificity of
recommendations for the intensity of dosing by patient population and the
grouping of drugs with dosing into the different intensity recommendations.
Our concern is that this measure will give a passing mark to everyone who
orders a statin for a patient and will not have the intended effect of
providing patients with the intensity of therapy appropriate for their level
of risk which is what is required to achieve maximum reduction in ASCVD risk.
In addition, we have not seen the specifications and are concerned that the
numerator will not include other lipid-lowering agents which may be required
for appropriate, optimal management of many patients who are either statin
intolerant or resistant. This may impact up 40-60% of the patients. For
many, the combination of a statin with another drug (ezetimibe or niacin) is
needed to achieve the desired reduction. (Karalis 2012.
doi:10.1155/2012/861924). This is supported by the positive results of the
IMProved Reduction of Outcomes: Vytorin Efficacy International Trial
(IMPROVE-IT). This trial evaluated the potential benefit for reduction in
major cardiovascular (CV) events from the addition of ezetimibe versus placebo
to statin therapy (Blazing, 2014: 205-212). IMPROVE-IT results were presented
at the AHA Scientific Sessions 2014, including separate analyses of the
intent-to-treat and on-treatment patient populations. Trial results met
primary endpoint, showing ~ 2% reduction in CV events with Vytorin
(ezetimibe/simvastatin) vs. simvastatin (HR=0.936, p=0.016; 6.4% relative risk
reduction). IMPROVE-IT results are consistent with the established
relationship between absolute reductions in LDL-C and reductions in major CV
events (Baigent, 2010: 167-81). It is the first trial to show that adding a
non-statin to a statin to further reduce LDL-C levels can help to reduce CV
events. Because of the need for combination therapy to achieve therapeutic
results and the time lag in incorporating new evidence and drugs in the
guidelines, the addition of “statins and other lipid-lowering drugs” would
allow the measure to be timely as new evidence and drugs become available.
(Submitted by: SMT, Inc.)
(Program:
Medicare Shared Savings Program; MUC ID: MUC15-275) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- See comments for MIPS. (Submitted by: SMT, Inc)
- We support the rationale for this measure, but have concerns that the data
collection and medical record review could be a barrier to timely and accurate
reporting. (Submitted by: Johns Hopkins Armstrong Institute for Patient
Safety and Quality)
- (Early public comment)The measure overlaps with other measures
currently in MSSP (statin therapy, controlling high blood pressure and IVD-use
of aspirin) and should not be included in the program. (Submitted by:
Premier)
- (Early public comment)This measure is not NQF-endorsed (Submitted
by: AdvaMed)
(Program: Inpatient Rehabilitation Facility Quality Reporting Program; MUC
ID: MUC15-287) |
- These comments apply to MUC 15 - 287, 289, 291. The 'socioeconomic
concerns' - like ' unintended consequences' - while literal and applicable
for all applications of these three measures, are not enough of a deterrent to
not measure MSPB. (Submitted by: American Medical Group Association -
EB)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The lack of details around how CMS may define and implement a Medicare
Spending Per Beneficiary (“MSPB”) measure as applied to IRFs do not enable us
to comprehensively comment on such a measure. However, we share the following
general principles. First, any MSPB established for post-acute care providers
should be designed to compare specific provider types. That is, MSPB
performance should not be measured by comparing post-acute care hospitals to
home health agencies or SNFs; rather performance should be measured by
comparing IRFs to IRFs, LTCHs to LTCHs, SNFs to SNFs, and homecare providers
to homecare providers. Second, to the extent such a measure may be implemented
as part of a future PAC specific value-based purchasing program (“VBP”)
similar in design to the acute hospital VBP, any “withhold” amount should be
transitioned over a multi-year period. Third, adequate risk adjustment to
account for the unique patient mix and related clinical characteristics and
medical complexities would be critically important. Finally, an IRF-specific
MSPB should not penalize providers who are already efficient or provide an
imbalanced advantage to currently inefficient providers. Additionally, the
various PAC MSPB measures should be limited in the extent to which they
overlap with other each or with other MSPB measures. The overlap of two MSPB
measures results in the same Medicare dollars being counted twice against two
different providers. For example, if the IRF MSPB measure were to overlap
with home health MSPB measure, some portion of an IRF stay would be attributed
to a home health agency, and vice versa. Such a construct makes the MSPB
rates of both providers higher than it actually is. While the inaccuracy is a
concern in itself, the impact that MSPB overlap can have in a payment model
that rewards providers for controlled spending is also a liability.
(Submitted by: HealthSouth)
- The AHA agrees with the MAP’s recommendation on this measure. Furthermore,
we strongly urge CMS to assess the measure for the impact of sociodemographic
factors on performance, and to incorporate adjustment as needed. (Submitted
by: American Hospital Association (AHA))
- AAPM&R commends NQF for evolving its work to understand how measures
are being developed and implemented across settings and how they impact
payment reform. This is a huge endeavor that AAPM&R stands behind in
concept. However, AAPM&R cautions NQF to ensure their processes and
review of measures are adequately reported back to CMS and other rule-making
entities to ensure the NQF’s measurement expertise is realized in rule making.
The Academy has concerns about comparing physicians to a national rather
than regional median. There are great variances in each community the
strengths, room for growth and practices. Also this metric does not take into
account quality of IRF care per episode. As an example, an early AFO or early
training prosthetic may cost more but the patient outcome and total cost in
the continuum of their total rehab episode for that diagnosis may be less
because of earlier, more aggressive mobilization. (Submitted by: American
Academy of Physical Medicine and Rehabilitation )
- AMRPA has been analyzing resource use measures such as a Medicare Spending
Per Beneficiary (MSPB) measure. We have done extensive work internally to
prepare for this type of measure including development of the episode and
risk-adjustment factors. We are concerned that an MSPB measure will not
improve the quality of care patients receive and may actually have an adverse
effect on outcomes. At this time an MSPB measure is not ready for inclusion in
the Inpatient Rehabilitation Facility Quality Reporting Program (IRF QRP) as
the development by the Centers for Medicare and Medicaid Services (CMS) is in
its infancy, as noted by its Measure Under Consideration (MUC) development
status of “Early Development.” The technical expert panel (TEP) convened by
CMS to develop the measure met only recently and we assume its work is
ongoing. Additionally, the details available through the MUC list are
inadequate to provide relevant feedback that may assist in making appropriate
modifications to the measure. Our comments highlight our concerns with the
measure as outlined in the MUC List as well our recommendations for further
development of the measure. We support the following elements of this measure
as outlined in the MUC materials. First, we agree that there should be a
separate MSPB measure for each post-acute care (PAC) provider type. It is
critically important, given the difference among the PAC settings, payment
systems, and the types of patients they treat, that like providers be compared
(e.g., inpatient rehabilitation facilities (IRFs) compared to IRFs). Second,
we also support the use of a national benchmark for payment purposes because
of the regional variation in the number of IRFs. Third, we support the episode
definition for the IRF MSPB measure as the IRF admission (index admission),
the IRF stay, and 30 days following discharge from the IRF. As is done with
the IPPS MSPB measure used in the Value-based Purchasing (VBP) program, the
IRF MSPB measure should also be risk-adjusted. However, the severity should be
based on the IRF prospective payment system (PPS) Case Mix Groups (CMGs), and
not on inpatient prospective payment system (IPPS) diagnostic related groups
(DRGs) because DRGs are not sensitive enough to capture the variation in IRF
patients. Risk-adjustment should also factor in socioeconomic and
sociodemographic characteristics as outlined in the National Quality Forum
(NQF) report entitled Risk Adjustment for Socioeconomic Status or Other
Sociodemographic Factors: Technical Report. These characteristics would
include factors such as the availability of caregiver and community supports
and race. We have also considered various exclusion and inclusion criteria for
an IRF MSPB measure. We believe all patients and diagnoses should be included,
but limit the measure to Medicare fee for service (FFS) patients thereby
excluding patients under Medicaid and Medicare Advantage and those not
enrolled in Medicare FFS for at least 90 days prior to the MSPB episode of
care. All Part A and Part B services should also be included with the
exception of planned readmissions and the associated costs, as well as other
planned and/or routine treatments that are clinically unrelated to the IRF
responsibility (e.g., chemotherapy or dialysis). Furthermore, we believe that
any Medicare payments attributed to an IRF should remove the effects of or
otherwise control for facility-specific payments paid under the IRF PPS (e.g.,
wage, low-income, rural, and teaching adjustments) as well as high-cost
outlier payments received by the IRF. These payments are unrelated to any
treatment services or associated services considered as cost/resource use.
However, a measure must be a) risk-adjusted as noted above, and b) adjusted to
address whether there are resources so that the patient can be discharged home
(e.g., family, or other caregiver). Not acknowledging the availability of
resources at home can lead to a bar to admissions (e.g., the patient would
require discharge to other settings and therefore more payments). Claims data
could be used but if a claim was denied by a Medicare contractor it should not
be included in the MSPB calculation. In addition to claims data, we recommend
the measure include items that examine functional and cognitive status and
patient comorbidities. To ensure the highest reliability of this information,
such data should be collected from PAC provider's assessment instruments and
should rely on functional measurements with which the field has the most
experience and for which the largest evidence base exists for its validity,
reliability, and predictive value, such as the functional independence measure
(FIM) scale. We understand that the IRF MSPB as outlined in the MUC List is
limited to resource use and does not seem to incorporate measures of
providers’ performance on quality outcomes. However, we also recognize that
future CMS and/or NQF initiatives may combine resource use/MPSB with
providers’ quality performance such as in a VBP program. While AMRPA supports
a national benchmark for expenditures as stated earlier, AMRPA does not
support holding providers to a national benchmark for quality performance such
as patient outcomes measures. There are regional variations in patient
outcomes beyond a provider’s control. For example, urban settings have higher
return to community rates than rural regions. If a regional benchmark (however
regional is defined) were to be used, it would need to include a sample size
of at least 30 IRFs for statistical purposes and power analysis. As noted, we
support the episode as outlined in the description and measure specifications.
However, there are too few details included in the MUC List materials to
effectively determine if the measure is appropriately developed. For example,
the risk-adjustment factors, if any, are not identified. In addition, several
keys terms need to be defined. 1. The measure description states, “The
MSPB-PAC episode includes all services during the episode window that are
attributable to the IRF provider and those rendered by other providers, except
those services during the associated services period that are clinically
unrelated to IRF responsibilities (e.g., planned care and routine screening).”
However, planned care and routine services are not defined. This makes it
challenging at best to determine if the episode window and services included
are appropriate. A clear definition of planned care and routine screenings is
critically important because patients with cancer, a transplant, or undergoing
dialysis, for example, might have high costs that should not be attributed to
the IRF because they are part of an ongoing treatment plan developed for the
patient based on their particular clinical needs. 2. Similarly,
specifications regarding planned and unplanned readmissions should be defined
and open for stakeholder feedback to determine if the episode window and
included services are appropriate. 3. The numerator description includes
several terms that need to be defined before we can comment completely. They
are standardized episode spending, expected episode spending, and average
standardized episode spending across all providers. 4. The denominator is
defined as “Measure is the weighted median MSPB-PAC Amount across all episodes
for IRFs nationally,” but insufficient information is provided about the
weighting methodology. Given the limited details provided and the fact that
this measure is still under development, AMRPA cannot support the MSPB measure
for inclusion in the IRF QRP at this time. Until additional details are
provided, it would be premature for the NQF MAP PAC/LTC Workgroup to provide
support for this measure. (Submitted by: American Medical Rehabilitation
Providers Association)
- ARN is concerned with how this information will be reported so that it is
meaningful to patients. Spending per beneficiary does not necessarily imply
better or higher quality care. (Submitted by: Association of Rehabilitation
Nurses)
- FAH opposes the inclusion of this measure in the IRF QRP. We strongly
support the workgroup's recommendation that further development of the measure
should include robust SDS adjustment. We strongly urge NQF to require
developers to explore additional SDS factors beyond the current variables that
are often used in the analysis (e.g., dual eligible status, race) and ask that
MAP make clear recommendations to CMS that a broader set of variables should
be included in the measures submitted for future consideration. From a
value-based payment or pay-for-performance perspective, the FAH continues to
question the value of an MSPB measure; particularly, as the IRF has little
control over costs and resource use following discharge. (Submitted by:
Federation of American Hospitals)
- (Early public comment)As an IMPACT Act measure that is stated to be
"standardized and interoperable", we are highly concerned that this measure
may allow for comparison between PAC venues without making adjustments for
patient severity or differences inherent within the various payment systems.
For example, some of the PAC venues are paid on a per diem basis, while other
PAC venues have payments that are episodic. How are these differences
accounted for in the measurement calculations. Additionally, each PAC venue
has different regulatory requirements impacting their ability to control
costs, which are not adequately accounted for in this measure. We also note
that at this time some of the PAC venues are in the midst of drastic changes
to their payment systems. Will the currently developed calculations of this
measure be impacted by changes to underlying payment systems? And finally, the
IMPACT Act also requests a report from MedPAC on the feasibility of a unified
PAC payment system. This work is currently underway, and may provide further
clarity to differences in payments between PAC sites. (Submitted by:
UDSMR)
- (Early public comment)AMRPA has been analyzing resource use
measures such as a Medicare Spending Per Beneficiary (MSPB) measure. We have
done extensive work internally to prepare for this type of measure including
development of the episode and risk-adjustment factors. We are concerned that
an MSPB measure will not improve the quality of care patients receive and may
actually have an adverse effect on outcomes. At this time an MSPB measure is
not ready for inclusion in the Inpatient Rehabilitation Facility Quality
Reporting Program (IRF QRP) as the development by the Centers for Medicare and
Medicaid Services (CMS) is in its infancy, as noted by its Measure Under
Consideration (MUC) development status of “Early Development.” The technical
expert panel (TEP) convened by CMS to develop the measure met only recently
and we assume its work is ongoing. Additionally, the details available through
the MUC list are inadequate to provide relevant feedback that may assist in
making appropriate modifications to the measure. Our comments highlight our
concerns with the measure as outlined in the MUC List as well our
recommendations for further development of the measure. We support the
following elements of this measure as outlined in the MUC materials. First, we
agree that there should be a separate MSPB measure for each post-acute care
(PAC) provider type. It is critically important, given the difference among
the PAC settings, payment systems, and the types of patients they treat, that
like providers be compared (e.g., inpatient rehabilitation facilities (IRFs)
compared to IRFs). Second, we also support the use of a national benchmark for
payment purposes because of the regional variation in the number of IRFs.
Third, we support the episode definition for the IRF MSPB measure as the IRF
admission (index admission), the IRF stay, and 30 days following discharge
from the IRF. As is done with the IPPS MSPB measure used in the Value-based
Purchasing (VBP) program, the IRF MSPB measure should also be risk-adjusted.
However, the severity should be based on the IRF prospective payment system
(PPS) Case Mix Groups (CMGs), and not on inpatient prospective payment system
(IPPS) diagnostic related groups (DRGs) because DRGs are not sensitive enough
to capture the variation in IRF patients. Risk-adjustment should also factor
in socioeconomic and sociodemographic characteristics as outlined in the
National Quality Forum (NQF) report entitled Risk Adjustment for Socioeconomic
Status or Other Sociodemographic Factors: Technical Report. These
characteristics would include factors such as the availability of caregiver
and community supports and race. We have also considered various exclusion and
inclusion criteria for an IRF MSPB measure. We believe all patients and
diagnoses should be included, but limit the measure to Medicare fee for
service (FFS) patients thereby excluding patients under Medicaid and Medicare
Advantage and those not enrolled in Medicare FFS for at least 90 days prior to
the MSPB episode of care. All Part A and Part B services should also be
included with the exception of planned readmissions and the associated costs,
as well as other planned and/or routine treatments that are clinically
unrelated to the IRF responsibility (e.g., chemotherapy or dialysis).
Furthermore, we believe that any Medicare payments attributed to an IRF
should remove the effects of or otherwise control for facility-specific
payments paid under the IRF PPS (e.g., wage, low-income, rural, and teaching
adjustments) as well as high-cost outlier payments received by the IRF. These
payments are unrelated to any treatment services or associated services
considered as cost/resource use. However, a measure must be a) risk-adjusted
as noted above, and b) adjusted to address whether there are resources so that
the patient can be discharged home (e.g., family, or other caregiver). Not
acknowledging the availability of resources at home can lead to a bar to
admissions (e.g., the patient would require discharge to other settings and
therefore more payments). Claims data could be used but if a claim was denied
by a Medicare contractor it should not be included in the MSPB calculation. In
addition to claims data, we recommend the measure include items that examine
functional and cognitive status and patient comorbidities. To ensure the
highest reliability of this information, such data should be collected from
PAC provider's assessment instruments and should rely on functional
measurements with which the field has the most experience and for which the
largest evidence base exists for its validity, reliability, and predictive
value, such as the functional independence measure (FIM) scale. We understand
that the IRF MSPB as outlined in the MUC List is limited to resource use and
does not seem to incorporate measures of providers’ performance on quality
outcomes. However, we also recognize that future CMS and/or NQF initiatives
may combine resource use/MPSB with providers’ quality performance such as in a
VBP program. While AMRPA supports a national benchmark for expenditures as
stated earlier, AMRPA does not support holding providers to a national
benchmark for quality performance such as patient outcomes measures. There
are regional variations in patient outcomes beyond a provider’s control. For
example, urban settings have higher return to community rates than rural
regions. If a regional benchmark (however regional is defined) were to be
used, it would need to include a sample size of at least 30 IRFs for
statistical purposes and power analysis. As noted, we support the episode as
outlined in the description and measure specifications. However, there are too
few details included in the MUC List materials to effectively determine if the
measure is appropriately developed. For example, the risk-adjustment factors,
if any, are not identified. In addition, several keys terms need to be
defined. 1. The measure description states, “The MSPB-PAC episode includes
all services during the episode window that are attributable to the IRF
provider and those rendered by other providers, except those services during
the associated services period that are clinically unrelated to IRF
responsibilities (e.g., planned care and routine screening).” However, planned
care and routine services are not defined. This makes it challenging at best
to determine if the episode window and services included are appropriate. A
clear definition of planned care and routine screenings is critically
important because patients with cancer, a transplant, or undergoing dialysis,
for example, might have high costs that should not be attributed to the IRF
because they are part of an ongoing treatment plan developed for the patient
based on their particular clinical needs. 2. Similarly, specifications
regarding planned and unplanned readmissions should be defined and open for
stakeholder feedback to determine if the episode window and included services
are appropriate. 3. The numerator description includes several terms that
need to be defined before we can comment completely. They are standardized
episode spending, expected episode spending, and average standardized episode
spending across all providers. 4. The denominator is defined as “Measure is
the weighted median MSPB-PAC Amount across all episodes for IRFs nationally,”
but insufficient information is provided about the weighting methodology.
Given the limited details provided and the fact that this measure is still
under development, AMRPA cannot support the MSPB measure for inclusion in the
IRF QRP at this time. Until additional details are provided, it would be
premature for the NQF MAP PAC/LTC Workgroup to provide support for this
measure. (Submitted by: American Medical Rehabilitation Providers
Association)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)We believe that cost information alone cannot
capture the quality of care provided by IRFs. Accordingly, we think that this
measure should only be used in close conjunction with other quality outcome
measures. As such, we believe that NQF’s consideration of this measure should
include special attention to its “intended use” within the Medicare program.
Furthermore, while we support the development of resource use measures
generally, we believe that such measures, like the IRF MSPB measure, should
also have adequate risk adjustment in order to account for unique patient mix
and related clinical characteristics that can exist within the IRF patient
population. (Submitted by: HealthSouth)
(Program:
Long-Term Care Hospital Quality Reporting Program; MUC ID: MUC15-289)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The AHA agrees with the MAP’s recommendation on this measure. Furthermore,
we strongly urge CMS to assess the measure for the impact of sociodemographic
factors on performance, and to incorporate adjustment as needed. (Submitted
by: American Hospital Association (AHA))
- We agree with MAP that there are potential unintended consequences of the
measures and the need for appropriate risk adjustments for the discharge to
community measure and the potentially preventable 30-day post-discharge
readmission measure. We recommend adjusting for factors that play a
significant role in determining resource use and outcomes in the LTCH setting,
such as prolonged mechanical ventilation, multiple organ failure, and three or
more days in an intensive care unit. We also recommend adjustment based on
socioeconomic factors. Issues related to standard and site neutral LTCH cases
for the Medicare Spending per Beneficiary measure Cases in an LTCH can be paid
according to two different payment structures, standard MS-LTC-DRG or the site
neutral rate, depending on whether the case meets certain criteria.
Recognizing the differences in these payment structures, the Medicare spending
per beneficiary measure is constructed differently for standard and site
neutral LTCH cases. Specifically, the associated services period for the
standard LTCH cases begins at admission to an LTCH and ends 30 days after
discharge whereas the associated services period for the site neutral cases
begins at discharge from LTCH and ends 30 days after discharge. Although the
measure is constructed differently for each LTCH case, both standard and site
neutral cases are pooled in estimating the hierarchical model that drives the
predicted and expected spending in the numerator definition. Since the
associated services period for standard LTCH cases also includes the LTCH
stay, the resource use for the two types of cases may be systematically
different even after controlling for patient characteristics observable in the
Medicare claims data. As a result, hospitals that have a higher percentage of
standard LTCH cases compared to the average hospital may have higher average
ratio of standardized to expected episode spending than the average hospital.
Therefore, the Medicare spending per beneficiary measure may reflect
differences in the prevalence of standard vs. site neutral cases across LTCHs
instead of differences in resource use efficiency. (Submitted by: National
Association of Long Term Hospitals)
- ARN is concerned with how this information will be reported so that it is
meaningful to patients. Spending per beneficiary does not necessarily imply
better or higher quality care. (Submitted by: Association of Rehabilitation
Nurses)
- FAH opposes the inclusion of this measure in the IRFQRP. We strongly
support the workgroup's recommendation that further development of the measure
should include robust SDS adjustment. We strongly urge NQF to require
developers to explore additional SDS factors beyond the current variables that
are often used in the analysis (e.g., dual eligible status, race) and ask that
MAP make clear recommendations to CMS that a broader set of variables should
be included in the measures submitted for future consideration. From a
value-based payment or pay-for-performance perspective, the FAH continues to
question the value of an MSPB measure; particularly, as the IRF has little
control over costs and resource use following discharge. (Submitted by:
Federation of American Hospitals)
- (Early public comment)As an IMPACT Act measure that is stated to be
"standardized and interoperable", we are highly concerned that this measure
may allow for comparison between PAC venues without making adjustments for
patient severity or differences inherent within the various payment systems.
For example, some of the PAC venues are paid on a per diem basis, while other
PAC venues have payments that are episodic. How are these differences
accounted for in the measurement calculations. Additionally, each PAC venue
has different regulatory requirements impacting their ability to control
costs, which are not adequately accounted for in this measure. We also note
that at this time some of the PAC venues are in the midst of drastic changes
to their payment systems. Will the currently developed calculations of this
measure be impacted by changes to underlying payment systems? And finally, the
IMPACT Act also requests a report from MedPAC on the feasibility of a unified
PAC payment system. This work is currently underway, and may provide further
clarity to differences in payments between PAC sites. (Submitted by:
UDSMR)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)Cases in an LTCH can be paid according to two
different payment structures, standard MS-LTC-DRG or the site neutral rate,
depending on whether the case meets certain criteria. Recognizing the
differences in these payment structures, the MSPB-PAC LTCH QRP Measure is
constructed differently for standard and site neutral LTCH cases.
Specifically, the associated services period for the standard LTCH cases
begins at admission to an LTCH and ends 30 days after discharge whereas the
associated services period for the site neutral cases begins at discharge from
LTCH and ends 30 days after discharge. Issues Related to Standard and Site
Neutral LTCH Cases Although the measure is constructed differently for each
LTCH case, both standard and site neutral cases are pooled in estimating the
hierarchical model that drives the predicted and expected spending in the
numerator definition. Since the associated services period for standard LTCH
cases also includes the LTCH stay, the resource use for the two types of cases
may be systematically different even after controlling for patient
characteristics observable in the Medicare claims data. As a result,
hospitals that have a higher percentage of standard LTCH cases compared to the
average hospital may have higher average ratio of standardized to expected
episode spending than the average hospital. Therefore, the MSPB-PAC LTCH QRP
measure may reflect differences in the prevalence of standard vs. site neutral
cases across LTCHs instead of differences in resource use efficiency. Issues
Related to Risk Adjustment The risk adjustment variables should include
factors that control for differences in patient acuity across settings,
including the use of assessment data being collected under the IMPACT Act. We
recommend adjusting for factors that play a significant role in determining
resource use and outcomes in the LTCH setting, such as prolonged mechanical
ventilation, multiple organ failure, and three or more days in an intensive
care unit. For consistency across PAC providers, these risk adjustors should
be from a prior short term acute care hospital stay, generating the need to
limit the measure sample to those who have had a short term acute care
hospital stay within a given period prior to PAC stay. We also recommend
adjustment based on socioeconomic factors. While Medicare claims data are
more readily available than other data sources, they may not capture finer
distinctions across patients that affect patients’ outcomes. Therefore, a
process to include assessment data in the MSPB-PAC measure calculations, once
available, needs to be established and followed. The measure should not be
used to compare across setting or at least not used to compare across setting
until the assessment data have been incorporated, tested, and validated.
(Submitted by: National Association of Long Term Hospitals)
(Program:
Skilled Nursing Facility Quality Reporting System; MUC ID: MUC15-291)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. AHCA is pleased to have the opportunity to comment on the MAP
Preliminary Decisions and MAP Draft Report ”. Thank you again for the
opportunity to provide these comments. Please contact me at DGifford@ahca.org
with any questions or for additional information. We support the MAP’s
preliminary decision to “encourage continued development” of this measure.
However, in the draft report, the MAP must clearly state that encouraging
continued development of this measures should not be taken as support of
inclusion of this measure in the SNF QRP. We also think the report needs to
include the comments and recommendations made by the MAP workgroup on each
measure since that is the primary role of the MAP to provide DHHS with
feedback on the MUC list and DHHS needs to respond to those comments in any
proposed rule. Without inclusion of these comments, if DHHS decided to
implement this measure for rule making via the Federal Register process, CMS
does not need to provide a rationale for their decision. Additionally, for the
sake of transparency and enhanced stakeholder feedback the draft report should
include the specific public comments submitted. Our specific comments on this
measure are as follows. This measure has not been specified, even in draft
form. In fact, the TEP discussion raised some serious concerns about the
measure. While no one has seen any specifications for the measure, including
TEP members, the material shared with the TEP indicates that the measure will
double count costs between PAC providers (and in the case of SNF and HH, will
double count certain beneficiary costs within a provider). For example, the
TEP panelists were presented with a measure model ‘concept’ that, instead of
measuring the cost of each beneficiary as the beneficiary navigates through
their post-acute clinical path, and attributing the true per-beneficiary costs
to the provider that was the beneficiary’s PAC entry point, the model instead
attributes beneficiary costs from the point of entry onto each PAC setting, as
well as healthcare costs for a specified time after discharge from each
setting. This results in the double-counting of per-beneficiary costs for the
time overlap when a beneficiary transitions from one PAC provider to another.
In the specific case of SNF, the model presented to the TEP would double-count
certain beneficiary costs within a single 100-day benefit period in cases
where the beneficiary was hospitalized for 8 or more days and readmitted to
the SNF during the same SNF benefit period. Similarly for HH, the model
presented would double-count certain beneficiary costs for a single HH
provider for beneficiaries with chronic complex needs receives continuous care
for the same admission over several consecutive HH 60-day ‘episode’ payment
blocks. The rationale for this does not appear to make sense and also is
contrary to the legislative intent of the IMPACT act to develop a set of
common PAC measures that allows comparability between PAC settings. It also
could create beneficiary access issues for patients with chronic complex needs
in settings where per-beneficiary costs within a single course of treatment
are double counted as providers would be dis-incentivized to admit patients
with such characteristics. This measure requires more thoughtful
deliberation. The CMS measure development contractor convened the TEP on
October 30-31 without providing several panelists with necessary review
materials in advance, and then asked the TEP for input on over 5 pages of 30
questions about how to develop and specify the measure on November 18th with
comments due on November 25th. This was only two days before the publication
of the MUC list so it is quite apparent that the TEP panel’s comments were not
considered adequately prior to the submission of this proposed measure.
(Submitted by: American Health Care Association )
- AAPM&R commends NQF for evolving its work to understand how measures
are being developed and implemented across settings and how they impact
payment reform. This is a huge endeavor that AAPM&R stands behind in
concept. However, AAPM&R cautions NQF to ensure their processes and
review of measures are adequately reported back to CMS and other rule-making
entities to ensure the NQF’s measurement expertise is realized in rule making.
The Academy feels that this measure should be studied in greater detail. It
is unknown what outcome CMS would find acceptable. There is a risk of
providers focusing solely on cutting costs and ignoring any related negative
impacts on improvements in outcomes and quality. (Submitted by: American
Academy of Physical Medicine and Rehabilitation )
- ARN is concerned with how this information will be reported so that it is
meaningful to patients. Spending per beneficiary does not necessarily imply
better or higher quality care. (Submitted by: Association of Rehabilitation
Nurses)
- (Early public comment)This measure is currently in early
development and measure specifications are in preliminary stages of
clarification. The proposed application and episode extension appears to
create inaccurate spending within successive post-acute settings without any
indication of the true cost of care per beneficiary. The Technical Expert
Panel clearly indicated that this measure needs extensive work to assure
accuracy and to meet the purpose for which it was intended. Because there is
obvious potential for accuracy in the proposed measure significant continued
development should be encouraged. (Submitted by: Genesis Health
Care)
- (Early public comment)AHCA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. Thank you again for the opportunity to provide these comments. Please
contact me at DGifford@ahca.org with any questions or for additional
information. This measure has not been specified, even in draft form. In
fact, the TEP discussion raised some serious concerns about the measure. While
no one has seen any specifications for the measure, including TEP members, the
material shared with the TEP indicates that the measure will double count
costs between PAC providers (and in the case of SNF and HH, will double count
certain beneficiary costs within a provider). For example, the TEP panelists
were presented with a measure model ‘concept’ that, instead of measuring the
cost of each beneficiary as the beneficiary navigates through their post-acute
clinical path, and attributing the true per-beneficiary costs to the provider
that was the beneficiary’s PAC entry point, the model instead attributes
beneficiary costs from the point of entry onto each PAC setting, as well as
healthcare costs for a specified time after discharge from each setting. This
results in the double-counting of per-beneficiary costs for the time overlap
when a beneficiary transitions from one PAC provider to another. In the
specific case of SNF, the model presented to the TEP would double-count
certain beneficiary costs within a single 100-day benefit period in cases
where the beneficiary was hospitalized for 8 or more days and readmitted to
the SNF during the same SNF benefit period. Similarly for HH, the model
presented would double-count certain beneficiary costs for a single HH
provider for beneficiaries with chronic complex needs receives continuous care
for the same admission over several consecutive HH 60-day ‘episode’ payment
blocs. The rationale for this does not appear to make sense and also is
contrary to the legislative intent of the IMPACT act to develop a set of
common PAC measures that allows comparability between PAC settings. It also
could create beneficiary access issues for patients with chronic complex needs
in settings where per-beneficiary costs within a single course of treatment
are double counted as providers would be dis-incentivized to admit patients
with such characteristics. This measure requires more thoughtful
deliberation. The CMS measure development contractor convened the TEP on
October 30-31 without providing several panelists with necessary review
materials in advance, and then asked the TEP for input on over 5 pages of 30
questions about how to develop and specify the measure on November 18th with
comments due on November 25th. This was only two days before the publication
of the MUC list so it is quite apparent that the TEP panel’s comments were not
considered adequately prior to the submission of this proposed measure.
Therefore, we believe this measure does not meet NQF MAP criteria for
endorsement but rather should receive a vote of “encourage continued
development”. (Submitted by: American Health Care Association )
- (Early public comment)As an IMPACT Act measure that is stated to be
"standardized and interoperable", we are highly concerned that this measure
may allow for comparison between PAC venues without making adjustments for
patient severity or differences inherent within the various payment systems.
For example, some of the PAC venues are paid on a per diem basis, while other
PAC venues have payments that are episodic. How are these differences
accounted for in the measurement calculations. Additionally, each PAC venue
has different regulatory requirements impacting their ability to control
costs, which are not adequately accounted for in this measure. We also note
that at this time some of the PAC venues are in the midst of drastic changes
to their payment systems. Will the currently developed calculations of this
measure be impacted by changes to underlying payment systems? And finally, the
IMPACT Act also requests a report from MedPAC on the feasibility of a unified
PAC payment system. This work is currently underway, and may provide further
clarity to differences in payments between PAC sites. (Submitted by:
UDSMR)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)AMDA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
AMDA - The Society for Post-Acute and Long-Term Care Medicine (AMDA)
represents over 5,500 physician medical directors, attending physicians, and
other practitioners who work in post-acute and long-term care settings.
Thank you again for the opportunity to provide these comments. Please contact
me at abardakh@amda.com with any questions or for additional information.
This measure has not been specified, even in draft form. In fact, the TEP
discussion raised some serious concerns about the measure. While no one has
seen any specifications for the measure, including TEP members, the material
shared with the TEP indicates that the measure will double count costs between
PAC providers (and in the case of SNF and HH, will double count certain
beneficiary costs within a provider). For example, the TEP panelists were
presented with a measure model ‘concept’ that, instead of measuring the cost
of each beneficiary as the beneficiary navigates through their post-acute
clinical path, and attributing the true per-beneficiary costs to the provider
that was the beneficiary’s PAC entry point, the model instead attributes
beneficiary costs from the point of entry onto each PAC setting, as well as
healthcare costs for a specified time after discharge from each setting. This
results in the double-counting of per-beneficiary costs for the time overlap
when a beneficiary transitions from one PAC provider to another. In the
specific case of SNF, the model presented to the TEP would double-count
certain beneficiary costs within a single 100-day benefit period in cases
where the beneficiary was hospitalized for 8 or more days and readmitted to
the SNF during the same SNF benefit period. Also, costs may be higher in the
SNF for patients admitted for prolonged courses of IV antibiotics, wound care,
hemodialysis, and ventilator management. Similarly for HH, the model presented
would double-count certain beneficiary costs for a single HH provider for
beneficiaries with chronic complex needs receives continuous care for the same
admission over several consecutive HH 60-day ‘episode’ payment blocs. The
rationale for this does not appear to make sense and also is contrary to the
legislative intent of the IMPACT act to develop a set of common PAC measures
that allows comparability between PAC settings. It also could create
beneficiary access issues for patients with chronic complex needs in settings
where per-beneficiary costs within a single course of treatment are double
counted as providers would be dis-incentivized to admit patients with such
characteristics. This measure requires more thoughtful deliberation. The CMS
measure development contractor convened the TEP on October 30-31 without
providing several panelists with necessary review materials in advance, and
then asked the TEP for input on over 5 pages of 30 questions about how to
develop and specify the measure on November 18th with comments due on November
25th. This was only two days before the publication of the MUC list so it is
quite apparent that the TEP panel’s comments were not considered adequately
prior to the submission of this proposed measure. Therefore, we believe this
measure does not meet NQF MAP criteria for endorsement but rather should
receive a vote of “encourage continued development”. (Submitted by: AMDA-The
Society for Post-Acute and Long-Term Care Medicine)
- (Early public comment)This measure is complicated and should be
fully vetted before it continues. it does not seem to meet the intent of the
IMPACT Act that provides for comparing one post acute setting with another
because some costs in the measure are counted twice. This measure needs more
detail in order to review it and needs comprehensive testing. (Submitted
by: National Association for the Suppor of Long Term Care)
(Program: Hospital Inpatient Quality Reporting and EHR Incentive Program;
MUC ID: MUC15-294) |
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The AHA/ASA supports the MAPs recommendation and appreciates the efforts
of CMS to refine the risk model for this claims-based measure by the addition
of the NIH Stroke Scale as a measure of stroke severity. The implementation of
a new ICD-10 code for initial NIHSS, which is expected to occur in October
2016, should facilitate its use in the revised risk model. We agree with the
MAP that CMS should carefully consider its implementation strategy as this,
and the 2 alternative measures, are rolled out, to avoid confusion among the
different versions or undue burden to hospitals. (Submitted by: American Heart
Association)
- Generally, SHM supports the NQF’s recommendation for conditional support
of this measure. While we agree conceptually with the MAP’s indication that
mortality may not be the most meaningful outcome for stroke patients, we have
concerns about the implementation of a more nuanced measure and how data on
other outcomes could be collected in a standardized way. (Submitted by:
Society of Hospital Medicine)
- We agree that mortality is not the most meaningful outcome for stroke
patients and would prefer measures assessing cognitive and functional
outcomes. However, we support this measure as it adjusts the existing measure
for stroke severity. (Submitted by: Premier)
- GNYHA agrees with MAP’s decision to conditionally support adoption of this
measure in the Hospital Inpatient Quality Reporting Program, pending NQF
review and endorsement. GNYHA is pleased that CMS has addressed past concerns
raised by stakeholders about addressing stroke severity in this measure. This
updated measure has been revised to include the National Institutes of Health
Stroke Scale as a measure of stroke severity in the risk-adjustment. However,
GNYHA also has the same concerns as the MAP that mortality is not the most
meaningful outcome when tracking outcomes of stroke patients. (Submitted by:
Greater New York Hospital Association)
- Genentech feels strongly that the CMS Stroke 30-Day Mortality and
Readmission measures need to be adjusted for stroke severity and supports
efforts to improve on these measures. We agree with MAP that Mortality may
not be the most meaningful outcome for stroke patients and that there is a
need for outcomes measures that consider cognitive and functional outcomes.
To that end, we believe that stroke outcome measures should if possible align
to those outcomes most frequently measured in stroke clinical trials such as
the modified Rankin Scale and NIHSS scale, not only at patient discharge but
also after a follow up period, for example 30 and 90 days after stroke.
(Submitted by: Genentech)
- Genentech feels strongly that the CMS Stroke 30-Day Mortality and
Readmission measures need to be adjusted for stroke severity and supports
efforts to improve on these measures. We agree with MAP that Mortality may
not be the most meaningful outcome for stroke patients and that there is a
need for outcomes measures that consider cognitive and functional outcomes.
To that end, we believe that stroke outcome measures should if possible align
to those outcomes most frequently measured in stroke clinical trials such as
the modified Rankin Scale and NIHSS scale, not only at patient discharge but
also after a follow up period, for example 30 and 90 days after stroke.
(Submitted by: Genentech)
- CAPC urges the MAP to change its preliminary recommendation for MUC15-294
from “Conditional Support” for inclusion in the Hospital Inpatient Quality
Reporting program (conditional pending NQF review and endorsement) to “Do Not
Support”. Schwarze et al. (2014) noted that the use of 30-day mortality
measures can inhibit the use of palliative services and fail to accommodate
the wishes of patients who would prefer death over prolonged life-sustaining
treatment. As proposed, this measure does not provide for consideration of a
patient’s goals of care – including the decision to withdraw life-sustaining
treatment – in setting of severe stroke. Inclusion of this measure in the HIQR
could create perverse incentives to keep patients alive despite their wishes;
it is easy to keep someone alive on a percutaneous endoscopic gastronomy tube
for a long period of time following acute stroke. This measure could also
potentially inhibit palliative care referral, as some providers may fear the
consequences of patients choosing to pursue comfort-related goals. We strongly
urge MAP to reconsider its position on this measure, and reiterate the MAP’s
suggestion to consider cognitive or functional outcomes such as impaired
capacity. (Submitted by: Center to Advance Palliative Care)
- We disagree with MAP’s recommendation to conditionally support this
measure and urge the MAP NOT to support this mortality measure. The use of
30-day mortality measures can inhibit the use of palliative services and fail
to accommodate the wishes of patients who would prefer death over prolonged
life-sustaining treatment. As proposed, this measure does not provide for
consideration of a patient’s goals of care – including the decision to
withdraw life-sustaining treatment – in setting of severe stroke. Inclusion of
this measure in the HIQR could create perverse incentives to keep patients
alive despite their wishes. This measure could also potentially inhibit
palliative care referral, as some providers may fear the consequences of
patients choosing to pursue comfort-related goals. We strongly urge MAP to
reconsider its position on this measure, and reiterate the MAP’s suggestion to
consider cognitive or functional outcomes such as impaired capacity. If the
MAP does proceed with recommending conditional support of this measure, at the
very least there should be an exclusion for both hospice patients and those
who opt to receive primarily palliative care. It is equally important to
include "discharged to hospice" as part of the exclusion criteria as it is to
include “admitted from hospice.” Hospitals should not be penalized for the
mortality of patients discharged to hospice or this will set up a disincentive
to discharge patients from hospital to hospice. (Submitted by: American
Academy of Hospice and Palliative Medicine)
- AAHPM urges the MAP to change its recommendation to “do not support.” The
use of 30-day mortality measures can inhibit the use of palliative services
and fail to accommodate the wishes of patients who would prefer death over
prolonged life-sustaining treatment. As proposed, this measure does not
provide for consideration of a patient’s goals of care – including the
decision to withdraw life-sustaining treatment – in setting of severe stroke.
Inclusion of this measure in the HIQR could create perverse incentives to keep
patients alive despite their wishes. This measure could also potentially
inhibit palliative care referral, as some providers may fear the consequences
of patients choosing to pursue comfort-related goals. We strongly urge MAP to
reconsider its position on this measure, and reiterate the MAP’s suggestion to
consider cognitive or functional outcomes such as impaired capacity. If this
measure is ever adopted, at the very least, it should include an exclusion for
both hospice patients and those who opt to receive primarily palliative care.
It is equally important to include "discharged to hospice" as part of the
exclusion criteria as it is to include “admitted from hospice.” Hospitals
should not be penalized for the mortality of patients discharged to hospice or
this will set up a disincentive to discharge patients from hospital to
hospice. (Submitted by: American Academy of Hospice and Palliative
Medicine)
- (Early public comment)We support adjusting the measure for stroke
severity; however, it is not clear if the revised measure has been endorsed.
Once the revision is endorsed we support using the updated measure in HIQR.
(Submitted by: Premier)
- (Early public comment)As with all mortality measures, Intermountain
has found the "all cause" mortality difficult to do performance improvement
on. Specifically, our providers would prefer a mortality related to the
initial disease process. (Submitted by: intermountain
Healthcare)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program: Hospital Value-Based Purchasing Program; MUC ID: MUC15-295)
|
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- We agree with MAP, this measure overlaps with MSPB and would create
unnecessary duplication in the program. (Submitted by: Premier)
- (Early public comment)Edwards supports inclusion of this
cost/resource use measure in the Hospital Value Based Purchasing program,
pending NQF review to ensure the measure is scientifically sound for use for
national public reporting and accountability programs. Edwards supports
efforts to specifically address both the cost of and quality of care when
selecting measures for inclusion in CMS programs. Reporting this measure with
an indicator of quality of care associated with total hip and/or total knee
arthroplasty, such as functional status, will increase understanding of the
value of healthcare services provided, while also illuminating drivers of
cost. Furthermore, by incentivizing hospitals to control costs for the
THA/TKA episode of care, this measure will likely drive improved care during
the admission through utilization of evidence-based practices to enhance
recovery, as well as improved care coordination to decrease readmissions and
increase patient utilization of less costly outpatient care. (Submitted by:
Edwards Lifesciences)
- (Early public comment)"This measure was recently added to HIQR and
requires additional experience before being incorporated into HVBP. CMS should
monitor if the bundled payment for THA/TKA (Comprhensive Care for Joint
Replacement model) impacts the performance of this measure; the model is
mandatroy in 67 regions and requires hospitals to reduce costs associated with
THA/TKA. The cohort for this measure is all hospitals in IQR (including those
in the bundle), the mandotory bundle could impact the expected payment for
all hospitals in IQR. The condition-specific payment meaures overlap with the
Medicare Spending Per Beneficiary measure that is currently in HIQR and HVBP;
adding segments of MSPB creates unecessary duplication in the programs. While
these payment measures would create alignment with the physician
value-modifier and later MIPS; MACRA establishment of patient relationship
categories and codes to attribute patients and episodes to providers, this
significantly change could the way the episode groupers are implemented and
lead to lack of alignment between the hospital and physician specifications.
Accordingly, the measures should not be added to hospital programs in advance
of finalizing the measures for physician programs. Additionally, we have
ongoing concerns about these measures. First, measures of Federal spending are
not real indicators of “value” for beneficiaries as they neither capture the
quality of care, nor are paired with measures that do so. Moreover, the
measures do not give beneficiaries a sense of their financial obligation so
they are not useful for public reporting and beneficiary engagement purposes.
Also, the spending measures are cross-cutting measures that are not
appropriate for evaluating care exclusively in the inpatient setting. CMS data
has previously shown that variation in total Medicare payments for episodes
are primarily due to readmission rates and post-acute care. Post-acute care
use varies due to wide ranging differences in local market availability of
these services and patterns of care, which are not within the hospital’s
control." (Submitted by: Premier)
- (Early public comment)ARN supports NQF’s acknowledgement that the
growth in Medicare spending highlights the need to incentivize high-value care
while ensuring all patients receive the right care at the right time in the
right setting. ARN believes the methodology used to develop this measure is
proper and we are hopeful that it successfully denotes the aims of the
measure, including capturing the differences in the payments for patients
undergoing THA/TKA, accounting for differences in payments across hospitals,
removing variation in payments due to payment adjustments that are not
directly related to clinical care, adjusting for hospital case mix, assessing
relative performance of hospitals, and aligning with THA/TKA quality outcome
measures. As THA and TKA procedures continue to increase and patients are
discharged across the PAC continuum, there will be a significant need to
standardize quality reporting mechanisms and payment methodology to enhance
the coordination of care. (Submitted by: Association of Rehabilitation
Nurses)
- (Early public comment)We believe this measure aligns with policy
objectives of bundled payment programs, and would fit within the VBP program.
(Submitted by: Smith & Nephew )
- (Early public comment)Ultimately, the AMA is hopeful that with some
refinements, tying costs and quality to well-defined episodes of care will
provide a more fair and accurate view of physician performance than the
measures that CMS is currently using in the hospital and physician value-based
purchasing programs. We do not think that the measures proposed in this rule
have been sufficiently refined; however, we also are opposed to layering
condition-specific measures on top of the broad total cost measures CMS is now
using. The AMA has expressed frequent objections to CMS’ use of overlapping
physician measures that all pick up the costs of a cohort of chronically ill
patients with significant health care costs that make physicians who treat
these patients more likely than others to face penalties under the value-based
modifier. We are concerned that the new episode measures proposed will
intensify similar problems on the hospital side and could create barriers to
care for some patients. The fact that these measures have not yet been
endorsed by NQF and that we do not know their final form adds to our
discomfort. (Submitted by: American Medical Association)
(Program: Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-296)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Optometric Association (AOA) recommends that the numerator
for MUC15-296 include a test that uses orange dye (fluorescein) and a blue
light to detect damage to the cornea. The cornea is the clear outer surface of
the eye, and without this dye and blue light, damage cannot be seen and will
be missed. Viewing devices incorporating blue light, and the ophthalmic
fluorescein strips necessary to accomplish this evaluation are inexpensive.
Furthermore, this recommended screening that uses orange dye (fluorescein) and
a blue light is of low risk to the individual being screened for corneal
abrasion. Without fluorescein examination the sensitivity of the exam will be
too low. Additionally, this is the only test that allows the provider to
determine the location and likely cause of a cornea injury depending on the
size, location, and shape of the staining. Left undiagnosed and untreated such
corneal injuries run a high risk of infection and painful and often recurrent
erosions and ulceration that can cause permanent vision loss (Submitted by:
American Optometric Association )
- (Early public comment)Although it does not look like a hospital
measure currently, the New Corneal Injury Not Diagnose in the PACU/ Recovery,
it would be difficult to capture this and track back to the
anesthesiologist/surgical encounter once the patient is in the clinic setting.
(Submitted by: Intermountain Healthcare)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)The American Optometric Association (AOA)
recommends that the numerator for MUC15-296 include a test that uses orange
dye (fluorescein) and a blue light to detect damage to the cornea. The cornea
is the clear outer surface of the eye, and without this dye and blue light,
damage cannot be seen and will be missed. Viewing devices incorporating blue
light, and the ophthalmic fluorescein strips necessary to accomplish this
evaluation are inexpensive. Furthermore, this recommended screening that uses
orange dye (fluorescein) and a blue light is of low risk to the individual
being screened for corneal abrasion. Additionally, this is the only test that
allows the provider to determine the location and likely cause of a cornea
injury depending on the size, location, and shape of the staining. Left
undiagnosed and untreated such corneal injuries run a high risk of infection
and painful and often recurrent erosions and ulceration. (Submitted by:
American Optometric Association)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-307)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program: Merit-Based Incentive Payment
System (MIPS); MUC ID: MUC15-313) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
(Program: Hospital Value-Based Purchasing
Program; MUC ID: MUC15-322) |
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- While SHM supports the concept of assessing costs around specific clinical
conditions, we have concerns about cases in this measure overlapping with
other measures, and therefore penalizing hospitals repeatedly for the same
costs. We believe that condition-specific cost measures may ultimately provide
more useful and actionable information for hospitals and hospitalists, however
use of this measure in a penalty program is not appropriate at this time.
(Submitted by: Society of Hospital Medicine)
- We agree with MAP, this measure overlaps with MSPB and would create
unnecessary duplication in the program. (Submitted by: Premier)
- We agree with MAP, this measure overlaps with MSPB and would create
unnecessary duplication in the program. (Submitted by: Premier)
- (Early public comment)Edwards supports inclusion of this
cost/resource use measure in the Hospital Value Based Purchasing program, as
addressing cost of care for a heart failure episode aligns with the National
Quality Strategy, addressing a condition that is significant driver of cost
for the Medicare program. Edwards supports efforts to specifically address
both the cost of and quality of care when selecting measures for inclusion in
CMS programs. Reporting this measure with an indicator of quality of care
associated with heart failure, such as the risk-standardized mortality and
risk-standardized readmission measures that CMS is already collecting through
the Hospital Inpatient Quality Reporting and Hospital Readmissions Reduction
Penalty Programs, will increase understanding of the value of healthcare
services provided, while also illuminating drivers of cost. Furthermore, by
incentivizing hospitals to control costs for the HF episode of care, this
measure will likely drive improved care during the admission through
utilization of evidence-based practices to enhance recovery, as well as
improved care coordination to decrease readmissions and increase patient
utilization of less costly outpatient care, particularly given that HF is
largely managed in the outpatient setting. (Submitted by: Edwards
Lifesciences)
- (Early public comment)"The condition-specific payment meaures
overlap with the Medicare Spending Per Beneficiary measure that is currently
in HIQR and HVBP; adding segments of MSPB creates unecessary duplication in
the programs. While these payment measures would create alignment with the
physician value-modifier and later MIPS; MACRA requires establishment of
patient relationship categories and codes to attribute patients and episodes
to providers, this significantly change could the way the episode groupers are
implemented and lead to lack of alignment between the hospital and physician
specifications. Accordingly, the measures should not be added to hospital
programs in advance of finalizing the measures for physician programs.
Additionally, we have ongoing concerns about these measures. First, measures
of Federal spending are not real indicators of “value” for beneficiaries as
they neither capture the quality of care, nor are paired with measures that do
so. Moreover, the measures do not give beneficiaries a sense of their
financial obligation so they are not useful for public reporting and
beneficiary engagement purposes. Also, the spending measures are cross-cutting
measures that are not appropriate for evaluating care exclusively in the
inpatient setting. CMS data has previously shown that variation in total
Medicare payments for episodes are primarily due to readmission rates and
post-acute care. Post-acute care use varies due to wide ranging differences in
local market availability of these services and patterns of care, which are
not within the hospital’s control." (Submitted by: Premier)
- (Early public comment)The AMA continues to have several concerns
regarding the clinical episode-based payment measures. First, as we noted
previously, we are concerned that the 90-day look-back period to capture a
patient’s co-morbidities in order to determine the hierarchical condition
categories (HCC) score is insufficient. There is precedent for utilizing a
longer look-back period: the HCC risk adjustment model used for the current
mortality and readmission measures utilizes a one year look-back period.
Second, information on the reliability and validity of this measure is not yet
available. In general, it is difficult to evaluate whether the measure is
appropriate for adoption in light of this lack of information. Data on the
reliability of the measure specifications is needed. In addition and perhaps
more importantly, the validity of these measures must be demonstrated prior to
implementation in any pay-for-performance program. Finally, continuing to
include cost of care measures in the absence of accompanying quality measures
addressing the same clinical condition is contrary to NQF recommendations and
the intent of the value-based programs. Because the proposed measure does not
demonstrate the linkage of expenditures as a result of quality achieved, the
proposed measure will not provide actionable information that a hospital and
physician could use to identify how to make improvements. In summary,
applying this measure in any pay-for-performance program without adequate
review and testing would have significant negative unintended consequences.
Ultimately, the AMA is hopeful that with some refinements, tying costs and
quality to well-defined episodes of care will provide a more fair and accurate
view of physician performance than the measures that CMS is currently using in
the hospital and physician value-based purchasing programs. We do not think
that the measures proposed in this rule have been sufficiently refined;
however, we also are opposed to layering condition-specific measures on top of
the broad total cost measures CMS is now using. The AMA has expressed
frequent objections to CMS’ use of overlapping physician measures that all
pick up the costs of a cohort of chronically ill patients with significant
health care costs that make physicians who treat these patients more likely
than others to face penalties under the value-based modifier. We are concerned
that the new episode measures proposed will intensify similar problems on the
hospital side and could create barriers to care for some patients. The fact
that these measures have not yet been endorsed by NQF and that we do not know
their final form adds to our discomfort. (Submitted by: American Medical
Association)
(Program: Hospital Value-Based
Purchasing Program; MUC ID: MUC15-369) |
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- While SHM supports the concept of assessing costs around specific clinical
conditions, we have concerns about cases in this measure overlapping with
other measures, and therefore penalizing hospitals repeatedly for the same
costs. We believe that condition-specific cost measures may ultimately provide
more useful and actionable information for hospitals and hospitalists, however
use of this measure in a penalty program is not appropriate at this time.
(Submitted by: Society of Hospital Medicine)
- We agree with MAP, this measure overlaps with MSPB and would create
unnecessary duplication in the program. (Submitted by: Premier)
- (Early public comment)Edwards supports inclusion of this
cost/resource use measure in the Hospital Value Based Purchasing program, as
addressing cost of care for an AMI episode aligns with the National Quality
Strategy, addressing a condition that is significant driver of cost for the
Medicare program. Edwards supports efforts to specifically address both the
cost of and quality of care when selecting measures for inclusion in CMS
programs. Reporting this measure with an indicator of quality of care
associated acute myocardial infarction, such as the risk-standardized
mortality and risk-standardized readmission measures that CMS is already
collecting through the Hospital Inpatient Quality Reporting and Hospital
Readmissions Reduction Penalty Programs, will increase understanding of the
value of healthcare services provided, while also illuminating drivers of
cost. Furthermore, by incentivizing hospitals to control costs for the AMI
episode of care, this measure will likely drive improved care during the
admission through utilization of evidence-based practices to enhance recovery,
as well as improved care coordination to decrease readmissions and increase
patient utilization of less costly outpatient care, as the variation in cost
for these episodes is largely driven by variation in post-acute care
utilization post-discharge. (Submitted by: Edwards Lifesciences)
- (Early public comment)"The condition-specific payment meaures
overlap with the Medicare Spending Per Beneficiary measure that is currently
in HIQR and HVBP; adding segments of MSPB creates unecessary duplication in
the programs. While these payment measures would create alignment with the
physician value-modifier and later MIPS; MACRA requires establishment of
patient relationship categories and codes to attribute patients and episodes
to providers, this significantly change could the way the episode groupers are
implemented and lead to lack of alignment between the hospital and physician
specifications. Accordingly, the measures should not be added to hospital
programs in advance of finalizing the measures for physician programs.
Additionally, we have ongoing concerns about these measures. First, measures
of Federal spending are not real indicators of “value” for beneficiaries as
they neither capture the quality of care, nor are paired with measures that do
so. Moreover, the measures do not give beneficiaries a sense of their
financial obligation so they are not useful for public reporting and
beneficiary engagement purposes. Also, the spending measures are cross-cutting
measures that are not appropriate for evaluating care exclusively in the
inpatient setting. CMS data has previously shown that variation in total
Medicare payments for episodes are primarily due to readmission rates and
post-acute care. Post-acute care use varies due to wide ranging differences in
local market availability of these services and patterns of care, which are
not within the hospital’s control." (Submitted by: Premier)
- (Early public comment)The AMA continues to have several concerns
regarding the clinical episode-based payment measures. First, as we noted
previously, we are concerned that the 90-day look-back period to capture a
patient’s co-morbidities in order to determine the hierarchical condition
categories (HCC) score is insufficient. There is precedent for utilizing a
longer look-back period: the HCC risk adjustment model used for the current
mortality and readmission measures utilizes a one year look-back period.
Second, information on the reliability and validity of this measure is not yet
available. In general, it is difficult to evaluate whether the measure is
appropriate for adoption in light of this lack of information. Data on the
reliability of the measure specifications is needed. In addition and perhaps
more importantly, the validity of these measures must be demonstrated prior to
implementation in any pay-for-performance program. Finally, continuing to
include cost of care measures in the absence of accompanying quality measures
addressing the same clinical condition is contrary to NQF recommendations and
the intent of the value-based programs. Because the proposed measure does not
demonstrate the linkage of expenditures as a result of quality achieved, the
proposed measure will not provide actionable information that a hospital and
physician could use to identify how to make improvements. In summary,
applying this measure in any pay-for-performance program without adequate
review and testing would have significant negative unintended consequences.
Ultimately, the AMA is hopeful that with some refinements, tying costs and
quality to well-defined episodes of care will provide a more fair and accurate
view of physician performance than the measures that CMS is currently using in
the hospital and physician value-based purchasing programs. We do not think
that the measures proposed in this rule have been sufficiently refined;
however, we also are opposed to layering condition-specific measures on top of
the broad total cost measures CMS is now using. The AMA has expressed
frequent objections to CMS’ use of overlapping physician measures that all
pick up the costs of a cohort of chronically ill patients with significant
health care costs that make physicians who treat these patients more likely
than others to face penalties under the value-based modifier. We are concerned
that the new episode measures proposed will intensify similar problems on the
hospital side and could create barriers to care for some patients. The fact
that these measures have not yet been endorsed by NQF and that we do not know
their final form adds to our discomfort and suggests that CMS is not
practicing the transparency that it preaches. (Submitted by: American Medical
Association)
(Program: Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-370)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Academy of Ophthalmology strongly supports NQF MAP’s
recommendation of encouraged continued development for this measure. We
support the inclusion of this measure for inclusion in federal quality
reporting programs, including the MIPS measure set. This measure has been
accepted by CMS as a qualified clinical data registry measure available and
currently used for PQRS reporting through the Academy’s QCDR, IRIS Registry.
This is an important outcome measure that measures achievement of
postoperative improved visual acuity, a desired surgical goal that improves
patients’ daily activities of daily living and quality of life. In 2014,
47,530 corneal transplants were performed in the US. This measure evaluates
the outcome of this final-stage option to restore sight and function in these
patients with a dysfunctional cornea resulting in significant visual loss.
(Submitted by: American Academy of Ophthalmology)
- The American Optometric Association (AOA) recommends that the numerator of
MUC15-370 include a test for visual acuity of 20/40 or better at least every
3-6 months for the first 2 years after surgery then every and 6-12 months
after surgery and for a minimum of 5 years. Only through longitudinal
measurement of acuity improvement, can we assess surgical risk to benefit and
fully counsel the patient. (Submitted by: American Optometric Association
)
- (Early public comment)The AMA strongly encourages NQF MAP to
recommend these measures for inclusion in federal quality reporting programs,
including the MIPS measure set. This is an important outcome measure that
measures achievement of postoperative improved visual acuity, a desired
surgical goal that improves patients’ daily activities of daily living and
quality of life. (Submitted by: American Medical Association)
- (Early public comment)The American Academy of Ophthalmology
strongly encourages NQF MAP to recommend these measures for inclusion in
federal quality reporting programs, including the MIPS measure set. This
measure has been accepted by CMS as a qualified clinical data registry measure
available and currently used for PQRS reporting through the Academy’s QCDR,
IRIS Registry. This is an important outcome measure that measures achievement
of postoperative improved visual acuity, a desired surgical goal that improves
patients’ daily activities of daily living and quality of life. In 2014,
47,530 corneal transplants were performed in the US. This measure evaluates
the outcome of this final-stage option to restore sight and function in these
patients with a dysfunctional cornea resulting in significant visual loss.
(Submitted by: American Academy of Ophthalmology)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)The American Optometric Association (AOA)
recommends that the numerator of MUC15-370 include a test for visual acuity of
20/40 or better at least every 6-12 months after surgery and for a minimum of
5 years. Only through longitudinal measurement of acuity improvement, can we
assess surgical risk to benefit and fully counsel the patient. (Submitted by:
American Optometric Association)
(Program: Merit-Based
Incentive Payment System (MIPS); MUC ID: MUC15-372) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Academy of Ophthalmology strongly supports NQF MAP’s
recommendation of encouraged continued development for this measure. We
support the inclusion of this measure for inclusion in federal quality
reporting programs, including the MIPS measure set. We appreciate the comments
in the MAP report regarding this measure’s relation to PQRS Measure 141. The
Academy is evaluating the measure through the IRIS Registry for the next few
years to understand this measure’s applicability in comparison to PQRS #141.
On the one hand, as the MAP has commented, it differentiates the outcome
threshold based on severity of disease and the plan of care is eliminated. On
the other hand, it will depend on complete and accurate disease staging which
will take time for clinicians to incorporate into their daily practice, and
the measure exclusions are in place of the plan of care, but may not be
comprehensive to cover all of the situations that maximal therapy is not
feasible (e.g., patient cannot afford therapy, patient refuses surgery,
patient is not adherent to therapy, etc.). Also, the 15% lowered IOP
threshold is based on evaluation of several randomized controlled trials in
glaucoma care, whereas the IOP thresholds based on severity of disease are in
part, based on consensus, because the severity categories were not in place
when the randomized controlled trials were performed. We will continue to
evaluate the measure in light of these issues and until the evaluation is
complete, we encourage CMS to adopt both as measures in MIPS. This measure
has been accepted by CMS as a qualified clinical data registry measure
available and currently used for PQRS reporting through the Academy’s QCDR,
IRIS Registry. This is an important outcome measure that measures the
reduction in intraocular pressure, the only modifiable risk factor for
glaucoma. This measure has a significant impact on public health. 45 million
people in the world have open-angle glaucoma (OAG), and glaucoma is the second
leading cause of blindness, with approximately 8.4 million people blind from
glaucoma. OAG affects an estimated 2.2 million people in the United States,
and that number is likely to increase to 3.3 million in 2020 as the population
ages. In 2011, 2.71 million persons in the United States had primary
open-angle glaucoma (POAG), and the largest demographic group is non-Hispanic
white women. This measure helps in addressing health disparities because
minority populations have a higher prevalence rate for glaucoma. Overall,
there appears to be a threefold higher prevalence of OAG in African Americans
relative to non-Hispanic Whites in the United States. Recent evidence on
Hispanics/Latinos suggests that they have high prevalence rates of OAG that
are comparable to African Americans. Based on studies in the literature
reviewing documentation of IOP achieved under care, the gap could be as great
as 50% or more in the community of ophthalmologists and optometrists treating
patients with primary open-angle glaucoma. Based on loose criteria for
control, IOP was controlled in 66% of follow-up visits for patients with mild
glaucoma and 52% of visits for patients with moderate to severe glaucoma.
Another study of a single comprehensive insurance plan suggested that a large
proportion of individuals felt to require treatment for glaucoma or suspect
glaucoma are falling out of care and are being monitored at rates lower than
expected from recommendations of published guidelines. (Submitted by: American
Academy of Ophthalmology)
- "Intraocular Pressure (IOP) is not a sole indicator of severity of
glaucoma. To judge severity, additional components are necessary, including
the following: gonioscopy (the use of a goniolens in conjunction with a slit
lamp to gain a view the presence of any peripheral anterior synechiae (PAS)
and the anatomical angle between the eye’s cornea and iris), serial visual
field testing, serial tonometry, optical coherence tomography (noninvasive,
noncontact, transpupillary imaging technology which can image cross-sectional
retinal structures through a technique described by confocal scanning laser
tomography), and corneal pachymetry (the process of measuring the thickness of
the cornea) among other tests, depending on a person’s age and other risk
factors. Therefore, the American Optometric Association (AOA) would support
the measure with the following change to the denominator: Denominator:
Patients aged between 40 and 85 years, with a minimum of 4 office visits
during the prior 24 months, with a diagnosis of glaucoma and with
documentation of the severity of their condition, based on ophthalmoscopy and
or optical coherence tomography, gonioscopy, serial visual field testing and
corneal pachymetry. (Submitted by: American Optometric
Association)
- (Early public comment)The AMA encourages NQF MAP to recommend these
measures for inclusion in federal quality reporting programs, including the
MIPS measure set. This is an important outcome measure that measures the
reduction in intraocular pressure, the only modifiable risk factor for
glaucoma. (Submitted by: American Medical Association)
- (Early public comment)The American Academy of Ophthalmology
strongly encourages NQF MAP to recommend this measure for inclusion in federal
quality reporting programs, including the MIPS measure set. This measure has
been accepted by CMS as a qualified clinical data registry measure available
and currently used for PQRS reporting through the Academy’s QCDR, IRIS
Registry. This is an important outcome measure that measures the reduction in
intraocular pressure, the only modifiable risk factor for glaucoma. This
measure has a significant impact on public health. 45 million people in the
world have open-angle glaucoma (OAG), and glaucoma is the second leading cause
of blindness, with approximately 8.4 million people blind from glaucoma. OAG
affects an estimated 2.2 million people in the United States, and that number
is likely to increase to 3.3 million in 2020 as the population ages. In 2011,
2.71 million persons in the United States had primary open-angle glaucoma
(POAG), and the largest demographic group is non-Hispanic white women. This
measure helps in addressing health disparities because minority populations
have a higher prevalence rate for glaucoma. Overall, there appears to be a
threefold higher prevalence of OAG in African Americans relative to
non-Hispanic Whites in the United States. Recent evidence on Hispanics/Latinos
suggests that they have high prevalence rates of OAG that are comparable to
African Americans. Based on studies in the literature reviewing documentation
of IOP achieved under care, the gap could be as great as 50% or more in the
community of ophthalmologists and optometrists treating patients with primary
open-angle glaucoma. Based on loose criteria for control, IOP was controlled
in 66% of follow-up visits for patients with mild glaucoma and 52% of visits
for patients with moderate to severe glaucoma. Another study of a single
comprehensive insurance plan suggested that a large proportion of individuals
felt to require treatment for glaucoma or suspect glaucoma are falling out of
care and are being monitored at rates lower than expected from recommendations
of published guidelines. (Submitted by: American Academy of
Ophthalmology)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)Intraocular Pressure (IOP) is not a sole
indicator of severity of glaucoma. To judge severity, additional components
are necessary, including the following: gonioscopy (the use of a goniolens in
conjunction with a slit lamp to gain a view the presence of any peripheral
anterior synechiae (PAS) and the anatomical angle between the eye’s cornea
and iris), serial visual field testing, serial tonometry, optical coherence
tomography (noninvasive, noncontact, transpupillary imaging technology which
can image cross-sectional retinal structures through a technique described by
confocal scanning laser tomography), and corneal pachymetry (the process of
measuring the thickness of the cornea) among other tests, depending on a
person’s age and other risk factors. Therefore, the American Optometric
Association (AOA) would support the measure with the following change to the
denominator: Denominator: Patients aged between 40 and 85 years, with a
minimum of 4 office visits during the prior 24 months, with a diagnosis of
glaucoma and with documentation of the severity of their condition, based on
ophthalmoscopy and or optical coherence tomography, gonioscopy, serial visual
field testing and corneal pachymetry. (Submitted by: American Optometric
Association)
(Program: Merit-Based Incentive Payment System
(MIPS); MUC ID: MUC15-374) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Academy of Ophthalmology strongly supports NQF MAP’s
recommendation of encouraged continued development for this measure. We
support the inclusion of this measure for inclusion in federal quality
reporting programs, including the MIPS measure set. The MAP recommendations
state that this measure does not specify a timeframe for measuring IOP after
surgery. We agree that if performed too soon, that the measure may not capture
increased pressure that occurs several months after surgery, potentially
overestimating good outcomes. However, the full measure specification does in
fact describe a time frame for the IOP comparison, which is 2-4 months after
the laser trabeculoplasty procedure. We ask MAP to make this correction in its
report. This measure has been accepted by CMS as a qualified clinical data
registry measure available and currently used for PQRS reporting through the
Academy’s QCDR, IRIS Registry. This is an important outcome measure that
measures reduction in intraocular pressure, the only modifiable risk factor
for glaucoma. Given the public health importance, including the high
prevalence of glaucoma, particularly among minority populations, and the
benefits of achieving the outcome evaluated by the measure, we encourage MAP
to recommend this measure for use. (Submitted by: American Academy of
Ophthalmology)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: American
Optometric Association)
- (Early public comment)The AMA encourages NQF MAP to recommend these
measures for inclusion in federal quality reporting programs, including the
MIPS measure set. This is an important outcome measure that measures reduction
in intraocular pressure, the only modifiable risk factor for glaucoma.
(Submitted by: American Medical Association)
- (Early public comment)The American Academy of Ophthalmology
strongly encourages NQF MAP to recommend this measure for inclusion in federal
quality reporting programs, including the MIPS measure set. This measure has
been accepted by CMS as a qualified clinical data registry measure available
and currently used for PQRS reporting through the Academy’s QCDR, IRIS
Registry. This is an important outcome measure that measures reduction in
intraocular pressure, the only modifiable risk factor for glaucoma. Given the
public health importance, including the high prevalence of glaucoma,
particularly among minority populations, and the benefits of achieving the
outcome evaluated by the measure, we encourage MAP to recommend this measure
for use. (Submitted by: American Academy of Ophthalmology)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)While written comments were not provided, the
commenter indicated their support for this measure in this program. (Submitted
by: American Optometric Association)
(Program: Merit-Based Incentive Payment System
(MIPS); MUC ID: MUC15-375) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Academy of Ophthalmology strongly supports NQF MAP’s
recommendation of encouraged continued development for this measure. We
support the inclusion of this measure for inclusion in federal quality
reporting programs, including the MIPS measure set. We agree with MAP’s
comments that it would be desirable to have a patient-reported outcome measure
related to this condition. However, the Academy notes that for incorporation
in a measure, a patient-reported outcome instrument would need to be
developed, tested and validated, which requires significant time and
resources. When there is a patient-reported outcome instrument relevant for
this condition, we would like to evaluate its use for measuring outcomes.
This measure has been accepted by CMS as a qualified clinical data registry
measure available and currently used for PQRS reporting through the Academy’s
QCDR, IRIS Registry. This is an important outcome measure for acquired
involutional ptosis that measures improved marginal reflex distance, a desired
goal to improve patient clinical and functional outcomes. Studies in the
United States on the prevalence of ptosis are lacking, but one study looking
at individuals 50 years of age and older in England discovered that 11.5% had
ptosis and that the prevalence increased with age. Patients with ptosis may
have blurred vision, and may need to lift an eyelid with a finger, or tilt
their head backwards in order to see. This measure evaluates the achievement
of a desired outcome that would improve a patient’s ability to see. (Submitted
by: American Academy of Ophthalmology)
- The American Optometric Association (AOA) recommends that the numerator of
MUC15-375 includes presence of corneal exposure keratitis due to poor lid
closure. Patients must understand the benefits versus harms before choosing
elective surgery and for cost/benefit ratios. This measure will allow us to
quantify these factors. (Submitted by: American Optometric Association
)
- (Early public comment)The AMA encourages NQF MAP to recommend these
measures for inclusion in the MIPS measure set. This is an important outcome
measure for acquired involutional ptosis that measures improved marginal
reflex distance, a desired goal to improve patient clinical and functional
outcomes. (Submitted by: American Medical Association)
- (Early public comment)ASPS is pleased to see meaningful and
relevant measures for plastic surgeons in the MIPS program. Going forward,
ASPS wishes to continue to see more relevant measures for specialties and
surgical specialties. (Submitted by: American Society of Plastic
Surgeons)
- (Early public comment)The American Academy of Ophthalmology
strongly encourages NQF MAP to recommend this measure for inclusion in federal
quality reporting programs, including the MIPS measure set. This measure has
been accepted by CMS as a qualified clinical data registry measure available
and currently used for PQRS reporting through the Academy’s QCDR, IRIS
Registry. This is an important outcome measure for acquired involutional
ptosis that measures improved marginal reflex distance, a desired goal to
improve patient clinical and functional outcomes. Studies in the United States
on the prevalence of ptosis are lacking, but one study looking at individuals
50 years of age and older in England discovered that 11.5% had ptosis and that
the prevalence increased with age. Patients with ptosis may have blurred
vision, and may need to lift an eyelid with a finger, or tilt their head
backwards in order to see. This measure evaluates the achievement of a desired
outcome that would improve a patient’s ability to see. (Submitted by: American
Academy of Ophthalmology)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)The American Optometric Association (AOA)
recommends that the numerator of MUC15-375 includes presence of corneal
exposure keratitis due to poor lid closure. Patients must understand the
benefits versus harms before choosing elective surgery and for cost/benefit
ratios. This measure will allow us to quantify these factors. (Submitted by:
American Optometric Assocation)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-377)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Academy of Ophthalmology strongly supports NQF MAP’s
recommendation of encouraged continued development for this measure. We
support the inclusion of this measure for inclusion in federal quality
reporting programs, including the MIPS measure set. We agree with MAP’s
comments that it would be desirable to have a patient-reported outcome measure
related to this condition. However, the Academy notes that for incorporation
in a measure, a patient-reported outcome instrument would need to be
developed, tested and validated, which requires significant time and
resources. When there is a patient-reported outcome instrument relevant for
this condition, we would like to evaluate its use for measuring outcomes.
This measure has been accepted by CMS as a qualified clinical data registry
measure available and currently used for PQRS reporting through the Academy’s
QCDR, IRIS Registry. This is an important outcome measure for acquired
involutional entropion that measures normalized lid position, a desired goal
to improve clinical and functional outcomes for the patient. In a study of
nearly 25,000 individuals over 60 years old, involutional entropion was found
in 2.1% of patients. Prevalence increased with age: 0.9% for patient 60-69
years old, 2.1% for 70-79, and 7.6% for those over 80. Bilateral disease is
three times more common than unilateral. Entropion is more common in women,
with prevalence 2.4%, than men, prevalence 1.9%. Involutional entropion has a
prevalence of 2.4% in whites and 0.8% in blacks. Patients with involutional
entropion are often elderly and have significant comorbidities. The 4-year
mortality for patients with involutional entropion is 30%. Patients with
ptosis may have blurred vision, and may need to lift an eyelid with a finger,
or tilt their head backwards in order to see. This measure evaluates the
achievement of a desired outcome that would improve a patient’s ability to
see. (Submitted by: American Academy of Ophthalmology)
- Age related macular degeneration deprives our older population of not only
sight, but independence and quality of life. Many of these patients have to
limit or forgo driving, and many of the vocations of which they were
accustomed. Measuring Visual Acuity in this population is critical to
understand treatment modalities and their success or lack of for this disease.
(Submitted by: American Optometric Association)
- The American Optometric Association would support this measure if it the
numerator included reporting of post-operative presence of corneal exposure
keratitis due to poor lid closure. Patients must understand the benefits
versus harms before choosing elective surgery and for cost/benefit ratios.
This measure will allow us to quantify these factors. (Submitted by: American
Optometric Association)
- (Early public comment)The AMA encourages NQF MAP to recommend
inclusion in the MIPS measure set. This is an important outcome measure for
acquired involutional entropian that measures normalized lid position, a
desired goal to improve clinical and functional outcomes for the patient.
(Submitted by: American Medical Association)
- (Early public comment)ASPS is pleased to see meaningful and
relevant measures for plastic surgeons in the MIPS program. Going forward,
ASPS wishes to continue to see more relevant measures for specialties and
surgical specialties. (Submitted by: American Society of Plastic
Surgeons)
- (Early public comment)The American Academy of Ophthalmology
strongly encourages NQF MAP to recommend this measure for inclusion in federal
quality reporting programs, including the MIPS measure set. This measure has
been accepted by CMS as a qualified clinical data registry measure available
and currently used for PQRS reporting through the Academy’s QCDR, IRIS
Registry. This is an important outcome measure for acquired involutional
entropion that measures normalized lid position, a desired goal to improve
clinical and functional outcomes for the patient. In a study of nearly 25,000
individuals over 60 years old, involutional entropion was found in 2.1% of
patients. Prevalence increased with age: 0.9% for patient 60-69 years old,
2.1% for 70-79, and 7.6% for those over 80. Bilateral disease is three times
more common than unilateral. Entropion is more common in women, with
prevalence 2.4%, than men, prevalence 1.9%. Involutional entropion has a
prevalence of 2.4% in whites and 0.8% in blacks. Patients with involutional
entropion are often elderly and have significant comorbidities. The 4-year
mortality for patients with involutional entropion is 30%. Patients with
ptosis may have blurred vision, and may need to lift an eyelid with a finger,
or tilt their head backwards in order to see. This measure evaluates the
achievement of a desired outcome that would improve a patient’s ability to
see. (Submitted by: American Academy of Ophthalmology)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)The American Optometric Association would
support this measure if it the numerator included reporting of post-operative
presence of corneal exposure keratitis due to poor lid closure. Patients must
understand the benefits versus harms before choosing elective surgery and for
cost/benefit ratios. This measure will allow us to quantify these factors.
(Submitted by: American Optometric Association )
(Program: Hospital Inpatient Quality Reporting and EHR
Incentive Program; MUC ID: MUC15-378) |
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- The measure should clearly specify for which age group it is targeting AND
in which it has been tested. If the measure is intended for across payer and
age use, it must be tested for validity in these populations. (Submitted by:
Children's Hospital Association)
- The methodology behind this measure is unclear, including the risk model
for sociodemographic status (SDS). We support the MAP's recommendation with
the following conditions: 1) provide clarification or further study on the
observed-to-expected ratio of infection; 2) pneumonia is difficult to
diagnose. We recommend further consideration of how the diagnosis can be made
and include in specifications; 3) the measure's cohort was expanded and
therefore this measure should be reviewed by a multi-stakeholder group once
testing data for the new cohort is available; 4) provide additional
information on methodology to account for SDS factors. (Submitted by:
American College of Surgeons)
- While SHM supports the concept of assessing costs around specific clinical
conditions, we have concerns about cases in this measure overlapping with
other measures, and therefore penalizing hospitals repeatedly for the same
costs. We believe that condition-specific cost measures may ultimately provide
more useful and actionable information for hospitals and hospitalists, use of
this measure in a penalty program is not appropriate at this time. However,
given their similarities, it is not clear why the MAP assessed this measure
differently from the other two payment measures (MUC15-322 HF and MUC15-369
AMI). SHM also has further questions about the exclusion criteria and why this
pneumonia measure differs from the HF and AMI measures (MUC15-322 and
MUC15-369, respectively). If the intent with the exclusion of patients with a
hospitalization in the prior 30 days is to exclude healthcare-associated
pneumonia (HCAP), why does the exclusion not match HCAP criteria? If the
exclusion is for another reason, why is this not mirrored in the HF and AMI
measures? We recommend this discrepancy be addressed prior to implementing
this measure. (Submitted by: Society of Hospital Medicine)
- "The condition-specific payment meaures overlap with the Medicare Spending
Per Beneficiary measure that is currently in HIQR and HVBP; adding segments of
MSPB creates unecessary duplication in the programs. While these payment
measures would create alignment with the physician value-modifier and later
MIPS; MACRA requires establishment of patient relationship categories and
codes to attribute patients and episodes to providers, this significantly
change could the way the episode groupers are implemented and lead to lack of
alignment between the hospital and physician specifications. Accordingly, the
measures should not be added to hospital programs in advance of finalizing the
measures for physician programs. Additionally, we have ongoing concerns about
these measures. First, measures of Federal spending are not real indicators of
“value” for beneficiaries as they neither capture the quality of care, nor are
paired with measures that do so. Moreover, the measures do not give
beneficiaries a sense of their financial obligation so they are not useful for
public reporting and beneficiary engagement purposes. Also, the spending
measures are cross-cutting measures that are not appropriate for evaluating
care exclusively in the inpatient setting. CMS data has previously shown that
variation in total Medicare payments for episodes are primarily due to
readmission rates and post-acute care. Post-acute care use varies due to wide
ranging differences in local market availability of these services and
patterns of care, which are not within the hospital’s control." (Submitted by:
Premier)
- (Early public comment)"The condition-specific payment meaures
overlap with the Medicare Spending Per Beneficiary measure that is currently
in HIQR and HVBP; adding segments of MSPB creates unecessary duplication in
the programs. While these payment measures would create alignment with the
physician value-modifier and later MIPS; MACRA requires establishment of
patient relationship categories and codes to attribute patients and episodes
to providers, this significantly change could the way the episode groupers are
implemented and lead to lack of alignment between the hospital and physician
specifications. Accordingly, the measures should not be added to hospital
programs in advance of finalizing the measures for physician programs.
Additionally, we have ongoing concerns about these measures. First, measures
of Federal spending are not real indicators of “value” for beneficiaries as
they neither capture the quality of care, nor are paired with measures that do
so. Moreover, the measures do not give beneficiaries a sense of their
financial obligation so they are not useful for public reporting and
beneficiary engagement purposes. Also, the spending measures are cross-cutting
measures that are not appropriate for evaluating care exclusively in the
inpatient setting. CMS data has previously shown that variation in total
Medicare payments for episodes are primarily due to readmission rates and
post-acute care. Post-acute care use varies due to wide ranging differences in
local market availability of these services and patterns of care, which are
not within the hospital’s control." (Submitted by: Premier)
- (Early public comment)The AMA continues to have several concerns
regarding the clinical episode-based payment measures. First, as we noted
previously, we are concerned that the 90-day look-back period to capture a
patient’s co-morbidities in order to determine the hierarchical condition
categories (HCC) score is insufficient. There is precedent for utilizing a
longer look-back period: the HCC risk adjustment model used for the current
mortality and readmission measures utilizes a one year look-back period.
Second, information on the reliability and validity of this measure is not yet
available. In general, it is difficult to evaluate whether the measure is
appropriate for adoption in light of this lack of information. Data on the
reliability of the measure specifications is needed. In addition and perhaps
more importantly, the validity of these measures must be demonstrated prior to
implementation in any pay-for-performance program. Finally, continuing to
include cost of care measures in the absence of accompanying quality measures
addressing the same clinical condition is contrary to NQF recommendations and
the intent of the value-based programs. Because the proposed measure does not
demonstrate the linkage of expenditures as a result of quality achieved, the
proposed measure will not provide actionable information that a hospital and
physician could use to identify how to make improvements. In summary,
applying this measure in any pay-for-performance program without adequate
review and testing would have significant negative unintended consequences.
(Submitted by: American Medical Association)
- (Early public comment)The AMA continues to have several concerns
regarding the clinical episode-based payment measures. First, as we noted
previously, we are concerned that the 90-day look-back period to capture a
patient’s co-morbidities in order to determine the hierarchical condition
categories (HCC) score is insufficient. There is precedent for utilizing a
longer look-back period: the HCC risk adjustment model used for the current
mortality and readmission measures utilizes a one year look-back period.
Second, information on the reliability and validity of this measure is not yet
available. In general, it is difficult to evaluate whether the measure is
appropriate for adoption in light of this lack of information. Data on the
reliability of the measure specifications is needed. In addition and perhaps
more importantly, the validity of these measures must be demonstrated prior to
implementation in any pay-for-performance program. Finally, continuing to
include cost of care measures in the absence of accompanying quality measures
addressing the same clinical condition is contrary to NQF recommendations and
the intent of the value-based programs. Because the proposed measure does not
demonstrate the linkage of expenditures as a result of quality achieved, the
proposed measure will not provide actionable information that a hospital and
physician could use to identify how to make improvements. In summary,
applying this measure in any pay-for-performance program without adequate
review and testing would have significant negative unintended consequences.
Ultimately, the AMA is hopeful that with some refinements, tying costs and
quality to well-defined episodes of care will provide a more fair and accurate
view of physician performance than the measures that CMS is currently using in
the hospital and physician value-based purchasing programs. We do not think
that the measures proposed in this rule have been sufficiently refined;
however, we also are opposed to layering condition-specific measures on top of
the broad total cost measures CMS is now using. The AMA has expressed
frequent objections to CMS’ use of overlapping physician measures that all
pick up the costs of a cohort of chronically ill patients with significant
health care costs that make physicians who treat these patients more likely
than others to face penalties under the value-based modifier. We are concerned
that the new episode measures proposed will intensify similar problems on the
hospital side and could create barriers to care for some patients. The fact
that these measures have not yet been endorsed by NQF and that we do not know
their final form adds to our discomfort and suggests that CMS is not
practicing the transparency that it preaches. (Submitted by: American Medical
Association)
(Program: Hospital Value-Based Purchasing Program; MUC
ID: MUC15-378) |
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- ACS agrees with the MAP's recommendation to do not support this measure
because it should first be placed in IQR and Hospital Compare for one year
prior to considering it for implementation into HVBP. (Submitted by: American
College of Surgeons)
- We agree with MAP, this measure overlaps with MSPB and would create
unnecessary duplication in the program. (Submitted by: Premier)
- (Early public comment)Edwards supports inclusion of this
cost/resource use measure in the Hospital Value Based Purchasing program and
the Hospital Inpatient Quality Reporting program. Edwards supports efforts to
specifically address both the cost of and quality of care when selecting
measures for inclusion in CMS programs. Reporting this measure with an
indicator of quality of care associated with pneumonia, such as the
risk-standardized mortality and risk-standardized readmission measures that
CMS is already collecting through the Hospital Inpatient Quality Reporting and
Hospital Readmissions Reduction Penalty Programs, will increase understanding
of the value of healthcare services provided, while also illuminating drivers
of cost. Collecting information on all three of these measures will ensure
that the full spectrum of care during the admission and care coordination
post-discharge can be assessed while simultaneously ensuring CMS can monitor
for unintended consequences of measurement. Furthermore, by incentivizing
hospitals to control costs for the pneumonia episode of care, this measure
will likely drive improved care during the admission through utilization of
evidence-based practices to enhance recovery, as well as improved care
coordination to decrease readmissions and increase patient utilization of less
costly outpatient care. (Submitted by: Edwards Lifesciences)
- (Early public comment)"The condition-specific payment meaures
overlap with the Medicare Spending Per Beneficiary measure that is currently
in HIQR and HVBP; adding segments of MSPB creates unecessary duplication in
the programs. While these payment measures would create alignment with the
physician value-modifier and later MIPS; MACRA requires establishment of
patient relationship categories and codes to attribute patients and episodes
to providers, this significantly change could the way the episode groupers are
implemented and lead to lack of alignment between the hospital and physician
specifications. Accordingly, the measures should not be added to hospital
programs in advance of finalizing the measures for physician programs.
Additionally, we have ongoing concerns about these measures. First, measures
of Federal spending are not real indicators of “value” for beneficiaries as
they neither capture the quality of care, nor are paired with measures that do
so. Moreover, the measures do not give beneficiaries a sense of their
financial obligation so they are not useful for public reporting and
beneficiary engagement purposes. Also, the spending measures are cross-cutting
measures that are not appropriate for evaluating care exclusively in the
inpatient setting. CMS data has previously shown that variation in total
Medicare payments for episodes are primarily due to readmission rates and
post-acute care. Post-acute care use varies due to wide ranging differences in
local market availability of these services and patterns of care, which are
not within the hospital’s control." (Submitted by: Premier)
- (Early public comment)The AMA continues to have several concerns
regarding the clinical episode-based payment measures. Information on the
reliability and validity of this measure is not yet available. In general, it
is difficult to evaluate whether the measure is appropriate for adoption in
light of this lack of information. Data on the reliability of the measure
specifications is needed. In addition and perhaps more importantly, the
validity of these measures must be demonstrated prior to implementation in any
pay-for-performance program. Finally, continuing to include cost of care
measures in the absence of accompanying quality measures addressing the same
clinical condition is contrary to NQF recommendations and the intent of the
value-based programs. Because the proposed measure does not demonstrate the
linkage of expenditures as a result of quality achieved, the proposed measure
will not provide actionable information that a hospital and physician could
use to identify how to make improvements. In summary, applying this measure
in any pay-for-performance program without adequate review and testing would
have significant negative unintended consequences. Ultimately, the AMA is
hopeful that with some refinements, tying costs and quality to well-defined
episodes of care will provide a more fair and accurate view of physician
performance than the measures that CMS is currently using in the hospital and
physician value-based purchasing programs. We do not think that the measures
proposed in this rule have been sufficiently refined; however, we also are
opposed to layering condition-specific measures on top of the broad total cost
measures CMS is now using. The AMA has expressed frequent objections to CMS’
use of overlapping physician measures that all pick up the costs of a cohort
of chronically ill patients with significant health care costs that make
physicians who treat these patients more likely than others to face penalties
under the value-based modifier. We are concerned that the new episode measures
proposed will intensify similar problems on the hospital side and could create
barriers to care for some patients. The fact that these measures have not yet
been endorsed by NQF and that we do not know their final form adds to our
discomfort and suggests that CMS is not practicing the transparency that it
preaches. Ultimately, the AMA is hopeful that with some refinements, tying
costs and quality to well-defined episodes of care will provide a more fair
and accurate view of physician performance than the measures that CMS is
currently using in the hospital and physician value-based purchasing programs.
We do not think that the measures proposed in this rule have been sufficiently
refined; however, we also are opposed to layering condition-specific measures
on top of the broad total cost measures CMS is now using. The AMA has
expressed frequent objections to CMS’ use of overlapping physician measures
that all pick up the costs of a cohort of chronically ill patients with
significant health care costs that make physicians who treat these patients
more likely than others to face penalties under the value-based modifier. We
are concerned that the new episode measures proposed will intensify similar
problems on the hospital side and could create barriers to care for some
patients. The fact that these measures have not yet been endorsed by NQF and
that we do not know their final form adds to our discomfort. (Submitted by:
American Medical Association)
(Program: Merit-Based
Incentive Payment System (MIPS); MUC ID: MUC15-379) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Academy of Ophthalmology strongly supports NQF MAP’s
recommendation of encouraged continued development for this measure. We
support the inclusion of this measure for inclusion in federal quality
reporting programs, including the MIPS measure set. This measure has been
accepted by CMS as a qualified clinical data registry measure available and
currently used for PQRS reporting through the Academy’s QCDR, IRIS Registry.
This is an important outcome measure that measures maintenance of visual
acuity, a desired treatment goal for exudative age-related macular
degeneration to continue the level of the patient's daily activities of daily
living and quality of life. In addition, this measure is greatly important to
public health. Approximately 1.75 million people age 40 years or older in the
United States have neovascular AMD or geographic atrophy and 7.3 million have
large drusen (=125 microns) in one or both eyes. AMD causes approximately 46
percent of cases of severe visual loss (visual acuity 20/200 or worse) in
Americans older than 40 years old. AMD is among the top 25 disease conditions
in cost for Medicare. AMD is a leading cause of blindness and visual
impairment in the Medicare population. In the US, a total of 8 million
individuals at least 55 years old have monocular or binocular intermediate AMD
or monocular advanced AMD, and are at risk for developing advanced AMD. Of
this high risk group, it is estimated that 1,315,000 individuals would develop
advanced AMD within 5 years. AMD causes 46 percent of cases of severe visual
loss (visual acuity 20/200 or worse) in Americans older than 40 years.
(Submitted by: American Academy of Ophthalmology)
- Age related macular degeneration deprives our older population of not only
sight, but independence and quality of life. Many of these patients have to
limit or forgo driving, and many of the vocations of which they were
accustomed. Measuring Visual Acuity in this population is critical to
understand treatment modalities and their success or lack of for this disease.
(Submitted by: American Optometric Association )
- (Early public comment)We encourage NQF MAP to recommend these
measures for inclusion in the MIPS measure set. This is an important outcome
measure that measures maintenance of visual acuity, a desired treatment goal
for exudative age-related macular degeneration to continue the level of the
patient's daily activities of daily living and quality of life. (Submitted by:
American Medical Association)
- (Early public comment)The American Academy of Ophthalmology
strongly encourages NQF MAP to recommend this measure for inclusion in federal
quality reporting programs, including the MIPS measure set. This measure has
been accepted by CMS as a qualified clinical data registry measure available
and currently used for PQRS reporting through the Academy’s QCDR, IRIS
Registry. This is an important outcome measure that measures maintenance of
visual acuity, a desired treatment goal for exudative age-related macular
degeneration to continue the level of the patient's daily activities of daily
living and quality of life. In addition, this measure is greatly important to
public health. Approximately 1.75 million people age 40 years or older in the
United States have neovascular AMD or geographic atrophy and 7.3 million have
large drusen (=125 microns) in one or both eyes. AMD causes approximately 46
percent of cases of severe visual loss (visual acuity 20/200 or worse) in
Americans older than 40 years old. AMD is among the top 25 disease conditions
in cost for Medicare. AMD is a leading cause of blindness and visual
impairment in the Medicare population. In the US, a total of 8 million
individuals at least 55 years old have monocular or binocular intermediate AMD
or monocular advanced AMD, and are at risk for developing advanced AMD. Of
this high risk group, it is estimated that 1,315,000 individuals would develop
advanced AMD within 5 years. AMD causes 46 percent of cases of severe visual
loss (visual acuity 20/200 or worse) in Americans older than 40 years.
(Submitted by: American Academy of Ophthalmology)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)Age related macular degeneration deprives our
older population of not only sight, but independence and quality of life. Many
of these patients have to limit or forgo driving, and many of the vocations of
which they were accustomed. Measuring Visual Acuity in this population is
critical to understand treatment modalities and their success or lack of for
this disease. (Submitted by: American Optometric Association)
(Program: Hospital
Inpatient Quality Reporting and EHR Incentive Program; MUC ID: MUC15-391)
|
- We do not support attributing this measure to hospitals at this time. High
or improved performance requires inpatient and outpatient interventions. Until
more is known about the role of the community, outpatient care, and hospitals
in their ability to impact performance, it should not be used for hospital
accountability purposes. Further, more needs to be known about how SDS impacts
performance, and how these factors do or do not affect valid attribution to
hospitals for accountability (Submitted by: Children's Hospital
Association)
- GNYHA agrees with MAP’s concerns about inclusion of this measure in the
Hospital Inpatient Quality Reporting Program and that the measure should take
into consideration socio-demographic factors that examine the true hospital
versus community role in readmissions. Lastly, GNYHA cautions CMS from using
multiple and redundant pneumonia readmission measures across its programs.
(Submitted by: Greater New York Hospital Association)
- The methodology behind this measure is unclear, including the risk model
for sociodemographic status (SDS). We recommend the following: 1) Provide
clarification or further study on the observed-to-expected ratio of infection;
2) Pneumonia is difficult to diagnose. We recommend further consideration of
how the diagnosis can be made and include in specifications; 3) The measure
assesses the average number of days a hospital's patients spend in an ED,
observation, or readmission and the number of days in acute care they would
have been expected to spend if discharged from an average hospital. However,
ACS believes that it is important to capture all of these events separately
(ED, observation and readmission) instead of combining them to represent one
number of days; 4) Provide additional information on methodology to account
for SDS factors. (Submitted by: American College of Surgeons)
- FAH opposes the inclusion of this measure in HIQR. We have concerns with
the measure construction and its intent. Specifically, why observations are
included in this measure is unclear and we question the utility of a measure
that broadly defines acute care. Regarding the intent of the measure, CMS has
not adequately explained how this measure relates to the current pneumonia
readmission measures. In many instances, the two measures could penalize a
hospital for the same occurrence twice. This duplication between the measures
must be addressed prior to implementation and a general rationale of the value
of this measure in addition to the current readmission measures should be
provided. (Submitted by: Federation of American Hospitals)
- While SHM agrees with the concept of this measure as a method of measuring
all hospital-based care required by patients after a hospitalization, we see
this as an expansion of existing readmission measures. We believe cases in the
measure overlap significantly with cases in other measures currently in use
and, as such, may be viewed as penalizing providers for the same patients and
cases. SHM also has concerns about the methodology for rounding up observation
time to the nearest half-day as biasing performance towards excessive days. We
recommend considering a methodology with more precision or to round up and
down when counting observation time, using standard rounding conventions.
(Submitted by: Society of Hospital Medicine)
- The measure combines readmissions, observation stays and ED visits into a
single number of days; each of these episodes reflect widely different
approaches to patient-centered care and cannot be interpreted from a single
number. While CMS aims to reduce the number of observation days, the fact is
that payment policies such as the Two Midnight rule and measures such as MSPB
drive care to the least restrictive and costly care setting (often being
observation status). Moreover, given that readmissions are already captured in
their own set of measures in addition to MSPB, it is not clear why the length
of stay for the readmission is of import. (Submitted by: Premier)
- (Early public comment)The measure combines readmissions,
observation stays and ED visits into a single number of days; each of these
episodes reflect widely different approaches to patient-centered care and
cannot be interpreted from a single number. While CMS aims to reduce the
number of observation days, the fact is that payment policies such as the Two
Midnight rule and measures such as MSPB drive care to the least restrictive
and costly care setting (often being observation status). Moreover, given that
readmissions are already captured in their own set of measures in addition to
MSPB, it is not clear why the length of stay for the readmission is of import.
(Submitted by: Premier)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-392)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Academy of Ophthalmology strongly supports NQF MAP’s
recommendation of encouraged continued development for this measure. We
support the inclusion of this measure for inclusion in federal quality
reporting programs, including the MIPS measure set. The MAP recommendations
state that it is unclear whether the degree of vision change quantified in
this measure will reflect the natural slow progression of the disease or the
impact of optimal treatment to slow down disease progression. We appreciate
the comment and note that we will be evaluating over time the progression of
visual acuity of patients with nonexudative age-related macular degeneration
in the IRIS Registry. Although the disease may progress slowly, the visual
acuity has been seen to change in longitudinal studies. In the randomized
controlled trial Age-Related Eye Disease Study, visual acuity loss was not
uncommon during the 5-year follow up period. (The Age-Related Eye Disease
Study 2 (AREDS2) Research Group. Secondary Analyses of the Effects of
Lutein/Zeaxanthin in Age-Related Macular Degeneration Progression AREDS2
Report No. 3, JAMA Ophthalmol; 2014; 132:142-9.) This measure has been
accepted by CMS as a qualified clinical data registry measure available and
currently used for PQRS reporting through the Academy’s QCDR, IRIS Registry.
This is an important outcome measure for nonexudative age-related macular
degeneration that measures maintenance of visual acuity, a desired treatment
goal to continue the level of the patient's daily activities of daily living
and quality of life. In addition, this measure is greatly important to public
health. Approximately 1.75 million people age 40 years or older in the United
States have neovascular AMD or geographic atrophy and 7.3 million have large
drusen (=125 microns) in one or both eyes. AMD causes approximately 46
percent of cases of severe visual loss (visual acuity 20/200 or worse) in
Americans older than 40 years old. AMD is among the top 25 disease conditions
in cost for Medicare. AMD is a leading cause of blindness and visual
impairment in the Medicare population. In the US, a total of 8 million
individuals at least 55 years old have monocular or binocular intermediate AMD
or monocular advanced AMD, and are at risk for developing advanced AMD. Of
this high risk group, it is estimated that 1,315,000 individuals would develop
advanced AMD within 5 years. AMD causes 46 percent of cases of severe visual
loss (visual acuity 20/200 or worse) in Americans older than 40 years. Three
randomized clinical trials (ANCHOR , MARINA , and PIER ) demonstrated that
with effective anti-VEGF treatment at the appropriate stage of disease, 90-96%
of patients lost less than 15 letters of visual acuity, and 33 – 40% of
patients gained more than 15 letters of visual acuity. Based on this
scientific evidence, timely and effective treatment can be provided to
patients who are staged accurately, thus avoiding the blindness and visual
impairment associated with the natural progression of disease. No data exists
on the identification and documentation of the severity of macular
degeneration and presence or absence of macular thickening but parallel data
for key structural assessments for glaucoma and cataract and diabetic
retinopathy suggest that significant gaps are likely. (Submitted by: American
Academy of Ophthalmology)
- Age related macular degeneration deprives our older population of not only
sight, but independence and quality of life. Many of these patients have to
limit or forgo driving, and many of the vocations of which they were
accustomed. Measuring Visual Acuity in this population is critical to
understand treatment modalities and their success or lack of for this disease.
(Submitted by: American Optometric Association)
- (Early public comment)We encourage NQF MAP to recommend these
measures for inclusion in the MIPS measure set. This is an important outcome
measure for nonexudative age-related macular degeneration that measures
maintenance of visual acuity, a desired treatment goal to continue the level
of the patient's daily activities of daily living and quality of life.
(Submitted by: American Medical Association)
- (Early public comment)The American Academy of Ophthalmology
strongly encourages NQF MAP to recommend this measure for inclusion in federal
quality reporting programs, including the MIPS measure set. This measure has
been accepted by CMS as a qualified clinical data registry measure available
and currently used for PQRS reporting through the Academy’s QCDR, IRIS
Registry. This is an important outcome measure for nonexudative age-related
macular degeneration that measures maintenance of visual acuity, a desired
treatment goal to continue the level of the patient's daily activities of
daily living and quality of life. In addition, this measure is greatly
important to public health. Approximately 1.75 million people age 40 years or
older in the United States have neovascular AMD or geographic atrophy and 7.3
million have large drusen (=125 microns) in one or both eyes. AMD causes
approximately 46 percent of cases of severe visual loss (visual acuity 20/200
or worse) in Americans older than 40 years old. AMD is among the top 25
disease conditions in cost for Medicare. AMD is a leading cause of blindness
and visual impairment in the Medicare population. In the US, a total of 8
million individuals at least 55 years old have monocular or binocular
intermediate AMD or monocular advanced AMD, and are at risk for developing
advanced AMD. Of this high risk group, it is estimated that 1,315,000
individuals would develop advanced AMD within 5 years. AMD causes 46 percent
of cases of severe visual loss (visual acuity 20/200 or worse) in Americans
older than 40 years. Three randomized clinical trials (ANCHOR , MARINA , and
PIER ) demonstrated that with effective anti-VEGF treatment at the appropriate
stage of disease, 90-96% of patients lost less than 15 letters of visual
acuity, and 33 – 40% of patients gained more than 15 letters of visual acuity.
Based on this scientific evidence, timely and effective treatment can be
provided to patients who are staged accurately, thus avoiding the blindness
and visual impairment associated with the natural progression of disease. No
data exists on the identification and documentation of the severity of macular
degeneration and presence or absence of macular thickening but parallel data
for key structural assessments for glaucoma and cataract and diabetic
retinopathy suggest that significant gaps are likely. (Submitted by:
American Academy of Ophthalmology)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)Age related macular degeneration deprives our
older population of not only sight, but independence and quality of life. Many
of these patients have to limit or forgo driving, and many of the vocations of
which they were accustomed. Measuring Visual Acuity in this population is
critical to understand treatment modalities and their success or lack of for
this disease. (Submitted by: American Optometric Association)
(Program: Merit-Based Incentive
Payment System (MIPS); MUC ID: MUC15-393) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Academy of Ophthalmology strongly supports NQF MAP’s
recommendation of encouraged continued development for this measure. We
support the inclusion of this measure for inclusion in federal quality
reporting programs, including the MIPS measure set. This measure has been
accepted by CMS as a qualified clinical data registry measure available and
currently used for PQRS reporting through the Academy’s QCDR, IRIS Registry.
This is an important outcome measure for diabetic macular edema that measures
maintenance of visual acuity, a desired treatment goal to continue the level
of the patient's daily activities of daily living and quality of life. The
public health impact of this measure is significant and will increase with the
aging of the population. In 2005–2008, 4.2 million people with diabetes aged
40 years or older had diabetic retinopathy. The numbers of affected patients
will rise dramatically, with the number tripling in 2050 to 16.0 million with
diabetic retinopathy, and 3.4 million with vision threatening diabetic
retinopathy. The elderly population will have the greatest increases in the
numbers with diabetes-related eye disease. The natural progression of diabetic
retinopathy is to advance with age and severity of diabetes mellitus resulting
in visual impairment and blindness. Diabetic macular edema, a manifestation of
diabetic retinopathy, is the most frequent cause of blindness in young and
mid-aged adults. Several level 1 randomized controlled trials studies
demonstrate the ability of timely treatment to reduce the rate and severity of
vision loss from diabetes (–DRS and ETDRS). Treatment of diabetic macular
edema, a common cause of visual impairment, has been significantly enhanced
with the introduction of anti- VEGF. The Diabetic Retinopathy Clinical
Research Network study found that the mean change in visual acuity was
significantly greater in patients receiving ranibizumab plus prompt/deferred
laser surgery (+9 letters) compared to treatments without anti-VEGF agents.
(Submitted by: American Academy of Ophthalmology)
- 0.3 logmar is equivalent to 20/40 Snellen which is the widely used
indicator. The American Optometric Association would support this measure if
it the numerator read: Percentage of patients with a diagnosis of diabetic
macular edema with vision =20 /40 within the past 12 months (Submitted by:
American Optometric Association)
- (Early public comment)We encourage NQF MAP to recommend these
measures for inclusion in the MIPS measure set. This is an important outcome
measure for diabetic macular edema that measures maintenance of visual acuity,
a desired treatment goal to continue the level of the patient's daily
activities of daily living and quality of life. (Submitted by: American
Medical Association)
- (Early public comment)The American Academy of Ophthalmology
strongly encourages NQF MAP to recommend this measure for inclusion in federal
quality reporting programs, including the MIPS measure set. This measure has
been accepted by CMS as a qualified clinical data registry measure available
and currently used for PQRS reporting through the Academy’s QCDR, IRIS
Registry. This is an important outcome measure for diabetic macular edema that
measures maintenance of visual acuity, a desired treatment goal to continue
the level of the patient's daily activities of daily living and quality of
life. The public health impact of this measure is significant and will
increase with the aging of the population. In 2005–2008, 4.2 million people
with diabetes aged 40 years or older had diabetic retinopathy. The numbers of
affected patients will rise dramatically, with the number tripling in 2050 to
16.0 million with diabetic retinopathy, and 3.4 million with vision
threatening diabetic retinopathy. The elderly population will have the
greatest increases in the numbers with diabetes-related eye disease. The
natural progression of diabetic retinopathy is to advance with age and
severity of diabetes mellitus resulting in visual impairment and blindness.
Diabetic macular edema, a manifestation of diabetic retinopathy, is the most
frequent cause of blindness in young and mid-aged adults. Several level 1
randomized controlled trials studies demonstrate the ability of timely
treatment to reduce the rate and severity of vision loss from diabetes (–DRS
and ETDRS). Treatment of diabetic macular edema, a common cause of visual
impairment, has been significantly enhanced with the introduction of anti-
VEGF. The Diabetic Retinopathy Clinical Research Network study found that the
mean change in visual acuity was significantly greater in patients receiving
ranibizumab plus prompt/deferred laser surgery (+9 letters) compared to
treatments without anti-VEGF agents. (Submitted by: American Academy of
Ophthalmology)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)While written comments were not provided, the
commenter indicated their support for this measure in this program. (Submitted
by: American Optometric Association )
(Program: Merit-Based
Incentive Payment System (MIPS); MUC ID: MUC15-394) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Academy of Ophthalmology strongly supports NQF MAP’s
recommendation of encouraged continued development for this measure. We
support the inclusion of this measure for inclusion in federal quality
reporting programs, including the MIPS measure set. This measure has been
accepted by CMS as a qualified clinical data registry measure available and
currently used for PQRS reporting through the Academy’s QCDR, IRIS Registry.
This is an important outcome measure for acute anterior uveitis that measures
improvement of visual acuity, a desired treatment goal to continue the level
of the patient's daily activities of daily living and quality of life. This
measure would address a gap in care; despite relatively low incidence rates,
uveitis is the third leading cause of preventable blindness in developed
countries, and sight-threatening complications of uveitis include glaucoma,
damage to the retina and macular edema. Available data strongly indicate that
active inflammation is correlated with visual loss and that higher levels of
inflammation are associated with a greater risk of visual loss. Furthermore,
active inflammation is a risk factor for the occurrence of structural
complications, which often are the cause of visual loss. The
preservation/improvement in visual acuity is the ultimate goal. (Submitted
by: American Academy of Ophthalmology)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: American
Optometric Association)
- (Early public comment)We encourage NQF MAP to recommend these
measures for inclusion in the MIPS measure set. This is an important outcome
measure for acute anterior uveitis that measures improvement of visual acuity,
a desired treatment goal to continue the level of the patient's daily
activities of daily living and quality of life. (Submitted by: American
Medical Association)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)The American Academy of Ophthalmology
strongly encourages NQF MAP to recommend this measure for inclusion in federal
quality reporting programs, including the MIPS measure set. This measure has
been accepted by CMS as a qualified clinical data registry measure available
and currently used for PQRS reporting through the Academy’s QCDR, IRIS
Registry. This is an important outcome measure for acute anterior uveitis that
measures improvement of visual acuity, a desired treatment goal to continue
the level of the patient's daily activities of daily living and quality of
life. This measure would address a gap in care; despite relatively low
incidence rates, uveitis is the third leading cause of preventable blindness
in developed countries, and sight-threatening complications of uveitis include
glaucoma, damage to the retina and macular edema. Available data strongly
indicate that active inflammation is correlated with visual loss and that
higher levels of inflammation are associated with a greater risk of visual
loss. Furthermore, active inflammation is a risk factor for the occurrence
of structural complications, which often are the cause of visual loss. The
preservation/improvement in visual acuity is the ultimate goal. (Submitted
by: American Academy of Ophthalmology)
- (Early public comment)While written comments were not provided, the
commenter indicated their support for this measure in this program. (Submitted
by: American Optometric Association)
(Program: Hospital Value-Based
Purchasing Program; MUC ID: MUC15-395) |
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- CAPC urges the MAP to change its preliminary recommendation for MUC15-395
from “Support” for inclusion in the Hospital Value-Based Purchasing program to
“Do Not Support”. Schwarze et al. (2014) noted that the use of 30-day
mortality measures (particularly perioperative mortality measures) can inhibit
the use of palliative services and fail to accommodate the wishes of patients
who would prefer death over prolonged life-sustaining treatment. Even in the
instance of a successful surgery, a patient could experience unforeseen
complications which cause extreme pain and suffering. Yet the inclusion of
this measure in the HVBP could potentially inhibit palliative care referral
before 30 days following surgery in these cases, as some providers may fear
the consequences of patients choosing to pursue comfort-related goals. We
strongly urge MAP to reconsider its position on this measure. (Submitted by:
Center to Advance Palliative Care)
- The measure combines readmissions, observation stays and ED visits into a
single number of days; each of these episodes reflect widely different
approaches to patient-centered care and cannot be interpreted from a single
number. While CMS aims to reduce the number of observation days, the fact is
that payment policies such as the Two Midnight rule and measures such as MSPB
drive care to the least restrictive and costly care setting (often being
observation status). Moreover, given that readmissions are already captured in
their own set of measures in addition to MSPB, it is not clear why the length
of stay for the readmission is of import. (Submitted by: Premier)
- This measure should be risk adjusted for socio-economic factors prior to
implementation in a payment program. (Submitted by: Premier)
- AAHPM urges the MAP to change its recommendation to “do not support.” The
use of 30-day mortality measures (particularly perioperative mortality
measures) can inhibit the use of palliative services and fail to accommodate
the wishes of patients who would prefer death over prolonged life-sustaining
treatment. Even in the instance of a successful surgery, a patient could
experience unforeseen complications, which cause extreme pain and suffering.
Yet the inclusion of this measure in the HVBP could potentially inhibit
palliative care referral before 30 days following surgery in these cases, as
some providers may fear the consequences of patients choosing to pursue
comfort-related goals. If this measure is ever adopted, at the very least, it
should include an exclusion for both hospice patients and those who opt to
receive primarily palliative care. It is equally important to include
"discharged to hospice" as part of the exclusion criteria as it is to include
“admitted from hospice.” Hospitals should not be penalized for the mortality
of patients discharged to hospice or this will set up a disincentive to
discharge patients from hospital to hospice. (Submitted by: American Academy
of Hospice and Palliative Medicine)
- (Early public comment)Edwards supports use of this outcome measure
in the Hospital Value Based Purchasing program; mortality is arguably the most
important outcome indicator to understand. An all-cause mortality measure for
patients who undergo CABG surgery will provide hospitals with an incentive to
reduce mortality through improved coordination of perioperative care and care
coordination post-discharge. Given that CABG readmission rates will be
collected through the Hospital Readmissions Reduction Program beginning in
2017, also collecting CABG mortality rates will help to ensure that the full
spectrum of perioperative care and care coordination can be assessed while
simultaneously ensuring CMS can monitor for unintended consequences of
measurement. Further, understanding mortality rates and causes of mortality
can lead to improved processes and protocols during the perioperative time
period for CABG surgery. Edwards would also like to see measurements of
patient reported outcomes to enhance understanding of the quality of care
delivered by the hospital. (Submitted by: Edwards Lifesciences)
- (Early public comment)This measure should be risk adjusted for
socio-economic factors prior to implementation in a payment program.
(Submitted by: Premier)
- (Early public comment)While data shows that negative pressure wound
therapy can help reduce post-operative complications, it is not clear whether
mortality would be impacted at this stage. Still, we believe the measure
would lead to important quality improvement and infection reduction efforts.
(Submitted by: Smith & Nephew )
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-396)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Academy of Ophthalmology strongly supports NQF MAP’s
recommendation of encouraged continued development for this measure. We
support the inclusion of this measure for inclusion in federal quality
reporting programs, including the MIPS measure set. The MAP recommendations
state that it is unclear what this intermediate outcome measure adds to the
functional outcome measure - Acute Anterior Uveitis: Post-treatment visual
acuity, which is more meaningful for public reporting. We understand the basis
for this comment, and note that this is the rationale for the measure.
Inflammation occurs earlier and leads to the loss of visual acuity. Although
visual acuity may be more meaningful for public reporting, the tracking of
inflammation may help the physician identify patients at risk for visual loss,
thus allowing the physician to intervene earlier and prevent visual loss.
This measure has been accepted by CMS as a qualified clinical data registry
measure available and currently used for PQRS reporting through the Academy’s
QCDR, IRIS Registry. This is an important outcome measure for acute anterior
uveitis that measures reduction of inflammation, a desired treatment goal for
improved clinical and functional outcome. This measure would address a gap in
care; despite relatively low incidence rates, uveitis is the third leading
cause of preventable blindness in developed countries, and sight-threatening
complications of uveitis include glaucoma, damage to the retina and macular
edema. Available data strongly indicate that active inflammation is
correlated with visual loss and that higher levels of inflammation are
associated with a greater risk of visual loss. Furthermore, active
inflammation is a risk factor for the occurrence of structural complications,
which often are the cause of visual loss. Therefore, a primary goal of
treatment (when treatment is needed) is suppression of inflammation to grade 0
cells (inactive disease). The use of the Standardization of Uveitis
Nomenclature (SUN) grading system, which is widely accepted and has excellent
interobserver agreement, is encouraged for grading anterior chamber
inflammation. For acute anterior uveitis, treatment then is tapered and
discontinued and treatment of the acute attacks is appropriate. (Submitted by:
American Academy of Ophthalmology)
- The American Optometric Association recommends that MUC15-396 should
include grade 0 flare in addition to Grade 0 cells. These together describe
the degree of anterior uveitis. (Submitted by: American Optometric
Association)
- (Early public comment)The AMA encourages NQF MAP to recommend these
measures for inclusion in the MIPS measure set. This is an important outcome
measure for acute anterior uveitis that measures reduction of inflammation, a
desired treatment goal for improved clinical and functional outcome.
(Submitted by: American Medical Association)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)The American Academy of Ophthalmology
strongly encourages NQF MAP to recommend this measure for inclusion in federal
quality reporting programs, including the MIPS measure set. This measure has
been accepted by CMS as a qualified clinical data registry measure available
and currently used for PQRS reporting through the Academy’s QCDR, IRIS
Registry. This is an important outcome measure for acute anterior uveitis that
measures reduction of inflammation, a desired treatment goal for improved
clinical and functional outcome. This measure would address a gap in care;
despite relatively low incidence rates, uveitis is the third leading cause of
preventable blindness in developed countries, and sight-threatening
complications of uveitis include glaucoma, damage to the retina and macular
edema. Available data strongly indicate that active inflammation is
correlated with visual loss and that higher levels of inflammation are
associated with a greater risk of visual loss. Furthermore, active
inflammation is a risk factor for the occurrence of structural complications,
which often are the cause of visual loss. Therefore, a primary goal of
treatment (when treatment is needed) is suppression of inflammation to grade 0
cells (inactive disease). The use of the Standardization of Uveitis
Nomenclature (SUN) grading system, which is widely accepted and has excellent
interobserver agreement, is encouraged for grading anterior chamber
inflammation. For acute anterior uveitis, treatment then is tapered and
discontinued and treatment of the acute attacks is appropriate. (Submitted
by: American Academy of Ophthalmology )
- (Early public comment)The American Optometric Association
recommends that MUC15-396 should include grade 0 flare in addition to Grade 0
cells. These together describe the degree of anterior uveitis. (Submitted by:
American Optometric Association )
(Program: Merit-Based
Incentive Payment System (MIPS); MUC ID: MUC15-397) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Academy of Ophthalmology strongly supports NQF MAP’s
recommendation of encouraged continued development for this measure. We
support the inclusion of this measure for inclusion in federal quality
reporting programs, including the MIPS measure set. The MAP recommendations
state that it is not clear whether patients that fail treatment for acute
uveitis in MUCFIFTEEN-394 Acute Anterior Uveitis: Post-treatment visual acuity
are the patients in this measure or when the 90 days specified begins. We
appreciate the comment, but note that the full measure specification states
that the 90 days begins with treatment initiation. Thus, the patients who
would fail the measure would be those patients with a best corrected visual
acuity worse than 20/40 or worse than their baseline value within 90 days of
treatment initiation. This measure has been accepted by CMS as a qualified
clinical data registry measure available and currently used for PQRS reporting
through the Academy’s QCDR, IRIS Registry. This is an important outcome
measure for chronic anterior uveitis that measures improvement of visual
acuity, a desired treatment goal to continue the level of the patient's daily
activities of daily living and quality of life. This measure would address a
gap in care; despite relatively low incidence rates, uveitis is the third
leading cause of preventable blindness in developed countries, and
sight-threatening complications of uveitis include glaucoma, damage to the
retina and macular edema. Available data strongly indicate that active
inflammation is correlated with visual loss and that higher levels of
inflammation are associated with a greater risk of visual loss. Furthermore,
active inflammation is a risk factor for the occurrence of structural
complications, which often are the cause of visual loss. The
preservation/improvement in visual acuity is the ultimate goal. (Submitted by:
American Academy of Ophthalmology)
- The American Optometric Association recommends that MUC15-397 should
include grade 0 flare in addition to Grade 0 cells. These together describe
the degree of anterior uveitis (Submitted by: American Optometric
Association)
- (Early public comment)The AMA encourages NQF MAP to recommend these
measures for inclusion in the MIPS measure set. This measure has been accepted
by CMS as a qualified clinical data registry measure available and currently
used for PQRS reporting through the Academy’s QCDR, IRIS Registry. This is an
important outcome measure for chronic anterior uveitis that measures
improvement of visual acuity, a desired treatment goal to continue the level
of the patient's daily activities of daily living and quality of life.
(Submitted by: American Medical Association)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)The American Academy of Ophthalmology
strongly encourages NQF MAP to recommend this measure for inclusion in federal
quality reporting programs, including the MIPS measure set. This measure has
been accepted by CMS as a qualified clinical data registry measure available
and currently used for PQRS reporting through the Academy’s QCDR, IRIS
Registry. This is an important outcome measure for chronic anterior uveitis
that measures improvement of visual acuity, a desired treatment goal to
continue the level of the patient's daily activities of daily living and
quality of life. This measure would address a gap in care; despite relatively
low incidence rates, uveitis is the third leading cause of preventable
blindness in developed countries, and sight-threatening complications of
uveitis include glaucoma, damage to the retina and macular edema. Available
data strongly indicate that active inflammation is correlated with visual loss
and that higher levels of inflammation are associated with a greater risk of
visual loss. Furthermore, active inflammation is a risk factor for the
occurrence of structural complications, which often are the cause of visual
loss. The preservation/improvement in visual acuity is the ultimate goal.
(Submitted by: American Academy of Ophthalmology)
- (Early public comment)The American Optometric Association
recommends that MUC15-397 should include grade 0 flare in addition to Grade 0
cells. These together describe the degree of anterior uveitis. (Submitted by:
American Optometric Association)
(Program: Long-Term Care Hospital Quality
Reporting Program; MUC ID: MUC15-398) |
- MAP notes this measure has high value potential for the LTCH QRP because
successful weaning is associated with decreased morbidity, mortality, and
resource use. We agree and further believe the measure is ready for
implementation in Medicare programs. (Submitted by: Medtronic)
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-399)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Academy of Ophthalmology strongly supports NQF MAP’s
recommendation of encouraged continued development for this measure. We
support the inclusion of this measure for inclusion in federal quality
reporting programs, including the MIPS measure set. In its recommendations,
MAP states that it is unclear what this intermediate outcome measure adds to
the functional outcome measure - Chronic Anterior Uveitis: Post-treatment
visual acuity which is more meaningful for public reporting. We understand the
basis for this comment, and note that this is the rationale for the measure.
Inflammation occurs earlier and leads to the loss of visual acuity. Although
visual acuity may be more meaningful for public reporting, the tracking of
inflammation may help the physician identify patients at risk for visual loss,
thus allowing the physician to intervene earlier and prevent visual loss. This
measure has been accepted by CMS as a qualified clinical data registry measure
available and currently used for PQRS reporting through the Academy’s QCDR,
IRIS Registry. This is an important outcome measure chronic anterior uveitis
that measures reduction of inflammation, a desired treatment goal for improved
clinical and functional outcome. This measure would address a gap in care;
despite relatively low incidence rates, uveitis is the third leading cause of
preventable blindness in developed countries, and sight-threatening
complications of uveitis include glaucoma, damage to the retina and macular
edema. Available data strongly indicate that active inflammation is
correlated with visual loss and that higher levels of inflammation are
associated with a greater risk of visual loss. Furthermore, active
inflammation is a risk factor for the occurrence of structural complications,
which often are the cause of visual loss. Therefore, a primary goal of
treatment (when treatment is needed) is suppression of inflammation to grade 0
cells (inactive disease). The use of the Standardization of Uveitis
Nomenclature (SUN) grading system, which is widely accepted and has excellent
interobserver agreement, is encouraged for grading anterior chamber
inflammation. For chronic anterior uveitis, treatment is tapered to topical
corticosteroid equivalents of prednisolone acetate 1% 3 times daily or less
while maintaining grade 0 anterior chamber cells. The use of systemic
medications may be necessary to achieve this goal and the choice is disease
and ‘host” specific. Long-term goals include the prevention of structural
complications, including posterior synechiae, ocular hypertension/glaucoma,
and cataracts. (Submitted by: American Academy of
Ophthalmology)
- The American Optometric Association recommends that MUC15-399 include
grade 0 flare in addition to Grade 0 cells. These together describe the degree
of anterior uveitis. (Submitted by: American Optometric
Association)
- (Early public comment)The AMA encourages NQF MAP to recommend these
measures for inclusion in the MIPS measure set. This is an important outcome
measure chronic anterior uveitis that measures reduction of inflammation, a
desired treatment goal for improved clinical and functional outcome.
(Submitted by: American Medical Association)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
- (Early public comment)The American Academy of Ophthalmology
strongly encourages NQF MAP to recommend this measure for inclusion in federal
quality reporting programs, including the MIPS measure set. This measure has
been accepted by CMS as a qualified clinical data registry measure available
and currently used for PQRS reporting through the Academy’s QCDR, IRIS
Registry. This is an important outcome measure chronic anterior uveitis that
measures reduction of inflammation, a desired treatment goal for improved
clinical and functional outcome. This measure would address a gap in care;
despite relatively low incidence rates, uveitis is the third leading cause of
preventable blindness in developed countries, and sight-threatening
complications of uveitis include glaucoma, damage to the retina and macular
edema. Available data strongly indicate that active inflammation is
correlated with visual loss and that higher levels of inflammation are
associated with a greater risk of visual loss. Furthermore, active
inflammation is a risk factor for the occurrence of structural complications,
which often are the cause of visual loss. Therefore, a primary goal of
treatment (when treatment is needed) is suppression of inflammation to grade 0
cells (inactive disease). The use of the Standardization of Uveitis
Nomenclature (SUN) grading system, which is widely accepted and has excellent
interobserver agreement, is encouraged for grading anterior chamber
inflammation. For chronic anterior uveitis, treatment is tapered to topical
corticosteroid equivalents of prednisolone acetate 1% 3 times daily or less
while maintaining grade 0 anterior chamber cells. The use of systemic
medications may be necessary to achieve this goal and the choice is disease
and ‘host” specific. Long-term goals include the prevention of structural
complications, including posterior synechiae, ocular hypertension/glaucoma,
and cataracts. (Submitted by: American Academy of Ophthalmology)
- (Early public comment)The American Optometric Association
recommends that MUC15-399 include grade 0 flare in addition to Grade 0 cells.
These together describe the degree of anterior uveitis.. (Submitted by:
American Optometric Association)
(Program: Long-Term Care Hospital Quality
Reporting Program; MUC ID: MUC15-400) |
- FAH supports the workgroup's recommendation and rationale. We request
that the measure be fully tested before it is considered for a future payment
program. (Submitted by: Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- We agree with MAP members who stressed the variation that exists in the
field and noted the importance of this measure. Given the lack of measures in
this area (NQF-endorsed or not), we believe this measure is appropriate for
incorporation into CMS programs at this time. (Submitted by:
Medtronic)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program: Merit-Based Incentive Payment System (MIPS);
MUC ID: MUC15-402) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program:
Inpatient Rehabilitation Facility Quality Reporting Program; MUC ID:
MUC15-408) |
- The AHA agrees with the MAP’s recommendations for this measure. We are
concerned by the lack of data of the reliability and validity of patient
discharge status codes that would be used in this measure. Given that it is
such a fundamental part of the measure, CMS should conduct such testing and
make the results publicly available. Furthermore, we strongly urge that this
measure be assessed for the impact of sociodemographic factors on performance,
and an adjustment should be incorporated if warranted. (Submitted by:
American Hospital Association (AHA))
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- We believe that the PAC industry should embrace measures, such as DTC,
that place an emphasis on the ability for patients to return and stay at home
– a central tenant of post-acute care. We have several comments that will
serve as constructive additions to the development of these measures. We hope
that NQF and measure developers will analyze and consider these comments and
how they could improve the DTC measure development for IRFs. A. THE DISCHARGE
TO COMMUNITY MEASURE SHOULD BE DISTINGUISHED FROM THE 31-DAY POST-DISCHARGE
READMISSIONS MEASURES The measure specification document states that this DTC
measure tracks “patients/residents/persons who are discharged to the
community, and do not have an unplanned (re)admission to an acute care
hospital or LTCH on the day of discharge or in the 31 days following discharge
to community, and remain alive during the 31 days following discharge to
community.” Based on this description, this DTC measure, although not called
a “readmissions” measure, functions as a readmission measure, similar to those
post-acute readmissions measures already in place and being developed under
the IMPACT Act (All-cause Unplanned Readmissions (NQF #2502), and the
Potentially Preventable Readmissions (“PPR”) measures under development), but
instead focused on a subset of a provider’s patient population – Medicare
patients that are discharged to community. If those existing (and soon-to-be
implemented) readmission measures already track the number of people who are
readmitted to a hospital within 30 days after being discharged from the PAC
setting either under an all-cause basis or a potentially preventable basis,
and this DTC measure tracks those patients that are discharged to community
and do not have a “(re)admission to an acute care hospital or LTCH” within the
31 day timespan, then all of the patients who have an “unfavorable outcome”
under the DTC measure will also and already be captured in at least one, if
not both, of these existing readmissions measures. Instead of using the DTC
measure to track and eventually publicly report on such readmissions, which
are already tracked by the other readmission measures soon to be in place, it
would be more meaningful to track the number of patients who go directly to
the community (numerator) vs. the number of patients expected to go directly
to the community (denominator), regardless of subsequent readmissions. The
proposed DTC measure design is already built around comparing the actual
number of successful discharges to community vs. expected successful
discharges, but our comment here is directed at the definition of what it
means to be “discharged to community.” In other words, if “discharged to
community” means “31 days at home without a readmission,” (as proposed by
measure developers) then this measure effectively becomes a readmission
measure that selectively focuses on those patients who are discharged home – a
population that is already covered both by the All-cause Unplanned
Readmissions measure (NQF #2502) and the proposed 30-day Post-discharge
Potentially Preventable Readmission measure (under development at RTI). If,
on the other hand, “discharged to community” means “patients who are
discharged home without an intervening facility stay” (regardless of a
subsequent readmission), that definition does not unnecessarily overlap with
other readmission measures, thus giving providers and the public a more useful
measure that is distinct from existing measures. B. MEASURE SHOULD REMAIN
LIMITED TO MEDICARE FEE-FOR-SERVICE POPULATION According to the measure
description (specifically Measure Exclusion 7), this measure is only
applicable to Medicare fee-for-service (“FFS”) populations, and not other
payer populations, including Medicare Advantage (“MA”). We support this
exclusive focus on FFS because other payers, including private insurance
companies that contract with the Medicare program to manage MA plans, often
dictate what services IRFs and other PAC providers can offer to their
discharged patients, thereby limiting the ability of such providers to
maximize their efforts to keep people healthy at home following discharge.
This has the potential to negatively impact the ability to optimize
performance on this DTC measure (and other readmission measures). We note
that, while CMS and RTI have made the laudable decision to focus only on
Medicare FFS for this DTC measure, we think this approach should extend to
other measures developed under the IMPACT Act as well. If some IMPACT Act
measures focus solely on Medicare FFS while others cover all patients and all
payers, a significant disconnect in the underlying data will arise. Despite
the logic behind this approach, CMS’ response to the Drug Regimen Review
measure public comments, released last week, indicated support for the
opposite view. In response to comments on that Drug Regimen Review measure
recommending that all PAC settings assess the same populations with the IMPACT
measures and that the denominators be limited to Medicare fee-for-service
enrollees only (since this is the population that is subject to changes in
payment policy under the IMPACT Act), CMS replied saying that it felt that
quality improvements are an appropriate goal for all patients, “regardless of
payer source.” While no one would disagree with this broad statement of
quality improvement across payer populations, this view does not account for
the specific fact that, if a CMS quality measure that is ultimately tied to
Medicare reimbursement measures non-Medicare populations for which PAC
providers are limited (by non-Medicare payers) in post-discharge service
offerings, such a scenario potentially thwarts a providers ability to control
and improve performance on that measure, and could have significant payment or
regulatory implications. C. RISK ADJUSTMENT FOR SOCIODEMOGRAPHIC AND
FUNCTIONAL STATUS The draft specifications indicate that the DTC measure will
be risk-adjusted for multiple variables, including age, sex, dialysis status,
and prior acute care utilization in the past year. We generally support this
broad range of risk adjustment, but also believe that the measure developers
should consider including risk adjustment for additional sociodemographic
factors and functional status as well, such as geographic area (urban/rural)
or percentage of low income patients. Recent academic literature has added
evidence to the notion that readmissions back to hospitals are driven by more
directly by patient status factors and not by the quality of care delivered.
Since this DTC measure, as currently proposed and as argued above, is (in its
current form) effectively a readmissions measure focused on the population of
patients discharged directly to community, we feel that this evidence is also
applicable to this measure, not just the formal readmission measures.
Furthermore, The National Quality Forum (“NQF”) in April began a two-year
trial program of a temporary policy change that would allow risk adjustment of
performance measures for socioeconomic and other demographic factors, a
departure from earlier quality measurement positions that viewed
sociodemographic risk adjustment as inappropriate. With evidence that
sociodemographic risk is real and impact readmission rates, we recommend that
measure developers and NQF consider including it in the list of risk
adjustment factors for these measures. We also believe adjusting for
functional status would benefit the accuracy of the DTC measure. Functional
status has a direct correlation with a patient’s ability to remain healthy at
home after PAC services have ended, meaning that PAC providers who treat more
functionally impaired patients will likely have a higher readmission rate, and
a lower DTC rate. Accordingly, we recommend that NQF and the measure
developers consider how to apply an additional risk-adjustment factor for
functional status in the overall risk adjustment methodology. D. RISK OF
CONFUSION IN MULTIPLE READMISSION MEASURES As part of the existing IRF PPS
Quality Reporting Program (“IRF QRP”), IRFs already report All-cause Unplanned
Readmission (NQF #2502) and are scheduled to have the PPR measure publicly
reported beginning next year, not to mention “within stay” readmissions
measures. Other PAC types will also require public reporting of a general
all-cause readmissions measure. We are concerned that, as required by the
IMPACT Act and various QRP provisions, the eventual public reporting of all of
these measures (which are essentially a subset of the more general all-cause
measures) will result in substantial confusion amongst members of the public.
For example, if both readmissions measures and the DTC measure are all
publicly reported without thorough explanations, PAC providers will have one
all-cause unplanned readmission rate, a separate PPR rate, a separate PPR
“within stay” rate, and a DTC percentage that is measured in the opposite
direction (looking at how many patients stayed home instead of how many
patients were readmitted). As a side comment, we note that it may be more
administratively simple if CMS instead measured DTC as a readmissions measure
for patients discharged to home. That would harmonize this version of a
readmissions rate with the other measures. Nevertheless, we question whether
the crucial distinctions between these different, but related, readmissions
indicators will be readily apparent to members of the public who take the time
to assess different PAC providers based on readmission rates. Similarly,
providers may have trouble accurately understanding the purpose and ultimate
use of additional readmissions indicators. IRF providers already receive
annual PEPPER reports and also report on the All-cause measure (NQF #2502).
With the addition of a “within stay” readmissions measure, a post-discharge
PPR measure, and this DTC measure, we think it would be highly valuable if CMS
were to take deliberate steps to clearly communicate the intended use of and
distinctions between each of these readmission tools, making sure to note and
how they will relate to one another. Without such clarifying communication,
providers may find themselves adrift in various readmissions data without a
clear idea of how it is all being used by the Agency. Lastly, in order to
standardize readmission measures and avoid unnecessary confusion, we ask that
CMS and RTI standardize the language and definitions used in conjunction with
establishing observation windows for all readmissions measures. For example,
the IRF All-Cause Unplanned Readmissions measure (NQF #2502) is measured
beginning two days after the day of discharge for 30 days; this DTC measure
begins one day after the day of discharge for 31 days. These two measures
both end on the same day, but it could help to avoid confusion if these
discharge and observation window definitions and timeframes were standardized.
(Submitted by: HealthSouth)
- FAH supports the workgroup's recommendation and rationale. FAH shares many
of the workgroup's concerns, particularly the concern about appropriate risk
adjustment and the potential conflict with other readmission measures. We
strongly urge NQF to require developers to explore additional SDS factors
beyond the current variables that are often used in the analysis (e.g., dual
eligible status, race) and ask that MAP make clear recommendations to CMS that
a broader set of variables should be included in the measures submitted for
future consideration. We request that the measure be fully tested before it is
considered for a future payment program. (Submitted by: Federation of American
Hospitals)
- AAPM&R commends NQF for evolving its work to understand how measures
are being developed and implemented across settings and how they impact
payment reform. This is a huge endeavor that AAPM&R stands behind in
concept. However, AAPM&R cautions NQF to ensure their processes and
review of measures are adequately reported back to CMS and other rule-making
entities to ensure the NQF’s measurement expertise is realized in rule making.
While this measure addresses functional improvement , it does not address
the practical value of the measurable improvement or the ability of a patient
to return to the community. For example, a patient with a complete cervical
spinal cord injury or dense hemiplegia from a stroke may not make significant
functional gains (i.e., they may remain dependent in many domains of mobility
and/or activities of daily living). However, with expert and comprehensive
patient and family/care-giver education and training by the rehabilitation
team, the patient may return to the community despite not meeting the
thresholds that are suggested by the quality measures. The Academy believes
that measurement of patient and family engagement with the process of care and
with education and training must be considered in the evaluation of models of
PAC. Another concern is that without factors related to psychosocial and
family financial support in prediction models, changes in function from
admission to discharge do not tell the entire story. The Academy urges CMS to
support the development of quality measures that relate to patient and family
engagement as PAC reform implementation evolves . AAPM&R believes there
needs to be further discussions about psychosocial issues. (Submitted by:
American Academy of Physical Medicine and Rehabilitation )
- This measure is being developed by CMS. Many patients desire to return to
their homes and communities after an acute hospital stay and subsequent
post-acute care services. At this time IRFs track discharge destination for
patients via the Inpatient Rehabilitation Facility Patient Assessment
Instrument (IRF PAI) though this measure has the potential to change the way
in which they track and report that information. While IRFs make every effort
to return patients to their communities at times discharge to community isnot
feasible particularly if a patient is very ill or injured or if the necessary
family, caregiver, or community support is not available. If this measure is
not developed properly it may create barriers to access for patients who do
not appear to be able to be discharged to their community. As a result, CMS
should consider excluding patient populations that are infrequently discharged
back to community such as patients that are admitted to IRFs from SNFS, who
typically return to SNFs. A discharge to community measure should be developed
carefully, with appropriate risk adjustment, to ensure IRFs are not unfairly
penalized for not returning such patients to the community. Without adequate
risk-adjustment, this measure will not allow for cross-setting comparisons.
Therefore, we recommend that CMS enhance the risk adjustment methodology to
account for socioeconomic and sociodemographic factors as wellas the patient’s
behavioral health and functional status. The need to adjust for socioeconomic
status was recently supported by Sheingold et al in an article published in
the January 2016 edition of Health Affairs entitled “Understanding Medicare
Hospital Readmission Rates And Differing Penalties Between Safety-Net And
Other Hospitals.” As drafted this measure defines discharge to community as
home with or without home health services. We believe this definition is too
narrow and does not sufficiently account for patients who may not be safely
discharged home. CMS intends to use the patient discharge status codes listed
in Table 1 of the draft measure specifications. In our comments to the Agency
we suggested that this list should be applicable to SNFs only. We believe the
low rate of discharge to community in this sector and the high incidence of
transfer to the residential portion of its own or another SNF’s nursing home
should not be counted as a discharge to the community. Table 1 also fails to
collect the level of detail associated with discharge to home as it currently
is collected on the IRF PAI. At this time there are two discharge status codes
on the IRF PAI associated with discharge to home which should be added for the
purposes of this measure; 01: Home (private apartment, board/care, assisted
living, group home, transitional living); and 06: Home under the care of an
organized home health service organization. Finally, CMS needs to consider
how to clearly delineate Discharge to Community data from the other IRF
readmission measures. For example, IRFs are currently subject to a
readmission measure under the IRF QRP and CMS is in the process of developing
two readmission measures for this setting pursuant to the IMPACT Act. Because
a discharge to the community can be nullified if the patient returns to an IRF
within 31 days of discharge, it is effectively a readmissions measure. CMS
has proposed that this measure be used and shared with patients via the recent
discharge planning rule, which would present patients with many similar, but
ultimately different, measures of readmissions which could lead to significant
confusion for patients and their families when deciding where to receive PAC
services. Due to our concerns with this measure as it is currently drafted,
CMS and NQF should consider measures such as the patient’s return to the
highest practicable level of function or independence or the achievement of
his or her goals at discharge. We believe such measures are more likely to
improve patient outcomes and add value to the measure set already in use in
the IRF QRP. As noted, CMS is still in the measure development process. The
Agency requested comments on the draft measure specifications which were due
December 8. Given that thismeasure is in the CMS development process, it may
be premature to approve this measure for the purpose of the IRF QRP.
(Submitted by: American Medical Rehabilitation Providers
Association)
- The hospice exemption, as already included, is very important for this
measure and should be retained during further development. (Submitted by:
American Academy of Hospice and Palliative Medicine)
- (Early public comment)We have the following concerns related to
this measure: 1. The inclusion of unplanned readmissions in the discharge
to community measure development and calculation. Our concerns related to the
inclusion of unplanned readmissions in the discharge to community measure
development and calculation can be defined as follows: a.
Duplication/commingling of quality metrics With the inclusion of unplanned
readmissions in the discharge to community measure development and
calculation, there is the potential for there to be a strong correlation
between the performances of the two measures. In other words, those PAC
providers that perform poorly with the unplanned readmission measure are more
likely to perform poorly on this measure, while those PAC providers that
perform well with the unplanned readmission measure have a better opportunity
to perform well on this measure. Take for instance the scenario of two
facilities with similar patient populations (age, sex, etc.), where provider A
discharges 75% to a community setting with a 5% readmission rate while
provider B discharges 72% to a community setting with a 2% readmission rate.
Which facility performs better at discharging patients to a community setting?
Is the discharge to community measure truly representative of the ability of
the post-acute care provider to provide services that get the patient back to
a community setting, or is too much emphasis being placed upon the ability of
the patient to stay in a community setting? b. Inclusion of a factor
that is outside of post-acute care provider control While a post-acute care
provider can provide services that impact the ability of a patient to be
discharged back to a community setting, whether or not a patient returns to an
acute care facility in the 30 days following that PAC discharge can be
completely unrelated to the services furnished by the PAC provider. For
instance, a patient is discharged home from a post-acute care provider but is
re-admitted to acute care 10 days later for pneumonia (which is listed as a
diagnosis category that cannot be considered planned). Should the post-acute
care provider’s discharge to community percentage be penalized if the
readmission is completely unrelated to the services provided within post-acute
care? With the concerns noted above, we would recommend that the measure
developers remove the unplanned readmission component from the discharge to
community measurement, and provide side-by-side comparison of these two
separate and unique quality measures. 2. Potential for site-specific
risk adjustment for a “cross-setting” measure. While we note that the risk
adjustment variables are “under consideration”, we are very concerned that the
variables noted in the draft specification designate certain variables as
being applicable to unique or specific post-acute care providers. The IMPACT
Act requires the specification of quality measures and resource use metrics
that are standardized and interoperable across PAC settings. In creating a
measure where consideration is being given to risk adjustment variables that
differ by post-acute care setting, is CMS truly meeting the definition of
“standardized and interoperable”? As an example, “Activities of Daily Living”
(ADLs) are noted as one of the Clinical conditions variables, yet is noted for
“the HHA setting only”. If the measure developer can show that ADLs can be
used to differentiate the performance within the HHA population, couldn’t ADLs
also be used to differentiate the performance of all post-acute care settings
and produce a measurement value that is “standardized and interoperable”? We
urge CMS and the measure developers to introduce risk-adjustment variables
that are “standardized and interoperable” in order to meet the IMPACT Act
requirements. (Submitted by: UDSMR)
- (Early public comment)This measure is being developed by CMS. Many
patients desire to return to their homes and communities after an acute
hospital stay and subsequent post-acute care services. At this time IRFs track
discharge destination for patients via the Inpatient Rehabilitation Facility
Patient Assessment Instrument (IRF PAI) though this measure has the potential
to change the way in which they track and report it. IRFs make every effort to
return patients to their communities but at times discharge to community is
not feasible particularly if a patient is very ill or injured or if the
necessary family, caregiver, or community support is not available. Therefore,
a discharge to community measure should be developed carefully, with
appropriate risk adjustment, to ensure IRFs are not unfairly penalized for not
returning such patients to the community. If this measure is not developed
properly it may create barriers to access for patients who do not appear to be
able to be discharged to their community. We recommend that CMS enhance the
risk adjustment methodology to account for socioeconomic and sociodemographic
factors as well as the patient’s functional status. As drafted this measure
defines discharge to community as home with or without home health services.
We believe this definition is too narrow and does not sufficiently account for
patients who may not be safely discharged home. CMS intends to use patient
discharge status codes as listed in Table 1 of the draft measure
specifications. In our comments to the Agency we suggested that this list
should be applicable to SNFs only. We believe the low rate of discharge to
community in this sector and the high incidence of transfer to the residential
portion of its own or another SNF’s nursing home should not be counted as a
discharge to the community. Table 1 also fails to collect the level of detail
associated with discharge to home as it currently is collected on the IRF PAI.
At this time there are two discharge status codes on the IRF PAI associated
with discharge to home which should be added for the purposes of this measure;
01: Home (private apartment, board/care, assisted living, group home,
transitional living); and 06: Home under the care of an organized home health
service organization. Due to our concerns with this measure as it is
currently drafted, CMS and NQF should consider measures such as the patient’s
return to the highest practicable level of function or independence or the
achievement of his or her goals at discharge. We believe such measures are
more likely to improve patient outcomes and add value to the measure set
already in use in the IRF QRP. As noted, CMS is still in the measure
development process. The Agency has requested comments which are due December
8. Given that this measure is in the CMS development process, it may be
premature to endorse this measure for the purpose of the IRF QRP. (Submitted
by: American Medical Rehabilitation Providers Association)
- (Early public comment)The ultimate goals of post-acute care are
avoiding institutionalization and returning patients to their previous level
of independence and functioning, with discharge to community being the primary
goal for the majority of post-acute patients. For many, home is a symbol of
independence, privacy, and competence. Discharge to community is considered a
valuable outcome to measure because it is a multifaceted measure that captures
the patient’s functional status, cognitive capacity, physical ability, and
availability of social support at home. There is considerable variation in
discharge to community rates within and across post-acute settings. Studies
show geographic variation, variation across patient socioeconomic
characteristics (for example, race and ethnicity), and variation by facility
characteristics (for profit vs. nonprofit, freestanding vs. hospital-based,
urban vs. rural). In the IRF setting, discharge to community rates vary across
providers, ranging from about 60% to 75%. The 2015 MedPAC report shows that,
in FY 2013, the facility-level, mean risk-adjusted discharge to community rate
for IRFs within 100 days of admission was 75.8%, and the mean observed rate
was 74.7%. Discharge to community rates also vary widely in the SNF setting,
ranging from as low as 31% to as high as 65%. The 2015 MedPAC report shows a
mean risk-adjusted discharge to community rate of 37.5% for SNFs within 100
days of admission, and mean observed rate of 40.1%. A multicenter study of 23
LTCHs reported that only 28.8% of 1,061 patients who were ventilator-dependent
on admission were discharged to home or assisted living facility. A study of
66,510 Medicare beneficiaries during pre- and post-HH episodes, revealed that
64 percent of beneficiaries discharged from HH did not use any other
Medicare-reimbursed acute or post-acute services in the 30 days following HH
discharge. Significant numbers of patients were admitted to inpatient
facilities (29percent) and lesser numbers to skilled nursing facilities (7.6
percent), inpatient rehabilitation (1.5 percent) and home health (7.2 percent)
or hospice (3.3 percent) within 30 days of HH discharge (Wolff et al., 2008).
II. Feedback Overall, there is not enough detail on the measure
specifications to provide adequate feedback. However, despite the lack of
detail, a response is included below on the discharge to community measure for
LTCH, IRF, SNF, and HH. Description Patients discharged to the community
following PAC stay/episode and do not have an unplanned admission to an acute
care hospital or LTCH in 31 days after community discharge and remain alive
• Although not explicitly stated, it appears that this measure is only holding
the last PAC setting responsible for the discharge? Given what is known about
multiple sites of PAC use either from LTCH/IRF patients are often discharged
to SNF before community discharge, as it is currently worded this measure will
penalize the SNF for the more difficult patients that could not be discharged
from the prior PAC setting. • Research has shown that PAC patients re-enter
the healthcare system through multiple doors after the PAC community
discharge why are these not captured in the measure as a failed transition I
recommend that the numerator should not include individuals who were admitted
to a SNF after PAC community discharge during the 30-day measure window.
Numerator & Denominator There is not enough detail to provide feedback on
the risk adjustment of the numerator. Without details on the variables
included, the origin of those variables, and methods of risk adjustment it is
difficult to provide feedback. Recommend providing further detail. Recommend
including functional status, functional cognition, presence of social support
(e.g., does the individual live alone), and comorbid conditions as risk
adjustors Exclusion There is no discussion of excluding long-stay nursing home
residents in this measure. Long-stay residents that have an acute medical
event, are admitted to an acute care hospital, discharged to PAC for care, and
then transitioned back to long-term care should be excluded from the measure.
These individuals are not returning to the community, while the nursing home
is their home, the effort and processes required for transitioning a long-stay
nursing home resident from PAC back to custodial care is very different that
transitioning a community- residing older adult back to their residence in the
community after a PAC stay. Recommend excluding long stay nursing home
residents from the measure. (Submitted by: American Occupational Therapy
Association)
- (Early public comment)ARN is supportive of a measure that works to
identify unplanned (re)admissions; however, we have concerns with identifying
unplanned (re)admissions based on the planned readmissions algorithm used in
NQF measure #2510: SNF 30-Day All-Cause Readmission Measure (SNFRM); NQF
#2502: All-Cause Unplanned Readmission Measure for 30 Days Post Discharge from
IRFs; NQF #2512: All-Cause Unplanned Readmission Measure for 30 Days Post
Discharge from LTCHs; and NQF #2380: Re-hospitalization During the First 30
Days of Home Health. The exclusion criteria included within NQF #2510 for SNF
stays where the patient had one or more intervening PAC admissions to an IRF
that occurred either between the prior proximal hospital discharge and SNF
admission or after the SNF discharge within the 30-day risk window fails to
allow for a medically complex patient that is treated in an IRF and readmitted
to the SNF within 30 days for a condition that may initially have been treated
as a comorbidity. We disagree with the rationale provided for exclusion, for
while the measure assesses readmission rates while accounting for patient
demographics, principal diagnosis in the prior hospitalization, comorbidities,
and other patient factors, often, this may not be the reason for admission to
a SNF. ARN believes the measure should include the principal diagnosis during
the prior proximal hospitalization, comorbidities based on the secondary
medical diagnoses listed on the patient’s prior proximal hospital claim and
diagnoses from prior hospitalizations that occurred in the previous 365 days,
length of stay during the patient’s prior proximal hospitalization, length of
stay in the intensive care unit (ICU), body system specific surgical
indicators, End-Stage Renal Disease (ESRD) status, whether the patient was
disabled, and the number of prior hospitalizations in the previous 365 days.
It also would be beneficial to understand the comorbidities being evaluated in
the risk-adjustment model. ARN urges the Centers for Medicare and Medicaid
Services (CMS) to develop of a list of comorbidities, comparable to the IRF
Prospective Payment System (PPS) list of comorbidities and we encourage CMS to
categorize an intervening admission to an IRF as a proximal hospitalization.
Additionally, ARN has serious concerns with CMS’s proposal to require PAC
providers to utilize Medicare claims data to calculate their 30-day
readmission rates. Using claims data to calculate readmission rates is
difficult for health care providers, as claims data are cumbersome to use and
access. Employing a 30-day readmission rate measure will not provide
meaningful insight or have an impact on quality improvement efforts if the PAC
settings do not have unrestricted access to the data. Further, ARN believes
that patients who have been discharged to the community and expire within the
post-discharge window should not be included within the quality measure, given
the variation in patient characteristics across the four settings. For
example, as compared to all Medicare beneficiaries, the SNF and LTCH patient
populations represent the most disabled, elderly, and frail beneficiaries. The
Medicare Payment Advisory Commission’s (MedPAC) March 2015 Report to Congress
found that compared with other beneficiaries, “SNF users are older, frailer,
and disproportionately female, disabled, living in an institution, and dually
eligible for both Medicare and Medicaid.” Moreover, as compared with all
Medicare beneficiaries, those admitted to LTCHs are “disproportionately
disabled (under age 65), over age 85, or diagnosed with [ESRD]. They are also
more likely to be African American.” ARN urges CMS to exclude patients that
pass away within the post-discharge window after being discharged to the
community from the discharge to community quality measure, as the types of
patients treated in each setting greatly varies and can lead to an inaccurate
reflection of the quality of care. ARN is pleased the CMS has proposed
discharge measure exclusions; however, we have concerns with the proposed
exclusion of post-acute stays that end in transfer to the same level of care,
and specifically, CMS’s proposal to include only the final post-acute provider
in the discharge to community measure. The Agency’s proposed exclusion
criteria fails to consider when a patient’s “home” is a custodial nursing
facility and the patient’s post-acute episode involves a discharge back to his
or her “home.” In such circumstances, including the final post-acute provider
in the discharge to community measure when a patient is discharged to the
originating level of care, but in essence, is returning home, may distort the
findings of the quality measure. We encourage CMS to design a quality measure
that is capable of capturing the difference between a patient’s return to his
or her home and a patient’s post-acute episode that involves transfer to the
same level of care. (Submitted by: Association of Rehabilitation
Nurses)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)ARN is supportive of a measure that works to
identify unplanned (re)admissions; however, we have concerns with identifying
unplanned (re)admissions based on the planned readmissions algorithm used in
NQF measure #2510: SNF 30-Day All-Cause Readmission Measure (SNFRM); NQF
#2502: All-Cause Unplanned Readmission Measure for 30 Days Post Discharge from
IRFs; NQF #2512: All-Cause Unplanned Readmission Measure for 30 Days Post
Discharge from LTCHs; and NQF #2380: Re-hospitalization During the First 30
Days of Home Health. The exclusion criteria included within NQF #2510 for SNF
stays where the patient had one or more intervening PAC admissions to an IRF
that occurred either between the prior proximal hospital discharge and SNF
admission or after the SNF discharge within the 30-day risk window fails to
allow for a medically complex patient that is treated in an IRF and readmitted
to the SNF within 30 days for a condition that may initially have been treated
as a comorbidity. We disagree with the rationale provided for exclusion, for
while the measure assesses readmission rates while accounting for patient
demographics, principal diagnosis in the prior hospitalization, comorbidities,
and other patient factors, often, this may not be the reason for admission to
a SNF. ARN believes the measure should include the principal diagnosis during
the prior proximal hospitalization, comorbidities based on the secondary
medical diagnoses listed on the patient’s prior proximal hospital claim and
diagnoses from prior hospitalizations that occurred in the previous 365 days,
length of stay during the patient’s prior proximal hospitalization, length of
stay in the intensive care unit (ICU), body system specific surgical
indicators, End-Stage Renal Disease (ESRD) status, whether the patient was
disabled, and the number of prior hospitalizations in the previous 365 days.
It also would be beneficial to understand the comorbidities being evaluated in
the risk-adjustment model. ARN urges the Centers for Medicare and Medicaid
Services (CMS) to develop of a list of comorbidities, comparable to the IRF
Prospective Payment System (PPS) list of comorbidities and we encourage CMS to
categorize an intervening admission to an IRF as a proximal hospitalization.
Additionally, ARN has serious concerns with CMS’s proposal to require PAC
providers to utilize Medicare claims data to calculate their 30-day
readmission rates. Using claims data to calculate readmission rates is
difficult for health care providers, as claims data are cumbersome to use and
access. Employing a 30-day readmission rate measure will not provide
meaningful insight or have an impact on quality improvement efforts if the PAC
settings do not have unrestricted access to the data. Further, ARN believes
that patients who have been discharged to the community and expire within the
post-discharge window should not be included within the quality measure, given
the variation in patient characteristics across the four settings. For
example, as compared to all Medicare beneficiaries, the SNF and LTCH patient
populations represent the most disabled, elderly, and frail beneficiaries. The
Medicare Payment Advisory Commission’s (MedPAC) March 2015 Report to Congress
found that compared with other beneficiaries, “SNF users are older, frailer,
and disproportionately female, disabled, living in an institution, and dually
eligible for both Medicare and Medicaid.” Moreover, as compared with all
Medicare beneficiaries, those admitted to LTCHs are “disproportionately
disabled (under age 65), over age 85, or diagnosed with [ESRD]. They are also
more likely to be African American.” ARN urges CMS to exclude patients that
pass away within the post-discharge window after being discharged to the
community from the discharge to community quality measure, as the types of
patients treated in each setting greatly varies and can lead to an inaccurate
reflection of the quality of care. ARN is pleased the CMS has proposed
discharge measure exclusions; however, we have concerns with the proposed
exclusion of post-acute stays that end in transfer to the same level of care,
and specifically, CMS’s proposal to include only the final post-acute provider
in the discharge to community measure. The Agency’s proposed exclusion
criteria fails to consider when a patient’s “home” is a custodial nursing
facility and the patient’s post-acute episode involves a discharge back to his
or her “home.” In such circumstances, including the final post-acute provider
in the discharge to community measure when a patient is discharged to the
originating level of care, but in essence, is returning home, may distort the
findings of the quality measure. We encourage CMS to design a quality measure
that is capable of capturing the difference between a patient’s return to his
or her home and a patient’s post-acute episode that involves transfer to the
same level of care. (Submitted by: Association of Rehabilitation
Nurses)
- (Early public comment)We believe that the PAC industry should
embrace measures, such as DTC, that place an emphasis on the ability for
patients to return and stay at home – a central tenant of post-acute care. We
have several comments that will serve as constructive additions to the
development of these measures. We hope that NQF and measure developers will
analyze and consider these comments and how they could improve the DTC measure
development for IRFs. A. THE DISCHARGE TO COMMUNITY MEASURE SHOULD BE
DISTINGUISHED FROM THE 31-DAY POST-DISCHARGE READMISSIONS MEASURES The
measure specification document states that this DTC measure tracks
“patients/residents/persons who are discharged to the community, and do not
have an unplanned (re)admission to an acute care hospital or LTCH on the day
of discharge or in the 31 days following discharge to community, and remain
alive during the 31 days following discharge to community.” Based on this
description, this DTC measure, although not called a “readmissions” measure,
functions as a readmission measure, similar to those post-acute readmissions
measures already in place and being developed under the IMPACT Act (All-cause
Unplanned Readmissions (NQF #2502), and the Potentially Preventable
Readmissions (“PPR”) measures under development), but instead focused on a
subset of a provider’s patient population – Medicare patients that are
discharged to community. If those existing (and soon-to-be implemented)
readmission measures already track the number of people who are readmitted to
a hospital within 30 days after being discharged from the PAC setting either
under an all-cause basis or a potentially preventable basis, and this DTC
measure tracks those patients that are discharged to community and do not have
a “(re)admission to an acute care hospital or LTCH” within the 31 day
timespan, then all of the patients who have an “unfavorable outcome” under the
DTC measure will also and already be captured in at least one, if not both, of
these existing readmissions measures. Instead of using the DTC measure to
track and eventually publicly report on such readmissions, which are already
tracked by the other readmission measures soon to be in place, it would be
more meaningful to track the number of patients who go directly to the
community (numerator) vs. the number of patients expected to go directly to
the community (denominator), regardless of subsequent readmissions. The
proposed DTC measure design is already built around comparing the actual
number of successful discharges to community vs. expected successful
discharges, but our comment here is directed at the definition of what it
means to be “discharged to community.” In other words, if “discharged to
community” means “31 days at home without a readmission,” (as proposed by
measure developers) then this measure effectively becomes a readmission
measure that selectively focuses on those patients who are discharged home – a
population that is already covered both by the All-cause Unplanned
Readmissions measure (NQF #2502) and the proposed 30-day Post-discharge
Potentially Preventable Readmission measure (under development at RTI). If,
on the other hand, “discharged to community” means “patients who are
discharged home without an intervening facility stay” (regardless of a
subsequent readmission), that definition does not unnecessarily overlap with
other readmission measures, thus giving providers and the public a more useful
measure that is distinct from existing measures. B. MEASURE SHOULD REMAIN
LIMITED TO MEDICARE FEE-FOR-SERVICE POPULATION According to the measure
description (specifically Measure Exclusion 7), this measure is only
applicable to Medicare fee-for-service (“FFS”) populations, and not other
payer populations, including Medicare Advantage (“MA”). We support this
exclusive focus on FFS because other payers, including private insurance
companies that contract with the Medicare program to manage MA plans, often
dictate what services IRFs and other PAC providers can offer to their
discharged patients, thereby limiting the ability of such providers to
maximize their efforts to keep people healthy at home following discharge.
This has the potential to negatively impact the ability to optimize
performance on this DTC measure (and other readmission measures). We note
that, while CMS and RTI have made the laudable decision to focus only on
Medicare FFS for this DTC measure, we think this approach should extend to
other measures developed under the IMPACT Act as well. If some IMPACT Act
measures focus solely on Medicare FFS while others cover all patients and all
payers, a significant disconnect in the underlying data will arise. Despite
the logic behind this approach, CMS’ response to the Drug Regimen Review
measure public comments, released last week, indicated support for the
opposite view. In response to comments on that Drug Regimen Review measure
recommending that all PAC settings assess the same populations with the IMPACT
measures and that the denominators be limited to Medicare fee-for-service
enrollees only (since this is the population that is subject to changes in
payment policy under the IMPACT Act), CMS replied saying that it felt that
quality improvements are an appropriate goal for all patients, “regardless of
payer source.” While no one would disagree with this broad statement of
quality improvement across payer populations, this view does not account for
the specific fact that, if a CMS quality measure that is ultimately tied to
Medicare reimbursement measures non-Medicare populations for which PAC
providers are limited (by non-Medicare payers) in post-discharge service
offerings, such a scenario potentially thwarts a providers ability to control
and improve performance on that measure, and could have significant payment or
regulatory implications. C. RISK ADJUSTMENT FOR SOCIODEMOGRAPHIC AND
FUNCTIONAL STATUS The draft specifications indicate that the DTC measure will
be risk-adjusted for multiple variables, including age, sex, dialysis status,
and prior acute care utilization in the past year. We generally support this
broad range of risk adjustment, but also believe that the measure developers
should consider including risk adjustment for additional sociodemographic
factors and functional status as well, such as geographic area (urban/rural)
or percentage of low income patients. Recent academic literature has added
evidence to the notion that readmissions back to hospitals are driven by more
directly by patient status factors and not by the quality of care delivered.
Since this DTC measure, as currently proposed and as argued above, is (in its
current form) effectively a readmissions measure focused on the population of
patients discharged directly to community, we feel that this evidence is also
applicable to this measure, not just the formal readmission measures.
Furthermore, The National Quality Forum (“NQF”) in April began a two-year
trial program of a temporary policy change that would allow risk adjustment of
performance measures for socioeconomic and other demographic factors, a
departure from earlier quality measurement positions that viewed
sociodemographic risk adjustment as inappropriate. With evidence that
sociodemographic risk is real and impact readmission rates, we recommend that
measure developers and NQF consider including it in the list of risk
adjustment factors for these measures. We also believe adjusting for
functional status would benefit the accuracy of the DTC measure. Functional
status has a direct correlation with a patient’s ability to remain healthy at
home after PAC services have ended, meaning that PAC providers who treat more
functionally impaired patients will likely have a higher readmission rate, and
a lower DTC rate. Accordingly, we recommend that NQF and the measure
developers consider how to apply an additional risk-adjustment factor for
functional status in the overall risk adjustment methodology. D. RISK OF
CONFUSION IN MULTIPLE READMISSION MEASURES As part of the existing IRF PPS
Quality Reporting Program (“IRF QRP”), IRFs already report All-cause Unplanned
Readmission (NQF #2502) and are scheduled to have the PPR measure publicly
reported beginning next year, not to mention “within stay” readmissions
measures. Other PAC types will also require public reporting of a general
all-cause readmissions measure. We are concerned that, as required by the
IMPACT Act and various QRP provisions, the eventual public reporting of all of
these measures (which are essentially a subset of the more general all-cause
measures) will result in substantial confusion amongst members of the public.
For example, if both readmissions measures and the DTC measure are all
publicly reported without thorough explanations, PAC providers will have one
all-cause unplanned readmission rate, a separate PPR rate, a separate PPR
“within stay” rate, and a DTC percentage that is measured in the opposite
direction (looking at how many patients stayed home instead of how many
patients were readmitted). As a side comment, we note that it may be more
administratively simple if CMS instead measured DTC as a readmissions measure
for patients discharged to home. That would harmonize this version of a
readmissions rate with the other measures. Nevertheless, we question whether
the crucial distinctions between these different, but related, readmissions
indicators will be readily apparent to members of the public who take the time
to assess different PAC providers based on readmission rates. Similarly,
providers may have trouble accurately understanding the purpose and ultimate
use of additional readmissions indicators. IRF providers already receive
annual PEPPER reports and also report on the All-cause measure (NQF #2502).
With the addition of a “within stay” readmissions measure, a post-discharge
PPR measure, and this DTC measure, we think it would be highly valuable if CMS
were to take deliberate steps to clearly communicate the intended use of and
distinctions between each of these readmission tools, making sure to note and
how they will relate to one another. Without such clarifying communication,
providers may find themselves adrift in various readmissions data without a
clear idea of how it is all being used by the Agency. Lastly, in order to
standardize readmission measures and avoid unnecessary confusion, we ask that
CMS and RTI standardize the language and definitions used in conjunction with
establishing observation windows for all readmissions measures. For example,
the IRF All-Cause Unplanned Readmissions measure (NQF #2502) is measured
beginning two days after the day of discharge for 30 days; this DTC measure
begins one day after the day of discharge for 31 days. These two measures
both end on the same day, but it could help to avoid confusion if these
discharge and observation window definitions and timeframes were standardized.
(Submitted by: HealthSouth)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-411)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
(Program: Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-412)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
(Program: Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-413)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
(Program: Long-Term Care
Hospital Quality Reporting Program; MUC ID: MUC15-414) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The AHA agrees with the MAP’s recommendations for this measure. We are
concerned by the lack of data of the reliability and validity of patient
discharge status codes that would be used in this measure. Given that it is
such a fundamental part of the measure, CMS should conduct such testing and
make the results publicly available. Furthermore, we strongly urge that this
measure be assessed for the impact of sociodemographic factors on performance,
and an adjustment should be incorporated if warranted. (Submitted by:
American Hospital Association (AHA))
- FAH supports the workgroup's recommendation and rationale. FAH shares many
of the workgroup's concerns, particularly the concern about appropriate risk
adjustment and the potential conflict with other readmission measures. We
strongly urge NQF to require developers to explore additional SDS factors
beyond the current variables that are often used in the analysis (e.g., dual
eligible status, race) and ask that MAP make clear recommendations to CMS that
a broader set of variables should be included in the measures submitted for
future consideration. We request that the measure be fully tested before it is
considered for a future payment program. (Submitted by: Federation of American
Hospitals)
- AAPM&R commends NQF for evolving its work to understand how measures
are being developed and implemented across settings and how they impact
payment reform. This is a huge endeavor that AAPM&R stands behind in
concept. However, AAPM&R cautions NQF to ensure their processes and
review of measures are adequately reported back to CMS and other rule-making
entities to ensure the NQF’s measurement expertise is realized in rule making.
While this measure addresses functional improvement , it does not address
the practical value of the measurable improvement or the ability of a patient
to return to the community. For example, a patient with a complete cervical
spinal cord injury or dense hemiplegia from a stroke may not make significant
functional gains (i.e., they may remain dependent in many domains of mobility
and/or activities of daily living). However, with expert and comprehensive
patient and family/care-giver education and training by the rehabilitation
team, the patient may return to the community despite not meeting the
thresholds that are suggested by the quality measures. The Academy believes
that measurement of patient and family engagement with the process of care and
with education and training must be considered in the evaluation of models of
PAC. Another concern is that without factors related to psychosocial and
family financial support in prediction models, changes in function from
admission to discharge do not tell the entire story. The Academy urges CMS to
support the development of quality measures that relate to patient and family
engagement as PAC reform implementation evolves. AAPM&R believes there
needs to be further discussions about psychosocial issues. (Submitted by:
American Academy of Physical Medicine and Rehabilitation )
- ARN is supportive of a measure that works to identify unplanned
(re)admissions; however, we have concerns with identifying unplanned
(re)admissions based on the planned readmissions algorithm used in NQF measure
#2510: SNF 30-Day All-Cause Readmission Measure (SNFRM); NQF #2502: All-Cause
Unplanned Readmission Measure for 30 Days Post Discharge from IRFs; NQF #2512:
All-Cause Unplanned Readmission Measure for 30 Days Post Discharge from LTCHs;
and NQF #2380: Re-hospitalization During the First 30 Days of Home Health.
The exclusion criteria included within NQF #2510 for SNF stays where the
patient had one or more intervening PAC admissions to an IRF that occurred
either between the prior proximal hospital discharge and SNF admission or
after the SNF discharge within the 30-day risk window fails to allow for a
medically complex patient that is treated in an IRF and readmitted to the SNF
within 30 days for a condition that may initially have been treated as a
comorbidity. We disagree with the rationale provided for exclusion, for while
the measure assesses readmission rates while accounting for patient
demographics, principal diagnosis in the prior hospitalization, comorbidities,
and other patient factors, often, this may not be the reason for admission to
a SNF. ARN believes the measure should include the principal diagnosis during
the prior proximal hospitalization, comorbidities based on the secondary
medical diagnoses listed on the patient’s prior proximal hospital claim and
diagnoses from prior hospitalizations that occurred in the previous 365 days,
length of stay during the patient’s prior proximal hospitalization, length of
stay in the intensive care unit, body system specific surgical indicators,
End-Stage Renal Disease (ESRD) status, whether the patient was disabled, and
the number of prior hospitalizations in the previous 365 days. It also would
be beneficial to understand the comorbidities being evaluated in the
risk-adjustment model. ARN urges the Centers for Medicare and Medicaid
Services (CMS) to develop of a list of comorbidities, comparable to the IRF
Prospective Payment System list of comorbidities and we encourage CMS to
categorize an intervening admission to an IRF as a proximal hospitalization.
Additionally, ARN has serious concerns with CMS’s proposal to require PAC
providers to utilize Medicare claims data to calculate their 30-day
readmission rates. Using claims data to calculate readmission rates is
difficult for health care providers, as claims data are cumbersome to use and
access. Employing a 30-day readmission rate measure will not provide
meaningful insight or have an impact on quality improvement efforts if the PAC
settings do not have unrestricted access to the data. Further, ARN believes
that patients who have been discharged to the community and expire within the
post-discharge window should not be included within the quality measure, given
the variation in patient characteristics across the four settings. For
example, as compared to all Medicare beneficiaries, the SNF and LTCH patient
populations represent the most disabled, elderly, and frail beneficiaries. The
Medicare Payment Advisory Commission’s March 2015 Report to Congress found
that compared with other beneficiaries, “SNF users are older, frailer, and
disproportionately female, disabled, living in an institution, and dually
eligible for both Medicare and Medicaid.” Moreover, as compared with all
Medicare beneficiaries, those admitted to LTCHs are “disproportionately
disabled (under age 65), over age 85, or diagnosed with [ESRD]. They are also
more likely to be African American.” ARN urges CMS to exclude patients that
pass away within the post-discharge window after being discharged to the
community from the discharge to community quality measure, as the types of
patients treated in each setting greatly varies and can lead to an inaccurate
reflection of the quality of care. ARN is pleased the CMS has proposed
discharge measure exclusions; however, we have concerns with the proposed
exclusion of post-acute stays that end in transfer to the same level of care,
and specifically, CMS’s proposal to include only the final post-acute provider
in the discharge to community measure. The Agency’s proposed exclusion
criteria fails to consider when a patient’s “home” is a custodial nursing
facility and the patient’s post-acute episode involves a discharge back to his
or her “home.” In such circumstances, including the final post-acute provider
in the discharge to community measure when a patient is discharged to the
originating level of care, but in essence, is returning home, may distort the
findings of the quality measure. We encourage CMS to design a quality measure
that is capable of capturing the difference between a patient’s return to his
or her home and a patient’s post-acute episode that involves transfer to the
same level of care. (Submitted by: Association of Rehabilitation
Nurses)
- Discharge to community is a flawed measure of quality for LTCHs LTCHs are
highly specialized acute care facilities that treat complex and often
critically ill patients who require care for an extended time. As such, an
LTCH must meet Medicare’s conditions of participation for acute care hospitals
and have an average length of stay of more than 25 days. Like short-term care
hospitals (STCHs), LTCHs treat patients requiring critical, acute, or
sub-acute levels of care1 and discharge patients that no longer require such
high levels of care; their goal is not to keep the patient until they are
ready to be discharged to the community. As a result, the discharge to
community measure as currently constructed is not an appropriate measure of
quality for the LTCH setting. After successful LTCH and STCH care, some
patients are discharged to lower levels of care such as skilled nursing
facilities. The discharge to community measure would wrongly treat discharges
to lower, non-acute care settings as unfavorable outcomes although these
discharges are favorable outcomes from the perspective of patients and LTCHs,
which are to discharge patients at the point where acute care is no longer
needed. Just as the discharge to community measure is not used as an
indicator of quality for STCHs, it should not be used as a quality measure for
LTCHs. While we understand the IMPACT Act requires the development of a
discharge to community measure, we urge NQF to consider the role of LTCHs as
acute care hospitals and take a broader perspective that includes discharges
to lower acuity settings and/or discharges to home after a period of time.
Clearly, more time is needed to develop and test an appropriate measure that
does not produce incentives to send patients to the community before it is
medically appropriate to do so. (Submitted by: National Association of Long
Term Hospitals)
- (Early public comment)APTA supports the goal of improving the
quality of health care. Physical therapists are committed to providing
high-quality, timely care and to the promotion of evidence-based and
patient-centered practice. Furthermore, APTA feels that it is essential that
we move towards a common set of quality measures across the continuum of care.
APTA supports the implementation of a discharge to community measure across
the care settings. We believe that successful transitions to the community
following discharge from the respective post-acute care settings will decrease
potentially preventable readmissions. However, the APTA does have some
concerns regarding the proposed measure methodology. These concerns are
discussed below. APTA believes that a patient’s level of function does impact
a patients ability to transition successfully back to the community. Recent
evidence indicates that patient function is associated with increased risk of
30-day all-cause hospital readmissions and may be an important factor in
preventing readmissions for Medicare seniors that is not currently accounted
for in measure methodologies1. APTA was pleased to see “activity of daily
living” scores in the home health setting included in the risk adjustment
methodology for the readmissions measures, and we recently commented,
encouraging the use of patient function in the risk adjustment methodology for
the post-acute care setting readmissions measures. We believe that
readmissions and discharge to community are closely related measures and that
patient function may also be an important risk adjustment variable for
discharge to community. APTA appreciates that CMS has strict deadlines for
the implementation of measures under the IMPACT act, however, as these
measures will be new to the respective post-acute care settings, we encourage
that settings have the ability to review this data as early as possible in
order to understand and, more importantly, so that the respective setting have
time to implement strategies to decrease readmissions where necessary. As
many of these settings do not always receive feedback on the readmissions of
their patients post-discharge, this data will be new to many facilities.
APTA recognizes that the overall goal of IMPACT is for PAC providers (HH,
IRF, SNF and LTCH) to collect and report standardized and interoperable
patient assessment data, quality and resource use measures. We acknowledge
that during the initial IMPACT implementation years that there will be a
transition period which will include the addition of new measures into all of
the post-acute care settings. We believe that achieving a standardized and
interoperable patient assessment data set and stable quality measures as
quickly as possible will allow for better cross-setting comparisons as well as
the evolution of better quality measures with uniform risk standardization,
thus achieving the true aim of IMPACT. 1 Greysen SR, Cenzer IS, Auerbach AD,
Covinsky KE. Functional Impairment and Hospital Readmission in Medicare
Seniors. JAMA Intern Med. 2015;175(4):559-565. (Submitted by: American
Physical Therapy Association )
- (Early public comment)We have the following concerns related to
this measure: 1. The inclusion of unplanned readmissions in the discharge
to community measure development and calculation. Our concerns related to the
inclusion of unplanned readmissions in the discharge to community measure
development and calculation can be defined as follows: a.
Duplication/commingling of quality metrics With the inclusion of unplanned
readmissions in the discharge to community measure development and
calculation, there is the potential for there to be a strong correlation
between the performances of the two measures. In other words, those PAC
providers that perform poorly with the unplanned readmission measure are more
likely to perform poorly on this measure, while those PAC providers that
perform well with the unplanned readmission measure have a better opportunity
to perform well on this measure. Take for instance the scenario of two
facilities with similar patient populations (age, sex, etc.), where provider A
discharges 75% to a community setting with a 5% readmission rate while
provider B discharges 72% to a community setting with a 2% readmission rate.
Which facility performs better at discharging patients to a community setting?
Is the discharge to community measure truly representative of the ability of
the post-acute care provider to provide services that get the patient back to
a community setting, or is too much emphasis being placed upon the ability of
the patient to stay in a community setting? b. Inclusion of a factor
that is outside of post-acute care provider control While a post-acute care
provider can provide services that impact the ability of a patient to be
discharged back to a community setting, whether or not a patient returns to an
acute care facility in the 30 days following that PAC discharge can be
completely unrelated to the services furnished by the PAC provider. For
instance, a patient is discharged home from a post-acute care provider but is
re-admitted to acute care 10 days later for pneumonia (which is listed as a
diagnosis category that cannot be considered planned). Should the post-acute
care provider’s discharge to community percentage be penalized if the
readmission is completely unrelated to the services provided within post-acute
care? With the concerns noted above, we would recommend that the measure
developers remove the unplanned readmission component from the discharge to
community measurement, and provide side-by-side comparison of these two
separate and unique quality measures. 2. Potential for site-specific
risk adjustment for a “cross-setting” measure. While we note that the risk
adjustment variables are “under consideration”, we are very concerned that the
variables noted in the draft specification designate certain variables as
being applicable to unique or specific post-acute care providers. The IMPACT
Act requires the specification of quality measures and resource use metrics
that are standardized and interoperable across PAC settings. In creating a
measure where consideration is being given to risk adjustment variables that
differ by post-acute care setting, is CMS truly meeting the definition of
“standardized and interoperable”? As an example, “Activities of Daily Living”
(ADLs) are noted as one of the Clinical conditions variables, yet is noted for
“the HHA setting only”. If the measure developer can show that ADLs can be
used to differentiate the performance within the HHA population, couldn’t ADLs
also be used to differentiate the performance of all post-acute care settings
and produce a measurement value that is “standardized and interoperable”? We
urge CMS and the measure developers to introduce risk-adjustment variables
that are “standardized and interoperable” in order to meet the IMPACT Act
requirements. (Submitted by: UDSMR)
- (Early public comment)The ultimate goals of post-acute care are
avoiding institutionalization and returning patients to their previous level
of independence and functioning, with discharge to community being the primary
goal for the majority of post-acute patients. For many, home is a symbol of
independence, privacy, and competence. Discharge to community is considered a
valuable outcome to measure because it is a multifaceted measure that captures
the patient’s functional status, cognitive capacity, physical ability, and
availability of social support at home. There is considerable variation in
discharge to community rates within and across post-acute settings. Studies
show geographic variation, variation across patient socioeconomic
characteristics (for example, race and ethnicity), and variation by facility
characteristics (for profit vs. nonprofit, freestanding vs. hospital-based,
urban vs. rural). In the IRF setting, discharge to community rates vary across
providers, ranging from about 60% to 75%. The 2015 MedPAC report shows that,
in FY 2013, the facility-level, mean risk-adjusted discharge to community rate
for IRFs within 100 days of admission was 75.8%, and the mean observed rate
was 74.7%. Discharge to community rates also vary widely in the SNF setting,
ranging from as low as 31% to as high as 65%. The 2015 MedPAC report shows a
mean risk-adjusted discharge to community rate of 37.5% for SNFs within 100
days of admission, and mean observed rate of 40.1%. A multicenter study of 23
LTCHs reported that only 28.8% of 1,061 patients who were ventilator-dependent
on admission were discharged to home or assisted living facility. A study of
66,510 Medicare beneficiaries during pre- and post-HH episodes, revealed that
64 percent of beneficiaries discharged from HH did not use any other
Medicare-reimbursed acute or post-acute services in the 30 days following HH
discharge. Significant numbers of patients were admitted to inpatient
facilities (29percent) and lesser numbers to skilled nursing facilities (7.6
percent), inpatient rehabilitation (1.5 percent) and home health (7.2 percent)
or hospice (3.3 percent) within 30 days of HH discharge (Wolff et al., 2008).
II. Feedback Overall, there is not enough detail on the measure
specifications to provide adequate feedback. However, despite the lack of
detail, a response is included below on the discharge to community measure for
LTCH, IRF, SNF, and HH. Description Patients discharged to the community
following PAC stay/episode and do not have an unplanned admission to an acute
care hospital or LTCH in 31 days after community discharge and remain alive
• Although not explicitly stated, it appears that this measure is only holding
the last PAC setting responsible for the discharge? Given what is known about
multiple sites of PAC use either from LTCH/IRF patients are often discharged
to SNF before community discharge, as it is currently worded this measure will
penalize the SNF for the more difficult patients that could not be discharged
from the prior PAC setting. • Research has shown that PAC patients re-enter
the healthcare system through multiple doors after the PAC community
discharge why are these not captured in the measure as a failed transition I
recommend that the numerator should not include individuals who were admitted
to a SNF after PAC community discharge during the 30-day measure window.
Numerator & Denominator There is not enough detail to provide feedback on
the risk adjustment of the numerator. Without details on the variables
included, the origin of those variables, and methods of risk adjustment it is
difficult to provide feedback. Recommend providing further detail. Recommend
including functional status, functional cognition, presence of social support
(e.g., does the individual live alone), and comorbid conditions as risk
adjustors Exclusion There is no discussion of excluding long-stay nursing home
residents in this measure. Long-stay residents that have an acute medical
event, are admitted to an acute care hospital, discharged to PAC for care, and
then transitioned back to long-term care should be excluded from the measure.
These individuals are not returning to the community, while the nursing home
is their home, the effort and processes required for transitioning a long-stay
nursing home resident from PAC back to custodial care is very different that
transitioning a community- residing older adult back to their residence in the
community after a PAC stay. Recommend excluding long stay nursing home
residents from the measure. (Submitted by: American Occupational Therapy
Association)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)ARN is supportive of a measure that works to
identify unplanned (re)admissions; however, we have concerns with identifying
unplanned (re)admissions based on the planned readmissions algorithm used in
NQF measure #2510: SNF 30-Day All-Cause Readmission Measure (SNFRM); NQF
#2502: All-Cause Unplanned Readmission Measure for 30 Days Post Discharge from
IRFs; NQF #2512: All-Cause Unplanned Readmission Measure for 30 Days Post
Discharge from LTCHs; and NQF #2380: Re-hospitalization During the First 30
Days of Home Health. The exclusion criteria included within NQF #2510 for SNF
stays where the patient had one or more intervening PAC admissions to an IRF
that occurred either between the prior proximal hospital discharge and SNF
admission or after the SNF discharge within the 30-day risk window fails to
allow for a medically complex patient that is treated in an IRF and readmitted
to the SNF within 30 days for a condition that may initially have been treated
as a comorbidity. We disagree with the rationale provided for exclusion, for
while the measure assesses readmission rates while accounting for patient
demographics, principal diagnosis in the prior hospitalization, comorbidities,
and other patient factors, often, this may not be the reason for admission to
a SNF. ARN believes the measure should include the principal diagnosis during
the prior proximal hospitalization, comorbidities based on the secondary
medical diagnoses listed on the patient’s prior proximal hospital claim and
diagnoses from prior hospitalizations that occurred in the previous 365 days,
length of stay during the patient’s prior proximal hospitalization, length of
stay in the intensive care unit (ICU), body system specific surgical
indicators, End-Stage Renal Disease (ESRD) status, whether the patient was
disabled, and the number of prior hospitalizations in the previous 365 days.
It also would be beneficial to understand the comorbidities being evaluated in
the risk-adjustment model. ARN urges the Centers for Medicare and Medicaid
Services (CMS) to develop of a list of comorbidities, comparable to the IRF
Prospective Payment System (PPS) list of comorbidities and we encourage CMS to
categorize an intervening admission to an IRF as a proximal hospitalization.
Additionally, ARN has serious concerns with CMS’s proposal to require PAC
providers to utilize Medicare claims data to calculate their 30-day
readmission rates. Using claims data to calculate readmission rates is
difficult for health care providers, as claims data are cumbersome to use and
access. Employing a 30-day readmission rate measure will not provide
meaningful insight or have an impact on quality improvement efforts if the PAC
settings do not have unrestricted access to the data. Further, ARN believes
that patients who have been discharged to the community and expire within the
post-discharge window should not be included within the quality measure, given
the variation in patient characteristics across the four settings. For
example, as compared to all Medicare beneficiaries, the SNF and LTCH patient
populations represent the most disabled, elderly, and frail beneficiaries. The
Medicare Payment Advisory Commission’s (MedPAC) March 2015 Report to Congress
found that compared with other beneficiaries, “SNF users are older, frailer,
and disproportionately female, disabled, living in an institution, and dually
eligible for both Medicare and Medicaid.” Moreover, as compared with all
Medicare beneficiaries, those admitted to LTCHs are “disproportionately
disabled (under age 65), over age 85, or diagnosed with [ESRD]. They are also
more likely to be African American.” ARN urges CMS to exclude patients that
pass away within the post-discharge window after being discharged to the
community from the discharge to community quality measure, as the types of
patients treated in each setting greatly varies and can lead to an inaccurate
reflection of the quality of care. ARN is pleased the CMS has proposed
discharge measure exclusions; however, we have concerns with the proposed
exclusion of post-acute stays that end in transfer to the same level of care,
and specifically, CMS’s proposal to include only the final post-acute provider
in the discharge to community measure. The Agency’s proposed exclusion
criteria fails to consider when a patient’s “home” is a custodial nursing
facility and the patient’s post-acute episode involves a discharge back to his
or her “home.” In such circumstances, including the final post-acute provider
in the discharge to community measure when a patient is discharged to the
originating level of care, but in essence, is returning home, may distort the
findings of the quality measure. We encourage CMS to design a quality measure
that is capable of capturing the difference between a patient’s return to his
or her home and a patient’s post-acute episode that involves transfer to the
same level of care. (Submitted by: Association of Rehabilitation
Nurses)
- (Early public comment)LTCHs are highly specialized acute care
facilities that treat complex and often critically ill patients who require
care for an extended time. As such, an LTCH must meet Medicare’s conditions
of participation for acute care hospitals and have an average length of stay
of more than 25 days. Like short-term care hospitals (STCHs), LTCHs treat
patients requiring critical, acute, or sub-acute levels of care1 and discharge
patients that no longer require such high levels of care. As acute care
hospitals, LTCHs’ goal is to discharge patients to the appropriate care
setting when they no longer need treatment at the acute care level; their goal
is not to keep the patient until they are ready to be discharged to community.
As a result, the discharge to community measure as currently constructed is
not an appropriate measure of quality for the LTCH setting. After successful
LTCH and STCH care, some patients are discharged to lower levels of care such
as skilled nursing facilities. The discharge to community measure would
wrongly treat discharges to lower, non-acute care settings as unfavorable
outcomes although these discharges are favorable outcomes from the perspective
of patients and LTCHs, which are to discharge patients at the point where
acute care is no longer needed. Just as the discharge to community measure is
not used an indicator of care quality for STCHs, it should not be used as a
quality measure for LTCHs. While we understand the IMPACT Act requires the
development of a discharge to community measure, we urge the measure
development team consider the role of LTCHs as acute care hospitals and take a
broader perspective that includes discharges to lower acuity settings and/or
discharges to home after a period of time. Clearly, more time is needed to
develop and test an appropriate measure that does not produce incentives to
send patients to the community before it is medically appropriate to do so.
(Submitted by: National Association of Long Term Hospitals)
(Program: Merit-Based Incentive
Payment System (MIPS); MUC ID: MUC15-415) |
- CAPC supports the MAP’s recommendation “Support” for the inclusion of
MUC15-415 in the Merit-Based Incentive Payment System (MIPS). As MIPS is a
brand new quality reporting program that will begin implementation in 2017,
NQF and CMS have a unique opportunity to ensure that the opening slate of
measures captures the quality of care delivered to patients across the
spectrum of illness. This holds especially true for the care provided to the
most seriously ill and vulnerable patients in the system through palliative
care and hospice. Research demonstrates that cancer patients often receive
late referrals to hospice (Diamond et al., 2016, and McCarthy et al., 2003),
and subsequently do not accrue many of the benefits associated with hospice
such as the relief of suffering and increased patient and family/caregiver
satisfaction (Teno et al., 2007). Therefore, it is important to capture
appropriate hospice utilization in cancer patients. More broadly, however, the
problem with short hospice length of stay is not limited to cancer;
approximately 35.5 percent of hospice patients dying or being discharged
within seven days of referral to hospice (NHPCO, 2015). Given this, we
encourage CMS and NQF to explore additional quality measures that look at the
timing of palliative care referral (Scibetta et al., 2016) and hospice
length-of-stay for all seriously ill patients referred to hospice, regardless
of diagnosis. (Submitted by: Center to Advance Palliative Care)
- TESTING ACROSS PAYERS AND AGES (Submitted by: Children's Hospital
Association)
- The Oncology Nursing Society (ONS) is a professional association of more
than 37,000 members committed to promoting excellence in oncology nursing. We
fully support the measure and the MAP preliminary recommendation. (Submitted
by: Oncology Nursing Society)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: American College
of Surgeons)
- Measure: Proportion admitted to hospice for less than 3 days – Percentage
of patients who died from cancer, and admitted to hospice and spent less than
3 days there. The Carolinas Center appreciates the attention to the late
referrals that hospices are seeing. The national median length of stay is less
than 18 days. This is a disservice to patients and families as well as to
hospices. Having only a few days of service means that more time is spent on
processes such as admission paperwork, DME setup and pharmacy orders than on
actual patient care. Longer lengths of stay are so important to give the
patient and family time to develop a rapport with staff and to obtain the full
benefit of hospice care from the full interdisciplinary team. MAP’s rationale
pointed out many benefits to having hospice including lower utilization of
hospitalization and invasive procedures as well as the realization of cost
savings. We agree with MAP’s suggestion that a longer timeframe would be
better. We recommend that this measure timeframe is lengthened to at least 7
days and preferably to 14 days. This would help encourage earlier referrals so
that hospice is not doing so much crisis care. Additionally, MAP and CMS have
stated that visits during the last week of life are important so it seems more
appropriate to encourage oncologists to make those referrals in a timely
manner so patients can have at least a 7-day stay. It could be beneficial to
correlate the timing of referral to hospice with the timing of oncologic
interventions such as chemotherapy to gauge how aggressive physicians are up
until the time of referral to hospice. Just as MAP did, we recommend that
this measure be extended to other provider types, including, but not limited
to, cardiology and pulmonology. Hospices see brink of death referrals from all
provider types, not just oncologists. All patients with advanced illness need
to be screened for hospice referral so this should include all physician
types. Having this type data on various providers could allow hospices to
target their education and outreach efforts to those providers with lower
scores. (Submitted by: The Carolinas Center)
- We applaud MAP for supporting this measure and recognizing that the
timeframe perhaps should be extended as well as recognizing the value of this
type of measure with patients who have a diagnosis other than cancer.
(Submitted by: National Association for Home & Hospice Care)
- We applaud MAP for supporting this measure and recognizing that the
timeframe perhaps should be extended as well as recognizing the value of this
type of measure with patients who have a diagnosis other than cancer.
(Submitted by: The Home Care & Hospice Association of New
Jersey)
- We applaud MAP for supporting this measure and recognizing that the
timeframe perhaps should be extended as well as recognizing the value of this
type of measure with patients who have a diagnosis other than cancer.
(Submitted by: Ohio Council for Home Care & Hospice)
- NPHI commends the American Society of Clinical Oncology for proposing a
measure that holds providers accountable for coordinating their patients’ care
across the care continuum to their last days of life, however NPHI contends
that this measure falls short of adequately capturing timely referral to end
of life hospice care. The timeframe of three days is not only insufficient for
patients to receive appropriate hospice care to meet and address patient and
family needs, but also inconsistent with Conditions of Participation
regulations that allow a timeframe of five days from hospice admission for a
comprehensive assessment. Any time frame should, at minimum, ensure that each
hospice patient receive a comprehensive assessment and sufficient time
thereafter to address patient needs during their last stage of life.
Furthermore, the need for timely care coordination to hospice services is not
limited to cancer patients. NPHI values the recognition of care coordination
and accountability of providers to coordinate patients’ referral to hospice,
and believes such measures will stimulate earlier discussions and ultimate
referrals to hospice care that will improve patient quality of life, which
should not be limited to oncology. The pattern of late referral to hospice
occurs unnecessarily across a range of chronic illnesses, including COPD,
liver disease, etc. Thus the application of this proposed measure should be
broadened in scope to encompass essentially all chronic advanced illness. As
efforts to better coordinate patient care across specialties and throughout a
patient’s continuum of care progress, appropriate accountability measures will
become increasingly important to develop. (Submitted by: National Parternship
for Hospice Innovation (NPHI))
- AAHPM supports this measure, which aims to achieve earlier referrals to
hospice. However, we are concerned about a potential unintended
consequence—that physicians may be discouraged from referring actively dying
patients to hospice if they are penalized for them when they die within 3
days. There are 2 ways to perform well on this measure: 1) refer patients to
hospice at the appropriate time; or 2) never refer patients to hospice. While
we believe there is an immediate need for this measure, an even better measure
for future consideration would pair this one with the percentage of cancer
patients who receive any hospice care before they die (i.e. simultaneously
evaluate overall utilization of hospice among that population). Another
option would be to consider a longer period as the proper time for a patient
with cancer to receive hospice services. Furthermore, the measure developer
should consider excluding actively dying patients who do not want the hospital
to be their place of death. These patients should be discharged with hospice,
even if they die with 3 days or less (as would be expected). We would not
want to commit these patients to an undesired hospital death due to this
measure. Also, while it is important to capture appropriate hospice
utilization in cancer patients, the problem with short hospice length of stay
is not limited to cancer. Approximately 35.5 percent of hospice patients dying
or being discharged within seven days of referral to hospice (NHPCO, 2015).
Given this, we encourage CMS and NQF to explore additional quality measures
that look at the timing of palliative care referral (Scibetta et al., 2016)
and hospice length-of-stay for all seriously ill patients referred to hospice,
regardless of diagnosis. (Submitted by: American Academy of Hospice and
Palliative Medicine)
- (Early public comment)The measure is appropriate and it will
stimulate earlier discussion and referral to hospice services for persons with
advanced cancer, thereby improving their quality of care and helping lighten
the burden for their caregivers. However, the problem of very late referral
to hospice care is not limited to oncology alone. Rather, this pattern is
seen with a broad array of chronic illness, including COPD, liver disease,
etc. Thus the application of this proposed measure should be broadened in
scope to encompass essentially all chronic advanced illness; anything less
implies that the problem is far more limited in is scope than reality reveals.
(Submitted by: The Coalition to Transform Advanced Care)
- (Early public comment)This MIPS measure is very good. Hospices have
reported seeing an uptick in late oncology referrals as payment policies have
changed. We recommend that it be considered for broader utilization by other
provider types, for causes of death other than cancer, and the length of stay
be extended to a longer timeframe. Earlier referral to hospice means
end-of-life pain and symptoms can be aggressively addressed and crises, such
as hospitalizations, can be avoided. (Submitted by: National Association for
Home Care & Hospice (NAHC))
- (Early public comment)This MIPS measure is very good. Hospices have
reported seeing an uptick in late oncology referrals as payment policies have
changed. We recommend that it be considered for broader utilization by other
provider types, for causes of death other than cancer, and the length of stay
be extended to a longer timeframe (at least 10 days). Earlier referral to
hospice means end-of-life pain and symptoms can be aggressively addressed and
crises, such as hospitalizations, can be avoided. (Submitted by: The Home Care
& Hospice Association of New Jersey)
- (Early public comment)This MIPS measure is very good. Hospices have
reported seeing an uptick in late oncology referrals as payment policies have
changed. We recommend that it be considered for broader utilization by other
provider types, for causes of death other than cancer, and the length of stay
be extended to a longer timeframe. Earlier referral to hospice means
end-of-life pain and symptoms can be aggressively addressed and crises, such
as hospitalizations, can be avoided. (Submitted by: Ohio Council for Home Care
& Hospice)
(Program: Merit-Based Incentive
Payment System (MIPS); MUC ID: MUC15-420) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-423)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
(Program: Merit-Based Incentive
Payment System (MIPS); MUC ID: MUC15-424) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- (Early public comment)This measure is currently being field tested,
has never been submitted to NQF and thus is not NQF-endorsed (Submitted by:
AdvaMed)
(Program: Merit-Based Incentive Payment System (MIPS);
MUC ID: MUC15-434) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The MAP should remove this measure. The measure was removed from
consideration by CMS on 12/1/2015. Thank you. (Submitted by: American
Urogynecologic Society)
- (Early public comment)American Urogynecologic Society believes this
is a valuable measure because the use of bulking agents should be utilized in
appropriate patients with Intrinsic Sphincter Deficiency. (Submitted by:
American Urogynecologic Society)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)This is not an outcome measure. (Submitted
by: American College of Obstetricians and Gynecologists)
(Program: Merit-Based Incentive
Payment System (MIPS); MUC ID: MUC15-436) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- It is unclear how Use of a Mesh is an actual outcome - it seems to be more
of a process of care. Perhaps it would be more useful to track the outcomes
of patients in whom the mesh was placed. (Process/protocol/procedure vs.
outcome/result) (Submitted by: American Medical Group Association -
KF)
- AUGS appreciates the MAP's interest in this measure. We encourage the MAP
to provide continued support for this measure. With the recent
up-classification of vaginal mesh to FDA Category III (FDA Statement released
January 4, 2016;
http://www.fda.gov/NewsEvents/Newsroom/PressAnnouncements/ucm479732.htm?source=govdelivery&utm_medium=email&utm_source=govdelivery),
this is the type of measure that NQF should be interested in. It is the only
measure on the list related to the use of vaginal mesh. Reporting is reliable;
there are unique CPT codes for both posterior compartment surgeries and pelvic
mesh. Please see systematic review demonstrating posterior repair with mesh is
not effective (Surgery for posterior vaginal wall prolapse
(http://www.ncbi.nlm.nih.gov/pubmed/24142058). (Submitted by: American
Urogynecologic Society)
- (Early public comment)American Urogynecologic Society believes
implementation of this measure will determine if best care practices are being
followed when treating women with disorder. (Submitted by: American
Urogynecologic Society)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)The American College of Obstetricians and
Gynecologists supports this measure. It should reduce complications and costs
without sacrificing positive outcomes for patients. (Submitted by: American
College of Obstetricians and Gynecologists)
(Program: Merit-Based Incentive Payment System
(MIPS); MUC ID: MUC15-437) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- AUGS appreciates the MAP's interest in this measure. We encourage the MAP
to provide continued support for this measure. AUGS is currently working on
identifying the gap and is currently testing. This is a measure that is
needed. More than half of hysterectomies in this country are still done via
open laparotomy (in fact, over 90% are being done laparoscopically). This
measure is designed to encourage surgeons to think about the surgical route.
A Canadian review shows evidence that vaginal route is preferred (SOGC
clinical guidelines. Hysterectomy;
http://www.ncbi.nlm.nih.gov/pubmed/12196887). Please also see the United
Healthcare January 2015 bulletin
(https://www.unitedhealthcareonline.com/ccmcontent/ProviderII/UHC/en-US/Assets/ProviderStaticFiles/ProviderStaticFilesPdf/News/January_2015_Network_Bulletin.pdf).
(Submitted by: American Urogynecologic Society )
- (Early public comment)American Urogynecologic Society believes this
is a valuable measure because vaginal hysterectomy has been shown to be the
safest method of hysterectomy. (Submitted by: American Urogynecologic
Society)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)The American College of Obstetricians and
Gynecologists supports this measure. It should drive use of minimally
invasive surgical procedures and avoids overuse of robotic surgery.
(Submitted by: American College of Obstetricians and
Gynecologists)
(Program: Merit-Based
Incentive Payment System (MIPS); MUC ID: MUC15-439) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- AUGS appreciates the MAP's interest in this measure. We encourage the MAP
to provide continued support for this measure. The AUGS quality committee
continues to work on this measure. We look forward to having future
discussions with NQF and CMS on potentially including this measure in the 2017
rule. (Submitted by: American Urogynecologic Society)
- (Early public comment)American Urogynecologic Society believes this
is a valuable measure because it will help ensure that patients who do have a
uterine malignancy are diagnosed prior to colpocleisis. (Submitted by:
American Urogynecologic Society)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)This measure represents good practice in
gynecology. (Submitted by: American College of Obstetricians and
Gynecologists)
(Program: Merit-Based Incentive Payment System (MIPS); MUC
ID: MUC15-440) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- AUGS appreciates the MAP's interest in this measure. We encourage the MAP
to provide continued support for this measure. The AUGS quality committee
continues to work on this measure. We look forward to having future
discussions with NQF and CMS on potentially including this measure in the 2017
rule. (Submitted by: American Urogynecologic Society)
- (Early public comment)American Urogynecologic Society believes it
is important to ensure that patients are offered the opportunity to pursue
conservative management prior to surgery, as assessed in this measure.
(Submitted by: American Urogynecologic Society)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)This measure represents good practice in
gynecology. (Submitted by: American College of Obstetricians and
Gynecologists)
(Program: Merit-Based Incentive Payment System (MIPS); MUC
ID: MUC15-441) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- AUGS appreciates the MAP's interest in this measure. We encourage the MAP
to provide continued support for this measure. The AUGS quality committee
continues to work on this measure. We look forward to having future
discussions with NQF and CMS on potentially including this measure in the 2017
rule. (Submitted by: American Urogynecologic Society)
- (Early public comment)While written comments were not provided, the
commenter indicated their support for this measure in this program. (Submitted
by: American Urological Association)
- (Early public comment)American Urogynecologic Society believes
current guidelines issued by the American Urologic Association that state that
behavioral therapies (e.g., bladder training, bladder control strategies,
pelvic floor muscle training, fluid management) should be first line therapy,
as assessed in this measure. (Submitted by: American Urogynecologic
Society)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)This measure represents good practice in
gynecology. (Submitted by: American College of Obstetricians and
Gynecologists)
(Program: Merit-Based Incentive Payment System (MIPS); MUC
ID: MUC15-450) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The Society of Gynecologic Oncology appreciates the MAP’s interest in this
measure and would like to address the opportunity for improvement in patient
care with this measure. In 2015, there was a paper published by Wright, et
al in the Journal of Clinical Oncology entitled, “Use and Effectiveness of
Intraperitoneal Chemotherapy for Treatment of Ovarian Cancer.” This paper
discusses how the use of IP chemotherapy has plateaued at about 50% since
2007-08 despite continued evidence of long-term benefit. Therefore, a quality
measure regarding its usage would ensure that the patients, who are currently
not receiving this therapy, do. There is room for improvement. The value of
IP chemotherapy was again reinforced by a recent paper by Tewari, et al in the
May 2015 edition of the Journal of Clinical Oncology entitled, “Long-term
survival advantage and prognostic factors associated with intraperitoneal
chemotherapy treatment in advanced ovarian cancer: a gynecologic oncology
group study,” demonstrating survival advantages extending beyond 10 years,
thus the SGO strongly believes there is opportunity with a quality measure to
ensure patient access. SGO appreciates the support from the MAP to encourage
continued development of this measure and we plan to run analysis /evidence
review of the specific number of days in the literature and will have that
done in the next few months. (Submitted by: Society of Gynecologic
Oncology)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-452)
|
- It has been a decade since MIS has been shown to be equivalent from a
survival standpoint, and superior from a patient/recovery standpoint, for
patients with endometrial cancer. There remains massive variation in the
utilization of MIS - this measure is long overdue. (Submitted by: Mayo
Clinic)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- We support inclusion of this measure for consideration in MIPS. While not
NQF-endorsed, as noted in Appendix B, Measure Rationales, there is strong,
peer reviewed, published evidence of the clinical and economic benefits of the
minimally invasive approach for hysterectomy procedures. Quality measures
which encourage the adoption of MIS for appropriate patients represents an
opportunity to improve outcomes and reduce costs. We further encourage the
consideration of adopting as quality measures the proportion of MIS for other
procedures where there exists strong evidence of MIS clinical benefits for
consideration under MIPS and other CMS quality programs. (Submitted by:
Medtronic)
- The Society of Gynecologic Oncology appreciates the MAP’s interest in this
measure and would like to address the opportunity for improvement in patient
care with this measure and also provide an update regarding testing and
endorsement through the National Quality Forum (NQF). A recent paper
published by Fader, et al in Obstet Gynecol. 2016 Jan;127(1):91-100, concluded
that hospital utilization of minimally invasive surgery for the treatment of
endometrial cancer varies considerably in the United States, representing a
disparity in the quality and cost of surgical care delivered nationwide. The
study found that only 50% of those patients that were candidates for minimally
invasive surgery were receiving it. While this study was performed with 2011
data, this same group of authors is currently working on a similar study with
more recent data and is again finding an opportunity for quality improvement
/measure gap of 50%. This measure is currently being tested for reliability
and validity using the SGO Clinical and Outcomes Research Registry and chart
review at 7 sites. The testing will be completed by February 29, 2016 and the
SGO is planning to submit this measure to the NQF Call for Surgical Measures
due on May 30, 2016. Therefore, the SGO requests that the MAP update its
recommendation for this measure from “Encourage Continued Development” to
“Conditional Approval, pending NQF endorsement,” and that this measure be
included in the quality measure portion of the MIPS program for 2017 given
that there are currently no specific measures regarding quality of care for
the treatment of women with gynecologic cancer in the list of measures for the
PQRS program and that this measure will have been tested and in use for 2017.
(Submitted by: Society of Gynecologic Oncology)
- (Early public comment)We strongly support inclusion of this measure
for consideration in MIPS and other CMS quality programs. The clinical and
economic value of minimally invasive surgery for appropriate patients is very
well documented in peer reviewed literature as noted in Appendix B, Measure
Rationales. Quality measures which encourage the adoption of MIS for
appropriate patients represent an opportunity to improve outcomes, reduce
costs, and reduce variability of care. We encourage review of “Hospital level
under-utilization of minimally invasive surgery in the United States:
retrospective review” BMJ 2014;349:g4198 doi: 10.1136/bmj.g4198 (Published 8
July 2014) and “Hospital Cost Implications of Increased Use of Minimally
Invasive Surgery” Published Online: March 25, 2015.
doi:10.1001/jamasurg.2014.4052 as this measure is considered. (Submitted by:
Medtronic)
- (Early public comment)Quality measures which encourage the adoption
of minimally invasive surgery (MIS) for appropriate patients represents an
opportunity to improve outcomes and reduce costs. However, this measure has
never been submitted to NQF for evaluation/endorsement. We support inclusion
of this measure – only pending future NQF-endorsement -- for consideration in
MIPS. (Submitted by: AdvaMed)
- (Early public comment)The American College of Obstetricians and
Gynecologists supports this measure. It should drive use of minimally
invasive surgical procedures . (Submitted by: American College of
Obstetricians and Gynecologists)
- (Early public comment)We support inclusion of this measure for
consideration in MIPS. While not NQF-endorsed, as noted in Appendix B,
Measure Rationales, there is strong, peer reviewed, published evidence of the
clinical and economic benefits of the minimally invasive approach for
hysterectomy procedures. Quality measures which encourage the adoption of MIS
for appropriate patients represents an opportunity to improve outcomes and
reduce costs. We further encourage the consideration of adopting as quality
measures the proportion of MIS for other procedures where there exists strong
evidence of MIS clinical benefits for consideration under MIPS and other CMS
quality programs. (Submitted by: Medtronic)
(Program: Merit-Based Incentive Payment System (MIPS); MUC
ID: MUC15-454) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The Society of Gynecologic Oncology greatly appreciates continued support
for this measure and looks forward to working with the NQF and CMS in its
continued development and inclusion in MIPs for 2017 – and if not 2017, then
2018. (Submitted by: Society of Gynecologic Oncology)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)This measure represents good practice in
gynecology. (Submitted by: American College of Obstetricians and
Gynecologists)
(Program: Merit-Based Incentive Payment System
(MIPS); MUC ID: MUC15-459) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The Society of Gynecologic Oncology greatly appreciates continued support
for this measure and looks forward to working with the NQF and CMS in its
continued development and inclusion in MIPs for 2017 – and if not 2017, then
2018. (Submitted by: Society of Gynecologic Oncology)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)This measure represents good practice in
gynecology. (Submitted by: American College of Obstetricians and
Gynecologists)
(Program: Merit-Based Incentive Payment System (MIPS); MUC
ID: MUC15-460) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- Exclusions include patients receiving “palliative radiation.” We request
that developers define what "palliative" means in this scenario. (Submitted
by: American Academy of Hospice and Palliative Medicine)
- The Society of Gynecologic Oncology appreciates the MAP’s interest in this
measure and would like to address the opportunity for improvement in patient
care with this measure. We appreciate the MAP’s understanding of the SGO’s
rationale for proposing this measure and understanding the deficiencies in the
performance of brachytherapy and the poor clinical outcomes associated with
the lack thereof for cervical cancer patients. Therefore, the SGO believes
that the MAP should provide for conditional support of this measure which the
SGO is planning on testing during the late spring/summer of 2016. We
appreciate the encouragement of continued development of this measure.
However, given the direct correlation to survival and the lack of access for
patients, the SGO requests that the MAP update its recommendation for this
measure from “Encourage Continued Development” to “Conditional Support,
pending testing ” and that this measure be included in the quality measure
portion of the MIPS program for 2017 given that there are currently no
specific measures regarding quality of care for the treatment of women with
gynecologic cancer in the list of measures for the PQRS program and that this
measure will have been tested and in use for 2017. (Submitted by: Society of
Gynecologic Oncology)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)This measure represents good practice in
gynecology. (Submitted by: American College of Obstetricians and
Gynecologists)
(Program: Merit-Based Incentive Payment System (MIPS); MUC
ID: MUC15-461) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The Society of Gynecologic Oncology appreciates the MAP’s interest in this
measure and would like to address the opportunity for improvement in patient
care with this measure. Regarding the MAP’s comments on the number of days
stated in this measure, the recommendation for 60 days is based on the
references provided in the SGO’s rationale to CMS for this measure. Though
the range varies from 56 days to 60 days, the general consensus from the
Society of Gynecologic Oncology (SGO), Radiation Therapy Oncology Group (RTOG)
and Commission on Cancer (COC) uses the target of 60 days. In the current
body of literature, starting with studies ranging from the 1990s to the
current decade continue to have a group of patients that do not complete
radiation within the 56-60 day target (Song, Yalman, Perez). Therefore, it is
an area that continues to have “non-compliance” and demonstrates gap for
improvement. This area continues to be an area of interest and there will be
an abstract presented at this year’s annual SGO meeting (Abstract 6231:
Primary chemo radiation for the treatment of locally advanced cervical cancer:
Impact of treatment location and time on outcomes.). This abstract focuses
both on the importance of time to completion as well as the treatment
location. Lastly, this measure supports coordination of care between
gynecologic oncologists and radiation oncologists for the treatment of this
group of patients. As the data shows that failure to complete radiation
within the 60 day time period has a direct impact on overall patient survival.
The SGO supports the continued development of this measure and believes that
it should have conditional support assuming it is tested before 2017.
(Submitted by: Society of Gynecologic Oncology)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program: Skilled Nursing
Facility Quality Reporting System; MUC ID: MUC15-462) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. AHCA is pleased to have the opportunity to comment on the MAP
Preliminary Decisions and MAP Draft Report ”. Thank you again for the
opportunity to provide these comments. Please contact me at DGifford@ahca.org
with any questions or for additional information. We support the MAP’s
preliminary decision to “encourage continued development” of this measure.
However, in the draft report, the MAP must clearly state that encouraging
continued development of this measures should not be taken as support of
inclusion of this measure in the SNF QRP. We also think the report needs to
include the comments and recommendations made by the MAP workgroup on each
measure since that is the primary role of the MAP to provide DHHS with
feedback on the MUC list and DHHS needs to respond to those comments in any
proposed rule. Without inclusion of these comments, if DHHS decided to
implement this measure for rule making via the Federal Register process, CMS
does not need to provide a rationale for their decision. Additionally, for the
sake of transparency and enhanced stakeholder feedback the draft report should
include the specific public comments submitted. Our specific comments on this
measure are as follows. A preliminary draft yet incomplete specifications for
this measure were provided by CMS for public comment, with the deadline for
comment being December 8th 2015, which is after the MUC list was published. No
information on reliability or validity of the measure is available and the
risk adjustment methodology is not fully specified. This lack of information
makes it difficult for stakeholder to appropriately comment on this measure.
Additionally, based on information available, we have the following concerns
with measure MUC15-462. 1. The name of the measure should reflect the limited
population to which it applies – fee-for service (FFS) Medicare beneficiaries.
Since in many states, 40% or more of Medicare beneficiaries are enrolled in
Medicare Advantage (MA) plans and for SNFs over half of SNF admissions and
discharges are not enrolled in FFS Medicare, this measure may not reflect a
SNF’s true discharge to community rate. 2. Since the determination of
discharge to the community is self-reported on the claims, we suggest the use
of PAC assessment tools as the source of data on discharge to the community,
which will allow the inclusion of additional Medicare Beneficiaries enrolled
in MA plans. The use of the PAC assessment instruments is consistent with the
intent of IMPACT act. 3. The measure does not exclude individuals admitted to
a SNF for Part A services but who have an expressed goal to remain in the SNF
for long term care and never be discharged back to the community. In fact,
when we have compared discharge to community rates as a relationship to the
turnover of patients in Part A beds, those SNFs with low turnover that are
consistent with being primarily long term care facilities have very low
discharge to community rates while SNFs with higher turnover of beds, have
higher discharge to community rates. 4. The denominator definition places
SNFs at a disadvantage when comparing discharges to community for other PAC
providers and the exclusions need to be modified: a. By including any
admissions to SNFs, IRFs or LTCHs within 30 days post hospital discharge, more
complex patients who are unlikely to be discharged home are added to SNFs,
IRFs and LTCHs, but this differentially impacts SNFs since a large proportion
of IRF and LTCH patients are discharged to SNFs within 30 days. b. For home
health, by not requiring a hospital stay prior to HH stay, increases the
number of individuals in their sample who are less likely to be
institutionalized after HH services, making their discharge to the community
measure look better than the other PAC settings simply due to the denominator
definition. c. Failure to exclude individuals admitted to a SNF who were
residents of a SNF prior to the hospital stay also is inappropriate since they
are residents of long term care facility and would not be expected to be
discharged to the community following Part A services. There are
approximately, 1.1M long term residents of which nearly 1/6th are admitted to
the hospital and sent back the SNF each year. 5. The specifications are based
on ICD-9 but all providers as of October 2015 are required to use ICD-10 and
no cross walk with ICD-10 is provided, yet the measure will be used during
time periods when only ICD-10 data is available. 6. The numerator definition
and methodology of calculating a “predicted actual” is extremely confusing,
which makes the data less likely to be used and is of questionable benefit.
Data showing how this approach is superior to using an actual rate divided by
the expected rate needs to be provided. 7. The numerator time window for how
long a PAC provider has to accomplish a discharge to the community is not
specified. 8. The numerator definition of alive 30 days after discharge to
the community will discourage discharging individuals to their home who are
dying. We appreciate that those who die in the next 30 days after discharge
who are also enrolled in hospice will be exclude but believe these should not
be excluded. Rather, we believe they should be counted as successful discharge
to the community rather than excluded. 9. The numerator should not count
individuals who during the 30 day discharge window are admitted to a SNF just
as any other rehospitalizations are not counted. 10. Risk adjustment is not
specified other than to state “under consideration is a hierarchical logistic
regression model” without any specification of the risk adjustment variables
other than examples and categories. Risk adjustment needs to include and
specify: a. Social Demographic Characteristics (SDS). b. Functional status
(ADL, mobility, self-care, and cognitive function) are some of the strongest
predictors of successful discharge to the community but are not included. The
risk adjustment variables are not specifically specified with respect to data
source and coding but are given as examples with just an overall descriptor.
Without knowing the risk adjustment variables and how they are specified, it
is hard to evaluate the proposed measures. c. Risk adjustment variables under
consideration are not consistent across all PAC settings which is
understandable for some settings and patients however, since LTCHs and IRFs
are not in all markets, SNFs in many parts of the country serve the same
population as IRFs and LTCHs. For example i. Ventilator use is only listed
for LTCH setting. SNFs also care for individuals using ventilators. ii.
Case mix groups is only listed for LTCH setting but should apply to IRFs and
SNFs as well. (Submitted by: American Health Care Association )
- The AHA agrees with the MAP’s recommendations for this measure. We are
concerned by the lack of data of the reliability and validity of patient
discharge status codes that would be used in this measure. Given that it is
such a fundamental part of the measure, CMS should conduct such testing and
make the results publicly available. Furthermore, we strongly urge that this
measure be assessed for the impact of sociodemographic factors on performance,
and an adjustment should be incorporated if warranted. (Submitted by:
American Hospital Association)
- AAPM&R commends NQF for evolving its work to understand how measures
are being developed and implemented across settings and how they impact
payment reform. This is a huge endeavor that AAPM&R stands behind in
concept. However, AAPM&R cautions NQF to ensure their processes and
review of measures are adequately reported back to CMS and other rule-making
entities to ensure the NQF’s measurement expertise is realized in rule making.
While this measure addresses functional improvement , it does not address
the practical value of the measurable improvement or the ability of a patient
to return to the community. For example, a patient with a complete cervical
spinal cord injury or dense hemiplegia from a stroke may not make significant
functional gains (i.e., they may remain dependent in many domains of mobility
and/or activities of daily living). However, with expert and comprehensive
patient and family/care-giver education and training by the rehabilitation
team, the patient may return to the community despite not meeting the
thresholds that are suggested by the quality measures. The Academy believes
that measurement of patient and family engagement with the process of care and
with education and training must be considered in the evaluation of models of
PAC. Another concern is that without factors related to psychosocial and
family financial support in prediction models, changes in function from
admission to discharge do not tell the entire story. The Academy urges CMS to
support the development of quality measures that relate to patient and family
engagement as PAC reform implementation evolves. AAPM&R believes there
needs to be further discussions about psychosocial issues. (Submitted by:
American Academy of Physical Medicine and Rehabilitation )
- ARN is supportive of a measure that works to identify unplanned
(re)admissions; however, we have concerns with identifying unplanned
(re)admissions based on the planned readmissions algorithm used in NQF measure
#2510: SNF 30-Day All-Cause Readmission Measure (SNFRM); NQF #2502: All-Cause
Unplanned Readmission Measure for 30 Days Post Discharge from IRFs; NQF #2512:
All-Cause Unplanned Readmission Measure for 30 Days Post Discharge from LTCHs;
and NQF #2380: Re-hospitalization During the First 30 Days of Home Health.
The exclusion criteria included within NQF #2510 for SNF stays where the
patient had one or more intervening PAC admissions to an IRF that occurred
either between the prior proximal hospital discharge and SNF admission or
after the SNF discharge within the 30-day risk window fails to allow for a
medically complex patient that is treated in an IRF and readmitted to the SNF
within 30 days for a condition that may initially have been treated as a
comorbidity. We disagree with the rationale provided for exclusion, for while
the measure assesses readmission rates while accounting for patient
demographics, principal diagnosis in the prior hospitalization, comorbidities,
and other patient factors, often, this may not be the reason for admission to
a SNF. ARN believes the measure should include the principal diagnosis during
the prior proximal hospitalization, comorbidities based on the secondary
medical diagnoses listed on the patient’s prior proximal hospital claim and
diagnoses from prior hospitalizations that occurred in the previous 365 days,
length of stay during the patient’s prior proximal hospitalization, length of
stay in the intensive care unit, body system specific surgical indicators,
End-Stage Renal Disease (ESRD) status, whether the patient was disabled, and
the number of prior hospitalizations in the previous 365 days. It also would
be beneficial to understand the comorbidities being evaluated in the
risk-adjustment model. ARN urges the Centers for Medicare and Medicaid
Services (CMS) to develop of a list of comorbidities, comparable to the IRF
Prospective Payment System list of comorbidities and we encourage CMS to
categorize an intervening admission to an IRF as a proximal hospitalization.
Additionally, ARN has serious concerns with CMS’s proposal to require PAC
providers to utilize Medicare claims data to calculate their 30-day
readmission rates. Using claims data to calculate readmission rates is
difficult for health care providers, as claims data are cumbersome to use and
access. Employing a 30-day readmission rate measure will not provide
meaningful insight or have an impact on quality improvement efforts if the PAC
settings do not have unrestricted access to the data. Further, ARN believes
that patients who have been discharged to the community and expire within the
post-discharge window should not be included within the quality measure, given
the variation in patient characteristics across the four settings. For
example, as compared to all Medicare beneficiaries, the SNF and LTCH patient
populations represent the most disabled, elderly, and frail beneficiaries. The
Medicare Payment Advisory Commission’s March 2015 Report to Congress found
that compared with other beneficiaries, “SNF users are older, frailer, and
disproportionately female, disabled, living in an institution, and dually
eligible for both Medicare and Medicaid.” Moreover, as compared with all
Medicare beneficiaries, those admitted to LTCHs are “disproportionately
disabled (under age 65), over age 85, or diagnosed with [ESRD]. They are also
more likely to be African American.” ARN urges CMS to exclude patients that
pass away within the post-discharge window after being discharged to the
community from the discharge to community quality measure, as the types of
patients treated in each setting greatly varies and can lead to an inaccurate
reflection of the quality of care. ARN is pleased the CMS has proposed
discharge measure exclusions; however, we have concerns with the proposed
exclusion of post-acute stays that end in transfer to the same level of care,
and specifically, CMS’s proposal to include only the final post-acute provider
in the discharge to community measure. The Agency’s proposed exclusion
criteria fails to consider when a patient’s “home” is a custodial nursing
facility and the patient’s post-acute episode involves a discharge back to his
or her “home.” In such circumstances, including the final post-acute provider
in the discharge to community measure when a patient is discharged to the
originating level of care, but in essence, is returning home, may distort the
findings of the quality measure. We encourage CMS to design a quality measure
that is capable of capturing the difference between a patient’s return to his
or her home and a patient’s post-acute episode that involves transfer to the
same level of care. (Submitted by: Association of Rehabilitation
Nurses)
- (Early public comment)APTA supports the goal of improving the
quality of health care. Physical therapists are committed to providing
high-quality, timely care and to the promotion of evidence-based and
patient-centered practice. Furthermore, APTA feels that it is essential that
we move towards a common set of quality measures across the continuum of care.
APTA supports the implementation of a discharge to community measure across
the care settings. We believe that successful transitions to the community
following discharge from the respective post-acute care settings will decrease
potentially preventable readmissions. However, the APTA does have some
concerns regarding the proposed measure methodology. These concerns are
discussed below. APTA believes that a patient’s level of function does impact
a patients ability to transition successfully back to the community. Recent
evidence indicates that patient function is associated with increased risk of
30-day all-cause hospital readmissions and may be an important factor in
preventing readmissions for Medicare seniors that is not currently accounted
for in measure methodologies1. APTA was pleased to see “activity of daily
living” scores in the home health setting included in the risk adjustment
methodology for the readmissions measures, and we recently commented,
encouraging the use of patient function in the risk adjustment methodology for
the post-acute care setting readmissions measures. We believe that
readmissions and discharge to community are closely related measures and that
patient function may also be an important risk adjustment variable for
discharge to community. APTA appreciates that CMS has strict deadlines for
the implementation of measures under the IMPACT act, however, as these
measures will be new to the respective post-acute care settings, we encourage
that settings have the ability to review this data as early as possible in
order to understand and, more importantly, so that the respective setting have
time to implement strategies to decrease readmissions where necessary. As
many of these settings do not always receive feedback on the readmissions of
their patients post-discharge, this data will be new to many facilities.
APTA recognizes that the overall goal of IMPACT is for PAC providers (HH,
IRF, SNF and LTCH) to collect and report standardized and interoperable
patient assessment data, quality and resource use measures. We acknowledge
that during the initial IMPACT implementation years that there will be a
transition period which will include the addition of new measures into all of
the post-acute care settings. We believe that achieving a standardized and
interoperable patient assessment data set and stable quality measures as
quickly as possible will allow for better cross-setting comparisons as well as
the evolution of better quality measures with uniform risk standardization,
thus achieving the true aim of IMPACT. 1 Greysen SR, Cenzer IS, Auerbach AD,
Covinsky KE. Functional Impairment and Hospital Readmission in Medicare
Seniors. JAMA Intern Med. 2015;175(4):559-565. (Submitted by: American
Physical Therapy Association)
- (Early public comment)This measure is currently in early
development and measure specifications are in preliminary stages of
clarification. The proposed application could create inaccuracy in
measurement of patient condition and payment. Exclusions have not been defined
(i.e. “Short term acute stay”), tested regarding clinical reasonableness (i.e.
SNFs stays that end in transfer to another SNF) or verified for CMS
capabilities to avoid Provider burden for unnecessary and in appropriate data
capture (ie. Patients not continuously enrolled in Part A FFS Medicare for 12
months prior to the SNF admission date and at least 31 days after SNF
discharge). This measure needs extensive work to assure accuracy and to meet
the purpose for which it was intended. Because there is potential for accuracy
this measure should continue to be developed. (Submitted by: Genesis Health
Care)
- (Early public comment)We have the following concerns related to
this measure: 1. The inclusion of unplanned readmissions in the discharge
to community measure development and calculation. Our concerns related to the
inclusion of unplanned readmissions in the discharge to community measure
development and calculation can be defined as follows: a.
Duplication/commingling of quality metrics With the inclusion of unplanned
readmissions in the discharge to community measure development and
calculation, there is the potential for there to be a strong correlation
between the performances of the two measures. In other words, those PAC
providers that perform poorly with the unplanned readmission measure are more
likely to perform poorly on this measure, while those PAC providers that
perform well with the unplanned readmission measure have a better opportunity
to perform well on this measure. Take for instance the scenario of two
facilities with similar patient populations (age, sex, etc.), where provider A
discharges 75% to a community setting with a 5% readmission rate while
provider B discharges 72% to a community setting with a 2% readmission rate.
Which facility performs better at discharging patients to a community setting?
Is the discharge to community measure truly representative of the ability of
the post-acute care provider to provide services that get the patient back to
a community setting, or is too much emphasis being placed upon the ability of
the patient to stay in a community setting? b. Inclusion of a factor
that is outside of post-acute care provider control While a post-acute care
provider can provide services that impact the ability of a patient to be
discharged back to a community setting, whether or not a patient returns to an
acute care facility in the 30 days following that PAC discharge can be
completely unrelated to the services furnished by the PAC provider. For
instance, a patient is discharged home from a post-acute care provider but is
re-admitted to acute care 10 days later for pneumonia (which is listed as a
diagnosis category that cannot be considered planned). Should the post-acute
care provider’s discharge to community percentage be penalized if the
readmission is completely unrelated to the services provided within post-acute
care? With the concerns noted above, we would recommend that the measure
developers remove the unplanned readmission component from the discharge to
community measurement, and provide side-by-side comparison of these two
separate and unique quality measures. 2. Potential for site-specific
risk adjustment for a “cross-setting” measure. While we note that the risk
adjustment variables are “under consideration”, we are very concerned that the
variables noted in the draft specification designate certain variables as
being applicable to unique or specific post-acute care providers. The IMPACT
Act requires the specification of quality measures and resource use metrics
that are standardized and interoperable across PAC settings. In creating a
measure where consideration is being given to risk adjustment variables that
differ by post-acute care setting, is CMS truly meeting the definition of
“standardized and interoperable”? As an example, “Activities of Daily Living”
(ADLs) are noted as one of the Clinical conditions variables, yet is noted for
“the HHA setting only”. If the measure developer can show that ADLs can be
used to differentiate the performance within the HHA population, couldn’t ADLs
also be used to differentiate the performance of all post-acute care settings
and produce a measurement value that is “standardized and interoperable”? We
urge CMS and the measure developers to introduce risk-adjustment variables
that are “standardized and interoperable” in order to meet the IMPACT Act
requirements. (Submitted by: UDSMR)
- (Early public comment)AHCA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. Thank you again for the opportunity to provide these comments. Please
contact me at DGifford@ahca.org with any questions or for additional
information. A preliminary draft yet incomplete specifications for this
measure were provided by CMS for public comment, with the deadline for comment
being December 8th 2015, which is after the MUC list was published. No
information on reliability or validity of the measure is available and the
risk adjustment methodology is not fully specified. Therefore, we believe this
measure does not meet NQF MAP criteria for endorsement but rather should
receive a vote of “encourage continued development”. Additionally, based on
information available, we have the following concerns with measure MUC15-462.
1. The name of the measure should reflect the limited population to which it
applies – fee-for service (FFS) Medicare beneficiaries. Since in many states,
40% or more of Medicare beneficiaries are enrolled in Medicare Advantage (MA)
plans and for SNFs over half of SNF admissions and discharges are not enrolled
in FFS Medicare, this measure may not reflect a SNF’s true discharge to
community rate. 2. Since the determination of discharge to the community is
self-reported on the claims, we suggest the use of PAC assessment tools as the
source of data on discharge to the community, which will allow the inclusion
of additional Medicare Beneficiaries enrolled in MA plans. The use of the PAC
assessment instruments is consistent with the intent of IMPACT act. 3. The
measure does not exclude individuals admitted to a SNF for Part A services but
who have an expressed goal to remain in the SNF for long term care and never
be discharged back to the community. In fact, when we have compared discharge
to community rates as a relationship to the turnover of patients in Part A
beds, those SNFs with low turnover that are consistent with being primarily
long term care facilities have very low discharge to community rates while
SNFs with higher turnover of beds, have higher discharge to community rates.
4. The denominator definition places SNFs at a disadvantage when comparing
discharges to community for other PAC providers and the exclusions need to be
modified: a. By including any admissions to SNFs, IRFs or LTCHs within 30 days
post hospital discharge, more complex patients who are unlikely to be
discharged home are added to SNFs, IRFs and LTCHs, but this differentially
impacts SNFs since a large proportion of IRF and LTCH patients are discharged
to SNFs within 30 days. b. For home health, by not requiring a hospital stay
prior to HH stay, increases the number of individuals in their sample who are
less likely to be institutionalized after HH services, making their discharge
to the community measure look better than the other PAC settings simply due to
the denominator definition. c. Failure to exclude individuals admitted to a
SNF who were residents of a SNF prior to the hospital stay also is
inappropriate since they are residents of long term care facility and would
not be expected to be discharged to the community following Part A services.
There are approximately, 1.1M long term residents of which nearly 1/6th are
admitted to the hospital and sent back the SNF each year. 5. The
specifications are based on ICD-9 but all providers as of October 2015 are
required to use ICD-10 and no cross walk with ICD-10 is provided, yet the
measure will be used during time periods when only ICD-10 data is available.
6. The numerator definition and methodology of calculating a “predicted
actual” is extremely confusing, which makes the data less likely to be used
and is of questionable benefit. Data showing how this approach is superior to
using an actual rate divided by the expected rate needs to be provided.
7. The numerator time window for how long a PAC provider has to accomplish a
discharge to the community is not specified. 8. The numerator definition of
alive 30 days after discharge to the community will discourage discharging
individuals to their home who are dying. We appreciate that those who die in
the next 30 days after discharge who are also enrolled in hospice will be
exclude but believe these should not be excluded. Rather, we believe they
should be counted as successful discharge to the community rather than
excluded. 9. The numerator should not count individuals who during the 30 day
discharge window are admitted to a SNF just as any other rehospitalizations
are not counted. 10. Risk adjustment is not specified other than to state
“under consideration is a hierarchical logistic regression model” without any
specification of the risk adjustment variables other than examples and
categories. Risk adjustment needs to include and specify: a. Social
Demographic Characteristics (SDS). b. Functional status (ADL, mobility,
self-care, and cognitive function) are some of the strongest predictors of
successful discharge to the community but are not included. The risk
adjustment variables are not specifically specified with respect to data
source and coding but are given as examples with just an overall descriptor.
Without knowing the risk adjustment variables and how they are specified, it
is hard to evaluate the proposed measures. c. Risk adjustment variables under
consideration are not consistent across all PAC settings which is
understandable for some settings and patients however, since LTCHs and IRFs
are not in all markets, SNFs in many parts of the country serve the same
population as IRFs and LTCHs. For example i. Ventilator use is only listed
for LTCH setting. SNFs also care for individuals using ventilators. ii.
Case mix groups is only listed for LTCH setting but should apply to IRFs and
SNFs as well. (Submitted by: American Health Care Association )
- (Early public comment)This measure is limited to FFS beneficaries
only, therefore is misleading as a "measure of return to community". It also
does not recognize those individuals who resided in the long stay NH PRIOR to
their hospital stay and SNF services, who thus plan to stay. Risk adjustment,
for chronic conditions, functional status and SES are critical in order for
the measure to have any meaning, given the diverse populations served in the
SNF setting (Submitted by: Leadingage)
- (Early public comment)The ultimate goals of post-acute care are
avoiding institutionalization and returning patients to their previous level
of independence and functioning, with discharge to community being the primary
goal for the majority of post-acute patients. For many, home is a symbol of
independence, privacy, and competence. Discharge to community is considered a
valuable outcome to measure because it is a multifaceted measure that captures
the patient’s functional status, cognitive capacity, physical ability, and
availability of social support at home. There is considerable variation in
discharge to community rates within and across post-acute settings. Studies
show geographic variation, variation across patient socioeconomic
characteristics (for example, race and ethnicity), and variation by facility
characteristics (for profit vs. nonprofit, freestanding vs. hospital-based,
urban vs. rural). In the IRF setting, discharge to community rates vary across
providers, ranging from about 60% to 75%. The 2015 MedPAC report shows that,
in FY 2013, the facility-level, mean risk-adjusted discharge to community rate
for IRFs within 100 days of admission was 75.8%, and the mean observed rate
was 74.7%. Discharge to community rates also vary widely in the SNF setting,
ranging from as low as 31% to as high as 65%. The 2015 MedPAC report shows a
mean risk-adjusted discharge to community rate of 37.5% for SNFs within 100
days of admission, and mean observed rate of 40.1%. A multicenter study of 23
LTCHs reported that only 28.8% of 1,061 patients who were ventilator-dependent
on admission were discharged to home or assisted living facility. A study of
66,510 Medicare beneficiaries during pre- and post-HH episodes, revealed that
64 percent of beneficiaries discharged from HH did not use any other
Medicare-reimbursed acute or post-acute services in the 30 days following HH
discharge. Significant numbers of patients were admitted to inpatient
facilities (29percent) and lesser numbers to skilled nursing facilities (7.6
percent), inpatient rehabilitation (1.5 percent) and home health (7.2 percent)
or hospice (3.3 percent) within 30 days of HH discharge (Wolff et al., 2008).
II. Feedback Overall, there is not enough detail on the measure
specifications to provide adequate feedback. However, despite the lack of
detail, a response is included below on the discharge to community measure for
LTCH, IRF, SNF, and HH. Description Patients discharged to the community
following PAC stay/episode and do not have an unplanned admission to an acute
care hospital or LTCH in 31 days after community discharge and remain alive
• Although not explicitly stated, it appears that this measure is only holding
the last PAC setting responsible for the discharge? Given what is known about
multiple sites of PAC use either from LTCH/IRF patients are often discharged
to SNF before community discharge, as it is currently worded this measure will
penalize the SNF for the more difficult patients that could not be discharged
from the prior PAC setting. • Research has shown that PAC patients re-enter
the healthcare system through multiple doors after the PAC community
discharge why are these not captured in the measure as a failed transition I
recommend that the numerator should not include individuals who were admitted
to a SNF after PAC community discharge during the 30-day measure window.
Numerator & Denominator There is not enough detail to provide feedback on
the risk adjustment of the numerator. Without details on the variables
included, the origin of those variables, and methods of risk adjustment it is
difficult to provide feedback. Recommend providing further detail. Recommend
including functional status, functional cognition, presence of social support
(e.g., does the individual live alone), and comorbid conditions as risk
adjustors Exclusion There is no discussion of excluding long-stay nursing home
residents in this measure. Long-stay residents that have an acute medical
event, are admitted to an acute care hospital, discharged to PAC for care, and
then transitioned back to long-term care should be excluded from the measure.
These individuals are not returning to the community, while the nursing home
is their home, the effort and processes required for transitioning a long-stay
nursing home resident from PAC back to custodial care is very different that
transitioning a community- residing older adult back to their residence in the
community after a PAC stay. Recommend excluding long stay nursing home
residents from the measure. (Submitted by: American Occupational Therapy
Association)
- (Early public comment)AMDA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015.
AMDA - The Society for Post-Acute and Long-Term Care Medicine (AMDA)
represents over 5,500 physician medical directors, attending physicians, and
other practitioners who work in post-acute and long-term care settings.
Thank you again for the opportunity to provide these comments. Please contact
me at abardakh@amda.com with any questions or for additional information. A
preliminary draft yet incomplete specifications for this measure were provided
by CMS for public comment, with the deadline for comment being December 8th
2015, which is after the MUC list was published. No information on reliability
or validity of the measure is available and the risk adjustment methodology is
not fully specified. Therefore, we believe this measure does not meet NQF MAP
criteria for endorsement but rather should receive a vote of “encourage
continued development” Based on information available, we have the following
concerns with measure MUC15-462. 1. The name of the measure should reflect
the limited population to which it applies – fee-for service (FFS) Medicare
beneficiaries. Since in many states, 40% or more of Medicare beneficiaries are
enrolled in Medicare Advantage (MA) plans and for SNFs over half of SNF
admissions and discharges are not enrolled in FFS Medicare, this measure may
not reflect a SNF’s true discharge to community rate. 2. Since the
determination of discharge to the community is self-reported on the claims, we
suggest the use of PAC assessment tools as the source of data on discharge to
the community, which will allow the inclusion of additional Medicare
Beneficiaries enrolled in MA plans. The use of the PAC assessment instruments
is consistent with the intent of IMPACT act. 3. The measure does not exclude
individuals admitted to a SNF for Part A services but who have an expressed
goal to remain in the SNF for long term care and never be discharged back to
the community. In fact, when we have compared discharge to community rates as
a relationship to the turnover of patients in Part A beds, those SNFs with low
turnover that are consistent with being a primary long term care facilities
have very low discharge to community rates while SNFs with higher turnover of
beds, have higher discharge to community rates. 4. The denominator definition
places SNFs at a disadvantage when comparing discharges to community for other
PAC providers and the exclusions need to be modified: a. By including any
admissions to SNFs, IRFs or LTCHs within 30 days post hospital discharge, more
complex patients who are unlikely to be discharged home are added to SNFs,
IRFs and LTCHs, but this differentially impacts SNFs since a large proportion
of IRF and LTCH patients are discharged to SNFs within 30 days. b. For home
health, by not requiring a hospital stay prior to HH stay, also increases
individuals in their sample who are less likely to be institutionalized after
HH services, making their discharge to the community measure look better than
the other PAC settings simply due to the denominator definition. c. Failure to
exclude individuals admitted to a SNF who were residents of a SNF prior to the
hospital stay also is inappropriate since they are residents of long term care
facility and would not be expected to be discharged to the community following
Part A services. There are approximately, 1.1M long term residents of which
nearly 1/6th are admitted to the hospital and sent back the SNF each year.
5. The specifications are based on ICD-9 but all providers as of October 2015
are required to use ICD-10 and no cross walk with ICD-10 is provided, yet the
measure will be used during time periods when only ICD-10 data is available.
6. The numerator definition and methodology of calculating a “predicted
actual” is extremely confusing, which makes the data less likely to be used
and is of questionable benefit. Data showing how this approach is superior to
using an actual rate divided by the expected rate needs to be provided.
7. The numerator time window for how long a PAC provider has to accomplish a
discharge to the community is not specified. 8. The numerator definition of
alive 30 days after discharge to the community will discourage discharging
individuals to their home who are dying. Many patients with terminal
diagnoses are reluctant to enroll in hospice programs or receive palliative
care. We appreciate that those who die in the next 30 days after discharge who
are also enrolled in hospice will be excluded, but believe these should not be
excluded. Rather, we believe they should be counted as successful discharge to
the community rather than excluded. 9. The numerator should not count
individuals who during the 30 day discharge window are admitted to a SNF just
as any other rehospitalizations are not counted. 10. Risk adjustment is not
specified other than to state “under consideration is a hierarchical logistic
regression model” without any specification of the risk adjustment variables
other than examples and categories. Risk adjustment needs to include and
specify: a. Social Demographic Characteristics (SDS). b. Functional status
(ADL, mobility, self-care, and cognitive function) are some of the strongest
predictors of successful discharge to the community but are not included. The
risk adjustment variables are not specifically specified with respect to data
source and coding but are given as examples with just an overall descriptor.
Without knowing the risk adjustment variables and how they are specified, it
is hard to evaluate the proposed measures. c. Risk adjustment variables under
consideration are not consistent across all PAC settings, which is
understandable for some settings and patients, however, since LTCHs and IRFs
are not in all markets, SNFs in many parts of the country serve the same
population as IRFs and LTCHs. For example: i. Ventilator use is only listed
for LTCH setting. SNFs also care for individuals using ventilators. ii.
Case mix groups is only listed for LTCH setting but should apply to IRFs and
SNFs as well. iii. Risk adjustment for other comorbidities should include
stroke, ESRD, COPD, advanced heart failure (high risk for frequent
decompensation). (Submitted by: AMDA-The Society for Post-Acute and Long-Term
Care Medicine)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)ARN is supportive of a measure that works to
identify unplanned (re)admissions; however, we have concerns with identifying
unplanned (re)admissions based on the planned readmissions algorithm used in
NQF measure #2510: SNF 30-Day All-Cause Readmission Measure (SNFRM); NQF
#2502: All-Cause Unplanned Readmission Measure for 30 Days Post Discharge from
IRFs; NQF #2512: All-Cause Unplanned Readmission Measure for 30 Days Post
Discharge from LTCHs; and NQF #2380: Re-hospitalization During the First 30
Days of Home Health. The exclusion criteria included within NQF #2510 for SNF
stays where the patient had one or more intervening PAC admissions to an IRF
that occurred either between the prior proximal hospital discharge and SNF
admission or after the SNF discharge within the 30-day risk window fails to
allow for a medically complex patient that is treated in an IRF and readmitted
to the SNF within 30 days for a condition that may initially have been treated
as a comorbidity. We disagree with the rationale provided for exclusion, for
while the measure assesses readmission rates while accounting for patient
demographics, principal diagnosis in the prior hospitalization, comorbidities,
and other patient factors, often, this may not be the reason for admission to
a SNF. ARN believes the measure should include the principal diagnosis during
the prior proximal hospitalization, comorbidities based on the secondary
medical diagnoses listed on the patient’s prior proximal hospital claim and
diagnoses from prior hospitalizations that occurred in the previous 365 days,
length of stay during the patient’s prior proximal hospitalization, length of
stay in the intensive care unit (ICU), body system specific surgical
indicators, End-Stage Renal Disease (ESRD) status, whether the patient was
disabled, and the number of prior hospitalizations in the previous 365 days.
It also would be beneficial to understand the comorbidities being evaluated in
the risk-adjustment model. ARN urges the Centers for Medicare and Medicaid
Services (CMS) to develop of a list of comorbidities, comparable to the IRF
Prospective Payment System (PPS) list of comorbidities and we encourage CMS to
categorize an intervening admission to an IRF as a proximal hospitalization.
Additionally, ARN has serious concerns with CMS’s proposal to require PAC
providers to utilize Medicare claims data to calculate their 30-day
readmission rates. Using claims data to calculate readmission rates is
difficult for health care providers, as claims data are cumbersome to use and
access. Employing a 30-day readmission rate measure will not provide
meaningful insight or have an impact on quality improvement efforts if the PAC
settings do not have unrestricted access to the data. Further, ARN believes
that patients who have been discharged to the community and expire within the
post-discharge window should not be included within the quality measure, given
the variation in patient characteristics across the four settings. For
example, as compared to all Medicare beneficiaries, the SNF and LTCH patient
populations represent the most disabled, elderly, and frail beneficiaries. The
Medicare Payment Advisory Commission’s (MedPAC) March 2015 Report to Congress
found that compared with other beneficiaries, “SNF users are older, frailer,
and disproportionately female, disabled, living in an institution, and dually
eligible for both Medicare and Medicaid.” Moreover, as compared with all
Medicare beneficiaries, those admitted to LTCHs are “disproportionately
disabled (under age 65), over age 85, or diagnosed with [ESRD]. They are also
more likely to be African American.” ARN urges CMS to exclude patients that
pass away within the post-discharge window after being discharged to the
community from the discharge to community quality measure, as the types of
patients treated in each setting greatly varies and can lead to an inaccurate
reflection of the quality of care. ARN is pleased the CMS has proposed
discharge measure exclusions; however, we have concerns with the proposed
exclusion of post-acute stays that end in transfer to the same level of care,
and specifically, CMS’s proposal to include only the final post-acute provider
in the discharge to community measure. The Agency’s proposed exclusion
criteria fails to consider when a patient’s “home” is a custodial nursing
facility and the patient’s post-acute episode involves a discharge back to his
or her “home.” In such circumstances, including the final post-acute provider
in the discharge to community measure when a patient is discharged to the
originating level of care, but in essence, is returning home, may distort the
findings of the quality measure. We encourage CMS to design a quality measure
that is capable of capturing the difference between a patient’s return to his
or her home and a patient’s post-acute episode that involves transfer to the
same level of care. (Submitted by: Association of Rehabilitation
Nurses)
(Program: Merit-Based
Incentive Payment System (MIPS); MUC ID: MUC15-463) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- Although the use of concurrent platinum-based chemotherapy for patients
with stage IIB-IV cervical cancer receiving primary radiation therapy has been
standard of care since the 1999 NCI clinical announcement stating as such, a
substantial proportion of these patients are not receiving this standard of
care. In a recent study (Lin J, et al) of locally advanced cervical cancer
patients (defined in the study as stage IIB – IIIB), using the National Cancer
Database as the data source, 1 out of 5 patients (20.1%) did not receive
chemotherapy. Thus, given the significant clinical benefit of concurrent
platinum-based chemotherapy for these patients, the gap in receipt of
concurrent platinum-based chemotherapy, and the widespread availability of
this low-cost treatment, this measure will have definitive positive impact and
is of paramount importance, therefore the SGO requests that MAP update its
recommendation to conditional support versus encouraged continued development.
Lin J, et al. Gynecol Oncol. 2014 Feb;132(2):416-22. doi:
10.1016/j.ygyno.2013.12.013. Epub 2013 Dec 12, PMID = 24333361 (Submitted by:
Society of Gynecologic Oncology)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)This measure represents good practice in
gynecology. (Submitted by: American College of Obstetricians and
Gynecologists)
(Program: Merit-Based Incentive Payment System
(MIPS); MUC ID: MUC15-465) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The Society of Gynecologic Oncology appreciates the MAP’s interest in this
measure and would like to address the opportunity for improvement in patient
care with this measure. The primary treatment of stage IB1-IIA cervical
cancer is radical hysterectomy. Radical hysterectomy has long been considered
the most appropriate type of hysterectomy for invasive cervical cancer. The
procedure requires expertise and technical skill to perform. Radical
hysterectomy can be performed via laparotomy, through minimally invasive
technology (robotic or laparoscopic) or vaginally. The Society will be
conducting additional analysis of this measure regarding opportunity of
improvement. However, we do believe that radically hysterectomy is not yet
being provided as a standard of care and that there is opportunity for
improvement in quality of care of women with invasive cervical cancer with the
adoption of this measure. Having this measure included in the quality measure
portion of the MIPS program for 2017 given that there are currently no
specific measures regarding quality of care for the treatment of women with
gynecologic cancer in the list of measures for the PQRS program is important
for women’s healthcare. (Submitted by: Society of Gynecologic
Oncology)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)This measure represents good practice in
gynecology. It supports referral to appropriate providers to ensure optimal
care for patients with curable cervical cancer. (Submitted by: American
College of Obstetricians and Gynecologists)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-466)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The Society of Gynecologic Oncology greatly appreciates continued support
for this measure and looks forward to working with the NQF and CMS in its
continued development and inclusion in MIPs for 2017 – and if not 2017, then
2018. (Submitted by: Society of Gynecologic Oncology)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program: Skilled Nursing Facility Quality Reporting System; MUC ID:
MUC15-495) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. AHCA is pleased to have the opportunity to comment on the MAP
Preliminary Decisions and MAP Draft Report ”. Thank you again for the
opportunity to provide these comments. Please contact me at DGifford@ahca.org
with any questions or for additional information. We support the MAP’s
preliminary decision to “encourage continued development” of this measure.
However, in the draft report, the MAP must clearly state that encouraging
continued development of this measures should not be taken as support of
inclusion of this measure in the SNF QRP. We also think the report needs to
include the comments and recommendations made by the MAP workgroup on each
measure since that is the primary role of the MAP to provide DHHS with
feedback on the MUC list and DHHS needs to respond to those comments in any
proposed rule. Without inclusion of these comments, if DHHS decided to
implement this measure for rule making via the Federal Register process, CMS
does not need to provide a rationale for their decision. Additionally, for the
sake of transparency and enhanced stakeholder feedback the draft report should
include the specific public comments submitted. Our specific comments on this
measure are as follows. A preliminary draft yet incomplete specifications for
this measure were provided by CMS for public comment, with the deadline for
comment being December 1st, 2015, which is after the MUC list was published.
No information on reliability or validity of the measure is available and the
risk adjustment methodology is not fully specified. In addition, CMS has
provided inadequate time for public review and comment of this measure. In
fact, the TEP never saw the preliminary full draft specification of this
measure until it was made available for public comment in late November 2015
after the TEP meeting. This measure (MUC15-495) double counts readmissions
with other SNF potentially preventable readmission measure (MUC15-1048).
Measure MUC15-1048 includes readmission that occur within a SNF stay and after
a SNF stay. Thus, this measure will capture the same readmissions as in
measure MUC15-1048 resulting in a double counting of measures. We have
additional concerns with this measure that mirror our comments on measure
MUC15-1048 which include: 1. The name of the measure should reflect the
limited population to which it applies – fee-for service (FFS) Medicare
beneficiaries; particularly since in many states 40% or more of Medicare
beneficiaries are enrolled in MA plans and for SNFs over half of SNF
admissions and discharges are not enrolled in FFS Medicare. 2. The
specifications are based on ICD-9 but all providers as of October 2015 are
required to use ICD-10 and no cross walk with ICD-10 is provided. 3. The
numerator definition and methodology of calculating a “predicted actual” is
extremely confusing, which makes the data less likely to be used and is of
questionable benefit. Data showing how this approach is superior to using an
actual rate divided by the expected rate needs to be provided. 4. Many of the
potentially preventable admissions contains diagnoses that do not meet the
proposed definition of potentially preventable readmissions; therefore, these
should be dropped. 5. The process for developing the list of potentially
preventable admissions used existing literature but would have benefited from
a more formal process such as the RAND appropriateness rating system (e.g.
modified Delphi approach) rather than ad hoc TEP and consultant experts. 6.
Risk adjustment does not included: a. SES characteristics, an issue
identified in the last round of NQF readmission measure reviews as a
requirement. b. Functional status, one of the strongest predictors of
hospitalizations. All the PAC settings are now required to utilize standard
functional status assessment – Section GG from the CARE tool. c. The risk
adjustment variables are not specifically specified with respect to data
source and categories but are given as examples with just a descriptor. For
example is age continuous or categorical variable and if categorical how and
from what source? d. Prior utilization variables indicate they “vary by
measure” but how they vary by measure is not provided. 7. The exclusions are
confusing and need some modifications. a. The denominator exclusions appear
confusing and overlapping so that it is unclear if discharges from IRF or LTCH
to SNF or HH are included in the IRF and LTCH denominator. Similarly, if SNF
discharges to HH are included. b. We agree that AMA discharges from PAC
provider should be excluded but so should hospital discharges that are AMA but
end up in PAC provider. 8. The list of related to other NQF endorsed measures
is incomplete and only compares to CMS or RTI endorsed measures. All other
NQF endorsed measures should be included. 9. We agree with the expansion of
unplanned readmission diagnoses from YALE’s list, but will this also be
applied to the SNFRM and hospital readmission measures? (Submitted by:
American Health Care Association )
- These comments cover MU 15-495 -498 and MU 15-523. Concerns about
multiple ways to measure and multiple penalty issues are right on spot.
Additionally, the introduction of "risk adjustment" introduces an entirely new
'black box measure' to the health system, since it is difficult to replicate
this kind of metric. (Submitted by: American Medical Group Association
-EB)
- We agree with MAP members’ concerns about potential overlap between
readmission measures as well as unintended consequences of these measures if
not appropriately risk adjusted. As currently outlined, the exclusion criteria
of SNF stays with a gap of greater than one day between discharge from the
prior proximal hospitalization and admission to a SNF fails to consider a
medically complex patient that is treated in an IRF and subsequently
readmitted within 30 days for an issue that may have been treated as a
comorbidity. Given that a prior proximal hospitalization is defined as an
inpatient admission to an acute care hospital, critical access hospital, or a
psychiatric hospital, and IRFs are licensed as hospitals, we believe that
admission to an IRF should be considered a proximal hospitalization and
disagree that patients who are clinically different should be excluded. ARN
also questions the rationale behind the exclusion for SNF stays where the
patient had one or more intervening PAC admissions which occurred either
between the prior proximal hospital discharge and SNF admission or after the
SNF discharge, within the 30-day risk window as well as SNF admissions where
the patient had multiple SNF admissions after the prior proximal
hospitalization, within the 30-day risk window. The rationale states that
“when patients have multiple PAC admissions, evaluating quality of care
coordination is confounded and even controversial in terms of attributing
responsibility for a readmission among multiple PAC providers. Similarly,
assigning responsibility for a readmission for patients who have multiple SNF
admissions subsequent to their prior proximal hospitalization is also
controversial.” ARN believes that this rationale could apply to any PAC
setting and therefore, disagrees with having this as an exclusion from the SNF
denominator. (Submitted by: Association of Rehabilitation Nurses)
- (Early public comment)APTA supports the goal of improving the
quality of health care. Physical therapists are committed to providing
high-quality, timely care and to the promotion of evidence-based and
patient-centered practice. Furthermore, APTA feels that it is essential that
we move towards a common set of quality measures across the across the
continuum of care. APTA supports the implementation of readmissions measures
across the care settings, as approximately 20% of all Medicare patients are
readmitted within 30 days of an acute care discharge and readmissions account
for an estimated $17 billion in health care spending. APTA is pleased to see
that the draft specifications for these measures align with existing
methodologies of other readmissions measures. We believe that potentially
preventable readmissions measures will focus providers on those patients who
are expected to have successful transitions to the community follow in
discharge from the respective post-acute care settings. However, the APTA
does have some concerns regarding the proposed measure methodology. These
concerns are discussed below. APTA believes that a patient’s level of function
does impact the potential for readmissions. Recent evidence indicates that
patient function is associated with increased risk of 30-day all-cause
hospital readmissions and may be an important factor in preventing
readmissions for Medicare seniors that is not currently accounted for in
measure methodologies1. APTA is pleased to see “activity of daily living”
scores included in the risk adjustment methodology, however, we note that this
is only included for those patients in the home health setting. We would
encourage measure developers to include this as a risk adjustment variable in
all readmissions measures. APTA appreciates that CMS has strict deadlines
for the implementation of measures under the IMPACT act, however, as these
measures will be new to the respective post-acute care settings we encourage
that settings have the ability to review this data as early as possible in
order to understand the data and, more importantly, so that the respective
setting have time to implement strategies to decrease readmissions where
necessary. As many of these settings do not always receive feedback on the
readmissions of their patients post-discharge, this data will be new to many
facilities. Additionally, skilled nursing facilities and inpatient
rehabilitation facilities will be trying to manage two measures, one within
stay, and one post-discharge. APTA recognizes that the overall goal of
IMPACT is for PAC providers (HH, IRF, SNF and LTCH) to collect and report
standardized and interoperable patient assessment data, quality and resource
use measures. We acknowledge that during the initial IMPACT implementation
years that there will be a transition period which will include the addition
of new measures into all of the post-acute care settings. We believe that
achieving a standardized and interoperable patient assessment data set and
stable quality measures as quickly as possible will allow for better
cross-setting comparisons as well as the evolution of better quality measures
with uniform risk standardization, thus achieving the true aim of IMPACT. 1
Greysen SR, Cenzer IS, Auerbach AD, Covinsky KE. Functional Impairment and
Hospital Readmission in Medicare Seniors. JAMA Intern Med.
2015;175(4):559-565. (Submitted by: American Physical Therapy
Association)
- (Early public comment)This measure is currently in early
development and measure specifications are in preliminary stages of
clarification. The proposed application could create inaccuracy in
measurement of patient condition and payment. Exclusions have not been defined
for clinical reasonableness as well as payment logic (i.e. “Patients who did
not have a short term acute-care stay within 30 days prior to the SNF
admission” - Does this mean all patients must have a hospitalization prior to
SNF admission to qualify for Part A benefits? If so, why? How does this
overlap with other CMS programs where beneficiaries are not required to have a
qualifying hospital stay such as the year two CJR program? ) nor have
exclusions been verified for CMS capabilities to avoid Provider burden for
unnecessary and in appropriate data capture (ie. Patients not continuously
enrolled in Part A FFS Medicare for 12 months prior to the SNF admission date
and at least 31 days after SNF discharge – How will CMS assure Providers do
not capture unneeded and/or inappropriate patient information?). This measure
needs extensive work to assure accuracy and to meet the purpose for which it
was intended. Because there is potential for accuracy this measure should
continue to be developed. (Submitted by: Genesis Health Care)
- (Early public comment)We would like to note the following concerns
regarding the development of these measures: 1. Measure development for the
IMPACT Act appears to create 4 separate measures that are site specific with
their own set of criteria and risk adjustment factors. The IMPACT Act aims to
create quality measurement within Post-Acute Care (PAC) that is "standardized
and interoperable". By developing measures which differ in their calculation,
such as site-specific inclusion/exclusion criteria or risk-adjustment factors,
PAC sites will be subjected to comparisons of quality that do not differ based
upon the quality of care provided, but rather the differences inherent in the
measure calculations. We strongly recommend that CMS and the measure
developers produce a measure that is calculated in a "standardized and
interoperable" manner with inclusion/exclusion criteria and risk-adjustment
factors the are applied consistently across all PAC sites. 2. The measures
developed for the IMPACT Act hold PAC providers responsible for circumstances
that occur outside of their control. While PAC providers are responsible for
providing care that allows patients safe transitions to their next setting or
home, holding these providers accountable fora time period in which they are
not furnishing care should not differentiate the quality of care they actually
provided. In Appendix A, Table A1 lists various conditions that define
potentially preventable hospital readmission for 30-days post-PAC discharge.
In this list, conditions such as Asthma, Congestive Heart Failure, and
Dehydration are listed as a reason for a potentially preventable readmission.
So if the patient fails to care for themselves post-discharge (against the
advice and discharge instructions provided by a PAC provider) and requires
readmission to Acute Care for one of these conditions, the PAC provider is
penalized even though the patient is no longer being cared for by the PAC
provider. We strongly recommend that CMS and the measure developers produce a
measure that represents the quality of care provided by PAC providers while
the patient is in their care. (Submitted by: UDSMR)
- (Early public comment)AHCA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. Thank you again for the opportunity to provide these comments. Please
contact me at DGifford@ahca.org with any questions or for additional
information. A preliminary draft yet incomplete specifications for this
measure were provided by CMS for public comment, with the deadline for comment
being December 1st, 2015, which is after the MUC list was published. No
information on reliability or validity of the measure is available and the
risk adjustment methodology is not fully specified. In addition, CMS has
provided inadequate time for public review and comment of this measure. In
fact, the TEP never saw the preliminary full draft specification of this
measure until it was made available for public comment in late November 2015
after the TEP meeting. Therefore, for these reasons and our concerns detailed
below, we believe this measure does not meet NQF MAP criteria for endorsement
but rather should receive a vote of “encourage continued development” This
measure (MUC15-495) double counts readmissions with other SNF potentially
preventable readmission measure (MUC15-1048). Measure MUC15-1048 includes
readmission that occur within a SNF stay and after a SNF stay. Thus, this
measure will capture the same readmissions as in measure MUC15-1048 resulting
in a double counting of measures. We have additional concerns with this
measure that mirror our comments on measure MUC15-1048 which include: 1. The
name of the measure should reflect the limited population to which it applies
– fee-for service (FFS) Medicare beneficiaries; particularly since in many
states 40% or more of Medicare beneficiaries are enrolled in MA plans and for
SNFs over half of SNF admissions and discharges are not enrolled in FFS
Medicare. 2. The specifications are based on ICD-9 but all providers as of
October 2015 are required to use ICD-10 and no cross walk with ICD-10 is
provided. 3. The numerator definition and methodology of calculating a
“predicted actual” is extremely confusing, which makes the data less likely to
be used and is of questionable benefit. Data showing how this approach is
superior to using an actual rate divided by the expected rate needs to be
provided. 4. Many of the potentially preventable admissions contains
diagnoses that do not meet the proposed definition of potentially preventable
readmissions; therefore, these should be dropped. 5. The process for
developing the list of potentially preventable admissions used existing
literature but would have benefited from a more formal process such as the
RAND appropriateness rating system (e.g. modified Delphi approach) rather than
ad hoc TEP and consultant experts. 6. Risk adjustment does not included:
a. SES characteristics, an issue identified in the last round of NQF
readmission measure reviews as a requirement. b. Functional status, one of
the strongest predictors of hospitalizations. All the PAC settings are now
required to utilize standard functional status assessment – Section GG from
the CARE tool. c. The risk adjustment variables are not specifically
specified with respect to data source and categories but are given as examples
with just a descriptor. For example is age continuous or categorical variable
and if categorical how and from what source? d. Prior utilization variables
indicate they “vary by measure” but how they vary by measure is not provided.
7. The exclusions are confusing and need some modifications. a. The
denominator exclusions appear confusing and overlapping so that it is unclear
if discharges from IRF or LTCH to SNF or HH are included in the IRF and LTCH
denominator. Similarly, if SNF discharges to HH are included. b. We agree
that AMA discharges from PAC provider should be excluded but so should
hospital discharges that are AMA but end up in PAC provider. 8. The list of
related to other NQF endorsed measures is incomplete and only compares to CMS
or RTI endorsed measures. All other NQF endorsed measures should be included.
9. We agree with the expansion of unplanned readmission diagnoses from YALE’s
list, but will this also be applied to the SNFRM and hospital readmission
measures? (Submitted by: American Health Care Association )
- (Early public comment)This measure seems to be in overlap with
MUC15-1048 as it captures the SAME readmissions. As with many of the other
measures, it should be acknowledged that this measure only addresses FFS. Many
SNF providers have a significant % of their admissions and discharges under
managed care, thus making this a far less useful measure of performance. Also,
there needs to be risk adjustment for clinical complexity, functional status
and SES. (Submitted by: LeadingAge)
- (Early public comment)This measure will encourage post-acute care
providers to optimize care for patients before discharge. (Submitted by:
Smith & Nephew )
- (Early public comment)ARN is pleased CMS has proposed discharge
measure exclusions; however, we disagree with the proposed exclusion criteria
of patients less than 18 years old. Many IRFs treat patients younger than 21
when necessary, is reflected by the Functional Independence Measure (FIM) and
IRF-Patient Assessment Instrument (PAI), both of which are used to assess
patients age seven or older. ARN encourages CMS not to exclude patients under
18 years old from the discharge measures. We also recommend that CMS ensure
the data collection time frame is the same for all PAC settings. Currently,
the time frame for the initial data collection for the project varies from one
year (SNFs), two years (IRFs and LTCHs), and three years (HHAs), we urge the
Agency to implement one standard reporting time frame across PAC providers.
While reporting may be based on either one year of data, two years of data,
etc., we strongly recommend CMS and its subcontractors address the
inconsistent reporting periods. Further, ARN questions the rationale behind
the exclusion for SNF stays where the patient had one or more intervening PAC
admissions which occurred either between the prior proximal hospital discharge
and SNF admission or after the SNF discharge, within the 30-day risk window as
well as SNF admissions where the patient had multiple SNF admissions after the
prior proximal hospitalization, within the 30-day risk window. The rationale
states that “when patients have multiple PAC admissions, evaluating quality of
care coordination is confounded and even controversial in terms of attributing
responsibility for a readmission among multiple PAC providers. Similarly,
assigning responsibility for a readmission for patients who have multiple SNF
admissions subsequent to their prior proximal hospitalization is also
controversial.” ARN believes that this rationale could apply to any PAC
setting and therefore, disagrees with having this as an exclusion from the SNF
denominator. We also have concerns with the exclusion criteria of SNF stays
with a gap of greater than one day between discharge from the prior proximal
hospitalization and admission to a SNF. As currently outlined, the exclusion
criteria fails to consider a medically complex patient that is treated in an
IRF and subsequently readmitted within 30 days for an issue that may have been
treated as a comorbidity. Given that a prior proximal hospitalization is
defined as an inpatient admission to an acute care hospital, critical access
hospital (CAH), or a psychiatric hospital, and IRFs are licensed as hospitals,
we believe that admission to an IRF should be considered a proximal
hospitalization and disagree that patients who are clinically different should
be excluded. Moreover, in regards to the within-stay criteria, IRFs have
experienced a rise in the number of patients who must return to the acute
inpatient care setting within 48-72 hours of admission due to the disparity
between the level of care which their condition (either a co-morbidity or
complication secondary to the presenting diagnosis) requires and the level of
care that an IRF is able to provide. An example of this is leukemia patients
as many times they require inpatient rehabilitation to discharge them from the
hospital and that the patient’s survival may be related to their functional
status and rehabilitation can improve function and symptoms such as fatigue,
well-being, and pain. To this end, ARN disagrees with the within-stay criteria
delineated for IRFs and believes that in specific instances, readmissions are
a necessity for patient safety, and not necessarily preventable. Finally,
while ARN is generally supportive of the potentially preventable readmissions
measure specifications, we have several concerns. As ARN has stated in
previous comment letters, the IRF measure is based on 24 months of data while
the SNF measure is based on 12 months of data. PAC facilities should not be
penalized for conditions that prompt readmissions that are unrelated to the
patient’s initial reason for admission. Moreover, as previously stated, we
oppose CMS’s proposal to require PAC providers to utilize 30-day readmission
claims data to determine their readmission rates. Using claims data to
calculate readmission rates will be difficult for IRFs and other PAC settings,
as claims data are cumbersome to use and access. Employing a 30-day
readmission rate measure will not provide meaningful insight or have an
impact on quality improvement efforts if PAC settings do not have unrestricted
access to the data. (Submitted by: Association of Rehabilitation
Nurses)
- (Early public comment)AMDA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
AMDA - The Society for Post-Acute and Long-Term Care Medicine (AMDA)
represents over 5,500 physician medical directors, attending physicians, and
other practitioners who work in post-acute and long-term care settings.
Thank you again for the opportunity to provide these comments. Please contact
me at abardakh@amda.com with any questions or for additional information. A
preliminary draft yet incomplete specifications for this measure were provided
by CMS for public comment, with the deadline for comment being December 1st,
2015, which is after the MUC list was published. No information on reliability
or validity of the measure is available and the risk adjustment methodology is
not fully specified. In addition, CMS has provided inadequate time for public
review and comment of this measure. In fact, the TEP never saw the preliminary
draft full specification of this measure until it was made available for
public comment in late November 2105 after the TEP meeting. Therefore, for
these reasons and our concerns detailed below, we believe this measure does
not meet NQF MAP criteria for endorsement but rather should receive a vote of
“encourage continued development” This measure (MUC15-495) double counts
readmissions with other SNF potentially preventable readmission measure
(MUC15-1048). Measure MUC15-1048 includes readmission that occur within a SNF
stay and after a SNF stay. Thus, this measure will capture the same
readmissions as in measure MUC15-1048 resulting in a double counting of
measures. We have additional concerns with this measure that mirror our
comments on measure MUC15-1048 which include: 1. The name of the measure
should reflect the limited population to which it applies – fee-for service
(FFS) Medicare beneficiaries; particularly since in many states 40% or more of
Medicare beneficiaries are enrolled in MA plans and for SNFs over half of SNF
admissions and discharges are not enrolled in FFS Medicare. 2. The
specifications are based on ICD-9 but all providers as of October 2015 are
required to use ICD-10 and no cross walk with ICD-10 is provided. 3. The
numerator definition and methodology of calculating a “predicted actual” is
extremely confusing, which makes the data less likely to be used and is of
questionable benefit. Data showing how this approach is superior to using an
actual rate divided by the expected rate needs to be provided. 4. Many of the
potentially preventable admissions contains diagnoses that do not meet the
proposed definition of potentially preventable readmissions; therefore, these
should be dropped. 5. The process for developing the list of potentially
preventable admissions used existing literature but would have benefited from
a more formal process such as the RAND appropriateness rating system (e.g.
modified Delphi approach) rather than ad hoc TEP and consultant experts.
6. Risk adjustment does not included: a. SES characteristics, an issue
identified in the last round of NQF readmission measure reviews as a
requirement. b. Functional status, one of the strongest predictors of
hospitalizations. All the PAC settings are now required to utilize standard
functional status assessment – Section GG from the CARE tool. c. The risk
adjustment variables are not specifically specified with respect to data
source and categories but are given as examples with just a descriptor. For
example is age continuous or categorical variable and if categorical how and
from what source? d. Prior utilization variables indicate they “vary by
measure” but how they vary by measure is not provided. 7. The exclusions are
confusing and need some modifications. a. The denominator exclusions appear
confusing and overlapping so that it is unclear if discharges from IRF or LTCH
to SNF or HH are included in the IRF and LTCH denominator. Similarly, if SNF
discharges to HH are included. b. We agree that AMA discharges from PAC
provider should be excluded but so should hospital discharges that are AMA but
end up in PAC provider. 8. The list of related to other NQF endorsed measures
is incomplete and only compares to CMS or RTI endorsed measures. All other
NQF endorsed measures should be included. 9. We agree with the expansion of
unplanned readmission diagnoses from YALE’s list, but will this also be
applied to the SNFRM and hospital readmission measures? (Submitted by:
AMDA-The Society for Post-Acute and Long-Term Care Medicine)
- (Early public comment)PointRight Inc., the leading provider of
web-based analytic services to SNFs nationwide, and the developer of the
NQF-endorsed PointRight Pro 30 measure of rehospitalizations from SNFs, is
pleased to offer comments on the proposed measure of potentially preventable
readmissions from SNFs (SNFPPR). We see the potential for enhancements in
the reporting of the SNFPPR that would make it much more valuable to
providers, payers and consumers, and would like to recommend these
enhancements NQF as the developers finalize the specification for their
measure. While other commenters have submitted comments on the methodology for
calculation of the SNFPPR, this is not our aim here. Instead, we are
advocating that the SNFPPR be reported in a distinctive way that will enhance
its acceptance, its clinical utility, and ultimately its impact on
provider-level and system-level performance improvement. We believe that there
will always be legitimate disagreements on optimal methods of defining
provider performance measures and adjusting them for clinical risk factors and
for measurement error. Our belief is that many such disagreements can be
mitigated by making the calculation methodology transparent to the measure’s
users, and by reporting the measure in a way that optimizes its integration
with complementary measures of the same domain of performance. In the case of
the SNFPPS, the complementary NQF-endorsed measure of rehospitalization is the
PointRight Pro 30 measure; this measure is based on MDS data rather than on
Medicare FFS claims. Our comments here will reference research that PointRight
has conducted using MDS data from CY2014, from a national sample of 1,766
Medicare-certified SNFs that were at least 97% complete in reporting the
outcomes of their post-acute stays. A more detailed report on that study and
its methodology is available to NQF upon request. The SNFPPR has certain
characteristics that make it an accurate measure of performance in many
circumstances but a potentially misleading one in others. These
characteristics are as follows: 1) The SNFPPR is based on Medicare FFS claims.
To the extent that a SNF has a relatively large number of post-acute
admissions that have other payers, and to the extent that its performance
differs by payer, the SNFPPR will be an inaccurate – or at the very least
incomplete – measure of a SNF’s performance. In general, post-acute stays of
Medicare Advantage and other non-Medicare FFS patients are shorter than
Medicare FFS stays, because financial incentives for SNFs are different, and
because proactive case management is more common when the payer is at risk. A
potential consequence of shorter SNF stays is a higher rate of
rehospitalizations after SNF discharge but within the 30 day window. Some
SNFs with a high managed care volume are able to reduce these indirect
rehospitalizations through intensive management of care transitions and
optimal timing of SNF discharge. Other SNFs do not succeed in doing this.
The SNFPPR measure does not distinguish these situations because it does not
cover non-FFS patients. A health plan that built its preferred provider
network or selected post-acute providers based on the SNFPPR alone might make
choices that actually led to an increase in its rehospitalization rates. This
issue has national scope and significance. For 25% of all SNFs in our
national sample the proportion of post-acute admissions that were not Medicare
FFS exceeded 29%. The 10% of SNFs with the highest proportion of non-Medicare
FFS post-acute admissions had a proportion in excess of 41%. The median
30-day direct rehospitalization rate was 26% for Medicare FFS patients, but
only 19% for non-Medicare FFS patients. 2) Research on rehospitalizations
across the entire post-acute continuum has shown that issues like functional
status, nutritional status and cognitive impairment that are not necessarily
captured by coded diagnoses can have a powerful effect on rehospitalization
rates. Facilities that treat a frail and debilitated elderly population will
look worse on the SNFPPR measure even after risk adjustment, and facilities
treating a more vigorous elderly population will look better on the SNFPPR
regardless of their true clinical performance. If discharge planners direct
patients based on the SNFPPR alone they may send frail patients to SNFs that
actually don’t do a good job with such patients, while reducing the census and
operating margins of some SNFs that do excel at managing highly vulnerable
patients. 3) The SNFPPR’s definition of a rehospitalization as potentially
preventable is based on an algorithm that may be more or less applicable to
particular patient populations, due to the interaction of non-measured
covariates with the claims-based information used in the algorithm. 4) The
use of predicted rather than observed numerators can mitigate problems of
non-representative ratios when denominators are small, but at the expense of
effacing genuine differences between facilities. A facility that persistently
has no potentially preventable readmissions, quarter after quarter, has
meaningfully different performance than one with an observed rate of 10%, even
if the predicted rate of the former facility is 10% when calculated one
quarter at a time. Predicted rates are not a substitute for observed rates
but rather a complement to them; aggregation of observed rates over time is an
alternative approach to dealing with errors related to small denominators. The
SNFPPR measure additional three features that limit its value for supporting
SNFs’ ongoing quality improvement programs: 5) A facility’s performance on the
SNFPPR can only be determined in retrospect. Thus, a facility cannot use the
measure’s methodology to prospectively identify patients at high risk, nor can
it continuously monitor the measure to quickly see the impact of a change in
its care processes. 6) The numerator does not distinguish between
rehospitalizations directly from the SNF and rehospitalizations from the
community following discharge from the SNF (but within 30 days of the hospital
discharge). Separating the two components of the numerator would enable a SNF
to know whether it has problems with discharge planning and care transitions
that contribute disproportionately to rehospitalizations. This is important
because care transitions have traditionally not been a major focus of
attention and resource deployment for SNFs. 7) The exclusion of
rehospitalizations from the denominator as “planned” is based on a
claims-based algorithm that does not necessarily agree with facilities’ own
categorization of rehospitalizations as planned. This can make it difficult
for a facility to target a change in its number of unplanned
rehospitalizations as categorized by the SNFPPR measure. In the PointRight
study cited above the proportion of direct rehospitalizations within 30 days
that were self-characterized as “planned” had a significantly skewed
distribution. (Proportion of rehospitalizations that were self-described as
planned: 10th percentile – 0%, 25th percentile – 3.4%, median – 6.8%, 75th
percentile – 11.1%, 90th percentile 16.8%) Since the distribution of the same
proportion determined by algorithm was not published, the extent of
disagreement cannot be determined. However, if the target of quality
improvement is reduction of unplanned rehospitalizations, this aim would be
better attained if facilities’ determinations of planned status and NQF’s
determination of planned status could be aligned. Recommendation: With these
considerations in mind PointRight suggests a change in reporting methodology
for the SNFPPR measure that will make the measure more transparent and more
useful for quality improvement, for payers’, hospitals’ and managed care
organizations’ development of post-acute care networks, and planning of care
transitions. The recommended changes in reporting will enable users to take
full advantage of the contemporaneous reporting of the SNFPPR with other,
complementary NQF-endorsed quality measures based on other data sources. The
recommended change in reporting would in fact be applicable, and valuable, for
other NQF-endorsed rehospitalization measures that are based on Medicare FFS
claims and have algorithm-based exclusion criteria. Concurrent interpretation
of complementary measures helps identify and make sense of situations where
claims-based expected rates may over-adjust or under-adjust for risk and
situations were where algorithm-based determinations of planned status or
potential preventability do not comport with clinical experience. Finally,
the separation of rehospitalizations into direct and indirect readmissions
makes the measure much more useful not only to SNFs but also to other users
such as hospitals, primary care physicians, payers and consumers. It enables
them to know whether a SNF’s primary weakness is with transitions of care from
SNF to community – a problem that parties upstream or downstream from the SNF
may be able to address proactively. Specifically, PointRight recommends that
reporting of the SNFPPR include the following items in addition to each SNF’s
predicted rate, expected rate, and adjusted rate of 30-day rehospitalizations
of the denominator population over the measurement period: 1) The observed
rate of rehospitalizations in the denominator population. 2) The observed rate
of rehospitalizations in the denominator population that took place directly
from the SNF to the acute care hospital, as opposed to from the community
following discharge from the SNF to the community. 3) The percentage of total
admissions to the SNF from acute care hospitals (i.e. potential members of the
denominator population) that were Medicare FFS. 4) The percentage of Medicare
FFS admissions to the SNF from acute care hospitals that was included in the
denominator population (i.e. not excluded from the denominator population
because of meeting one or more exclusion criteria). 5) The percentage of total
rehospitalizations of the denominator population excluded because the
hospitalizations were determined by algorithm to be planned. 6) The percentage
of total unplanned rehospitalizations of the denominator population excluded
from the numerator because the hospitalizations were determined by algorithm
to be not potentially preventable. 7) The actual count of the denominator
population, if this is permissible under HIPAA. In other words, the additional
data to be reported would provide the observed rate (and not just the
predicted rate), and would explain the relationship of the measure denominator
to the entirety of post-acute admissions, the relationship of the measure
numerator to the entirety of all rehospitalizations of the denominator
population, and the breakdown of the numerator into direct and indirect
rehospitalizations. (Submitted by: PointRight Inc.)
- (Early public comment)At least one NRHI member has expressed
concerns regarding this measure. Specifically, clinical staff at
HealthInsight have concerns with inclusion of this measure due to the validity
of and complicated methodologies used for "risk adjustment for patient
characteristics and a statistical estimate of the facility effect beyond
patient mix." This methodology is frequently cited as the basis for
determining potentially avoidable hospital facility admissions. This
methodology is not well-established. (Submitted by: Network for Regional
Healthcare Improvement)
(Program: Inpatient Rehabilitation Facility Quality
Reporting Program; MUC ID: MUC15-496) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- We are generally supportive of measuring PAC providers on potentially
preventable readmissions and believe that much of the work performed for these
measures is positive, such as the risk adjustment methodology. We believe
that the PAC industry should embrace measures, such as these PPR measures,
that help patients stay at home – a central tenant of post-acute care.
Accordingly, we value these PPR measures as useful tools in advancing that
goal. We have several comments that will serve as constructive additions to
the development of these measures. We hope that NQF and the measure
developers will analyze and consider these comments and how they could improve
the PPR measure development for IRFs. A. USE OF UPSTREAM DRGS; DIFFERENCES IN
SETTING-SPECIFIC MEASURES COULD CAUSE DIFFICULTY IN DATA COMPARISONS The
various PPR measure proposals each propose to rely on DRGs from the initial
hospital stay as the anchor condition for a PPR in a PAC setting. We are
concerned that the high level of variability in DRG coding practices amongst
upstream hospitals will present problems in the resulting PAC PPR data because
lack of consistency in initial DRG coding will have an effect on the number of
patients at a given PAC provider are “eligible” for inclusion in a
condition-based PPR measure. This dynamic would create a barrier to making
sound apples-to-apples PPR data comparisons. Another issue with using DRG
codes for the initial hospital stay is that such codes are often unreliable
indicators as to why a particular patient is referred to a particular PAC
setting, not to mention why they are eventually readmitted after the PAC stay.
For example, a patient admitted to the hospital for congestive heart failure
and who is treated in a subsequent PAC setting may end up returning to the
hospital during the 30-day post-PAC discharge window not for reasons
associated with congestive heart failure, but because he was not properly
hydrating. Although this readmission would count under the PPR measure, it
would not capture the actual reason the patient was readmitted. By
implementing a post-PAC discharge PPR measure that is coded all the way back
to the initial hospital DRG risks missing the clinical reason that was present
within the particular PAC setting at the time of readmission. Similarly,
we note that IRFs are the only provider for which a “within stay” measure is
being developed (for the IRF QRP, not under the IMPACT Act per se). Although
already in place for HHAs, we believe that such “within stay” PPR measures
could also be helpful and are possible for LTCHs as well, and ask CMS and RTI
to consider creating such a measure to enable more congruity into future PPR
comparisons between all PAC providers. The SNF 30-day post hospital discharge
measure, while covering at least some part of a SNF stay, is also incongruent
because it would fail to capture any “within stay” PPRs that occur when a
patient is still in a SNF 30 days after discharge from the acute hospital.
Although these differences are minor, they present concerns when considering
the ability of future policy makers to make direct comparisons within the PAC
industry. B. RISK ADJUSTMENT FOR SOCIODEMOGRAPHIC AND FUNCTIONAL STATUS
The draft specifications indicate that the PPR measures will all be
risk-adjusted for multiple variables, including age, sex, dialysis status, and
for the IRF measures, aggregates of the IRF case-mix groups. We support this
broad range of risk adjustment, but also believe that CMS and RTI should
consider including risk adjustment for sociodemographic factors and functional
status as well. Recent academic literature has added evidence to the notion
that readmissions back to hospitals are driven by more directly by patient
status factors and not by the quality of care delivered. Furthermore, NQF in
April began a two-year trial program of a temporary policy change that would
allow risk adjustment of performance measures for socioeconomic and other
demographic factors, a departure from earlier quality measurement positions
that viewed sociodemographic risk adjustment as inappropriate. However, with
evidence that sociodemographic risk is real and impact readmission rates, we
recommend that the measure developers consider including it in the list of
risk adjustment factors for these measures. We also believe adjusting for
functional status would benefit the accuracy of the PPR measures. Functional
status has a direct correlation with a patient’s ability to remain healthy at
home after PAC services have ended, meaning that PAC providers who treat more
functionally impaired patients will likely have a higher PPR rate.
Accordingly, we recommend that the measure developers consider how to apply an
additional risk-adjustment factor for functional status in the overall risk
adjustment methodology. C. RISK OF CONFUSION IN MULTIPLE READMISSION MEASURES
As part of the existing IRF PPS Quality Reporting Program (“IRF QRP”), IRFs
already report All-cause Unplanned Readmission (NQF #2502) and are scheduled
to have this measure publicly reported beginning next year. Other PAC types
will also require public reporting of a general all-cause readmissions
measure. We are concerned that, as required by the IMPACT Act, the eventual
public reporting of these PPR measures (which are essentially a subset of the
more general all-cause measures) will result in substantial confusion amongst
members of the public. For example, if both measures are publicly reported,
PAC providers will have one all-cause unplanned readmission rate, but likely a
different PPR rate. We question whether the crucial distinctions between
these two different, but related, readmissions measures will be readily
apparent to members of the public who take the time to assess different PAC
providers based on readmission rates. Similarly, providers may have trouble
accurately understanding the purpose and ultimate use of additional
readmissions measures. IRF providers already receive annual PEPPER reports
and also report on the All-cause measure (NQF #2502). With the addition of a
“within stay” measure and a post-discharge PPR measure to these existing
readmission measures, CMS should take deliberate steps to clearly communicate
the intended use for each of these four readmission tools and how they will
relate to one another. Without such clarifying communication, providers may
find themselves adrift in various readmissions data without a clear idea of
how it is all being used by the Agency. This is another example, similar
to the IRF short-stay/transfer case considerations discussed above, of the
reconciliation issues that CMS must face in overlaying IMPACT Act
requirements with existing PAC regulations, and insofar as NQF and the measure
developers can eliminate the duplicative requirements of IMPACT Act
implementation, including overlapping public reporting of two “flavors” of
readmissions, we highly encourage them to do so. Indeed, the IMPACT Act
encourages CMS to refrain from duplication in methods for data collection, and
we recommend that this theme be extended to other parts of IMPACT Act
implementation as well. NQF also has policies against endorsing measures that
have unnecessarily duplicative functions with existing measures. (Submitted
by: HealthSouth)
- FAH supports the workgroup's recommendation and rationale. FAH shares many
of the workgroup's concerns, particularly the concern about appropriate risk
adjustment and the potential conflict with other readmission measures. We
strongly urge NQF to require developers to explore additional SDS factors
beyond the current variables that are often used in the analysis (e.g., dual
eligible status, race) and ask that MAP make clear recommendations to CMS that
a broader set of variables should be included in the measures submitted for
future consideration. We request that the measure be fully tested before it is
considered for a future payment program. (Submitted by: Federation of American
Hospitals)
- AMRPA has historically supported readmissions measures within a
post-discharge window such as 30 days. A similar measure is included in the
IRF QRP, an all cause unplanned 30 day post IRF discharge readmission measure.
CMS should clarify its intent to replace the existing IRF QRP measure with
this new measure once it is adopted. A properly constructed readmission
measure has the potential to improve the outcomes for the patients IRFs treat.
However, before MUC 496 is adopted, we encourage CMS to modify how it
identifies a readmission as potentially preventable. The draft measure
specifications state that the potentially preventable readmission (PPR) is
based on the acute care hospital diagnosis. But this diagnosis, as represented
by the ICD code, is not always the rationale for admission to the IRF.
Instead, using data from the Inpatient Rehabilitation Facility Patient
Assessment Instrument (IRF PAI) might more accurately demonstrate when a
planned readmission to the acute care hospital is appropriate. For example,
Patient A is a C6 tetraplegic who is unexpectedly admitted to acute care from
the IRF for autonomic dysreflexia. In this scenario, the rationale for the
unplanned readmission to the acute care is rarely seen in the acute care
hospital but is not uncommon in the IRF setting. Additionally, the readmission
might not have been preventable meaning the IRF may be inappropriately
penalized for an unplanned readmission. The measure also fails to account for
planned readmissions that might be inappropriate. Finally, with regard to a
PPR, the clinical literature does not support the inclusion of inadequate
prophylaxis as a rationale for deeming a readmission as potentially
preventable. For example, increasingly chest guidelines are demonstrating the
role of deep vein thrombosis and pulmonary embolism prevention in PAC
settings. However, the literature is less clear on the ability to prevent
stress ulcers in IRFs. Therefore, it cannot be said that inadequate
prophylaxis is inextricably linked to PPRs in all cases. We also believe that
atrial fibrillation and flutter should be separated for the purposes of PPR.
While we appreciate the Agency’s attempt to minimize data collection and
reporting burden by using two years of claims data, we believe patient
characteristic data including diagnosis, comorbidities and complexities,
length of stay, motor and cognitive function, and discharge destination are
also critically important to collect. Fortunately the industry already
collects such information via the IRF PAI. We also recommend that the risk
adjustment methodology be modified to include socioeconomic and
sociodemographic factors. Finally, CMS recently closed a public comment
process seeking feedback on the draft measure specifications. Given that this
is a newly developed measure that has not yet completed the CMS development
process, it may be premature to endorse this measure for the purpose of the
IRF QRP. (Submitted by: American Medical Rehabilitation Providers
Association)
- We agree with MAP members’ concerns about potential overlap between
readmission measures as well as unintended consequences of these measures if
not appropriately risk adjusted. As currently outlined, the exclusion criteria
of SNF stays with a gap of greater than one day between discharge from the
prior proximal hospitalization and admission to a SNF fails to consider a
medically complex patient that is treated in an IRF and subsequently
readmitted within 30 days for an issue that may have been treated as a
comorbidity. Given that a prior proximal hospitalization is defined as an
inpatient admission to an acute care hospital, critical access hospital, or a
psychiatric hospital, and IRFs are licensed as hospitals, we believe that
admission to an IRF should be considered a proximal hospitalization and
disagree that patients who are clinically different should be excluded. ARN
also questions the rationale behind the exclusion for SNF stays where the
patient had one or more intervening PAC admissions which occurred either
between the prior proximal hospital discharge and SNF admission or after the
SNF discharge, within the 30-day risk window as well as SNF admissions where
the patient had multiple SNF admissions after the prior proximal
hospitalization, within the 30-day risk window. The rationale states that
“when patients have multiple PAC admissions, evaluating quality of care
coordination is confounded and even controversial in terms of attributing
responsibility for a readmission among multiple PAC providers. Similarly,
assigning responsibility for a readmission for patients who have multiple SNF
admissions subsequent to their prior proximal hospitalization is also
controversial.” ARN believes that this rationale could apply to any PAC
setting and therefore, disagrees with having this as an exclusion from the SNF
denominator. Moreover, in regards to the within-stay criteria, IRFs have
experienced a rise in the number of patients who must return to the acute
inpatient care setting within 48-72 hours of admission due to the disparity
between the level of care which their condition (either a co-morbidity or
complication secondary to the presenting diagnosis) requires and the level of
care that an IRF is able to provide. An example of this is leukemia patients
as many times they require inpatient rehabilitation to discharge them from the
hospital and that the patient’s survival may be related to their functional
status and rehabilitation can improve function and symptoms such as fatigue,
well-being, and pain. To this end, ARN disagrees with the within-stay
criteria delineated for IRFs and believes that in specific instances,
readmissions are a necessity for patient safety, and not necessarily
preventable. (Submitted by: Association of Rehabilitation Nurses)
- (Early public comment)APTA supports the goal of improving the
quality of health care. Physical therapists are committed to providing
high-quality, timely care and to the promotion of evidence-based and
patient-centered practice. Furthermore, APTA feels that it is essential that
we move towards a common set of quality measures across the across the
continuum of care. APTA supports the implementation of readmissions measures
across the care settings, as approximately 20% of all Medicare patients are
readmitted within 30 days of an acute care discharge and readmissions account
for an estimated $17 billion in health care spending. APTA is pleased to see
that the draft specifications for these measures align with existing
methodologies of other readmissions measures. We believe that potentially
preventable readmissions measures will focus providers on those patients who
are expected to have successful transitions to the community follow in
discharge from the respective post-acute care settings. However, the APTA
does have some concerns regarding the proposed measure methodology. These
concerns are discussed below. APTA believes that a patient’s level of function
does impact the potential for readmissions. Recent evidence indicates that
patient function is associated with increased risk of 30-day all-cause
hospital readmissions and may be an important factor in preventing
readmissions for Medicare seniors that is not currently accounted for in
measure methodologies1. APTA is pleased to see “activity of daily living”
scores included in the risk adjustment methodology, however, we note that this
is only included for those patients in the home health setting. We would
encourage measure developers to include this as a risk adjustment variable in
all readmissions measures. APTA appreciates that CMS has strict deadlines
for the implementation of measures under the IMPACT act, however, as these
measures will be new to the respective post-acute care settings we encourage
that settings have the ability to review this data as early as possible in
order to understand the data and, more importantly, so that the respective
setting have time to implement strategies to decrease readmissions where
necessary. As many of these settings do not always receive feedback on the
readmissions of their patients post-discharge, this data will be new to many
facilities. Additionally, skilled nursing facilities and inpatient
rehabilitation facilities will be trying to manage two measures, one within
stay, and one post-discharge. APTA recognizes that the overall goal of
IMPACT is for PAC providers (HH, IRF, SNF and LTCH) to collect and report
standardized and interoperable patient assessment data, quality and resource
use measures. We acknowledge that during the initial IMPACT implementation
years that there will be a transition period which will include the addition
of new measures into all of the post-acute care settings. We believe that
achieving a standardized and interoperable patient assessment data set and
stable quality measures as quickly as possible will allow for better
cross-setting comparisons as well as the evolution of better quality measures
with uniform risk standardization, thus achieving the true aim of IMPACT. 1
Greysen SR, Cenzer IS, Auerbach AD, Covinsky KE. Functional Impairment and
Hospital Readmission in Medicare Seniors. JAMA Intern Med.
2015;175(4):559-565. (Submitted by: American Physical Therapy
Association)
- (Early public comment)We would like to note the following concerns
regarding the development of these measures: 1. Measure development for the
IMPACT Act appears to create 4 separate measures that are site specific with
their own set of criteria and risk adjustment factors. The IMPACT Act aims to
create quality measurement within Post-Acute Care (PAC) that is "standardized
and interoperable". By developing measures which differ in their calculation,
such as site-specific inclusion/exclusion criteria or risk-adjustment factors,
PAC sites will be subjected to comparisons of quality that do not differ based
upon the quality of care provided, but rather the differences inherent in the
measure calculations. We strongly recommend that CMS and the measure
developers produce a measure that is calculated in a "standardized and
interoperable" manner with inclusion/exclusion criteria and risk-adjustment
factors the are applied consistently across all PAC sites. 2. The measures
developed for the IMPACT Act hold PAC providers responsible for circumstances
that occur outside of their control. While PAC providers are responsible for
providing care that allows patients safe transitions to their next setting or
home, holding these providers accountable fora time period in which they are
not furnishing care should not differentiate the quality of care they actually
provided. In Appendix A, Table A1 lists various conditions that define
potentially preventable hospital readmission for 30-days post-PAC discharge.
In this list, conditions such as Asthma, Congestive Heart Failure, and
Dehydration are listed as a reason for a potentially preventable readmission.
So if the patient fails to care for themselves post-discharge (against the
advice and discharge instructions provided by a PAC provider) and requires
readmission to Acute Care for one of these conditions, the PAC provider is
penalized even though the patient is no longer being cared for by the PAC
provider. We strongly recommend that CMS and the measure developers produce a
measure that represents the quality of care provided by PAC providers while
the patient is in their care. (Submitted by: UDSMR)
- (Early public comment)AMRPA has historically supported readmissions
measures within a post-discharge window such as 30 days. A similar measure is
included in the IRF QRP, an all cause unplanned 30 day post IRF discharge
readmission measure. CMS should clarify its intent to replace the existing IRF
QRP measure with this new measure once it is adopted. A properly constructed
readmission measure has the potential to improve the outcomes for the patients
IRFs treat. However, before MUC 496 is adopted, we encourage CMS to modify
how it identifies a readmission as potentially preventable. The draft measure
specifications state that the potentially preventable readmission (PPR) is
based on the acute care hospital diagnosis. But this diagnosis, as represented
by the ICD code, is not always the rationale for admission to the IRF.
Instead, using data from the Inpatient Rehabilitation Facility Patient
Assessment Instrument (IRF PAI) might more accurately demonstrate when a
planned readmission to the acute care hospital is appropriate. For example,
Patient A is a C6 tetraplegic who is unexpectedly admitted to acute care from
the IRF for autonomic dysreflexia. In this scenario, the rationale for the
unplanned readmission to the acute care is rarely seen in the acute care
hospital but is not uncommon in the IRF setting. Additionally, the readmission
might not have been preventable meaning the IRF may be inappropriately
penalized for an unplanned readmission. The measure also fails to account for
planned readmissions that might be inappropriate. With regard to a PPR, the
clinical literature does not support the inclusion of inadequate prophylaxis
as a rationale for deeming a readmission as potentially preventable. For
example, increasingly chest guidelines are demonstrating the role of deep vein
thrombosis and pulmonary embolism prevention in PAC settings. However, the
literature is less clear on the ability to prevent stress ulcers in IRFs.
Therefore, it cannot be said that inadequate prophylaxis is inextricably
linked to PPRs in all cases. We also believe that atrial fibrillation and
flutter should be separated for the purposes of PPR. While we appreciate the
Agency’s attempt to minimize data collection and reporting burden by using two
years of claims data, we believe patient characteristic data including
diagnosis, comorbidities and complexities, length of stay, motor and cognitive
function, and discharge destination are also critically important to collect.
Fortunately the industry already collects such information via the IRF PAI. We
also recommend that the risk adjustment methodology be modified to include
socioeconomic and sociodemographic factors. Finally, CMS recently closed a
public comment process seeking feedback on the draft measure specifications.
Given that this is a newly developed measure that has not yet completed the
CMS development process, it may be premature to endorse this measure for the
purpose of the IRF QRP. (Submitted by: American Medical Rehabilitation
Providers Association)
- (Early public comment)This measure will encourage post-acute care
providers to optimize care for patients before discharge. (Submitted by:
Smith & Nephew )
- (Early public comment)ARN is pleased CMS has proposed discharge
measure exclusions; however, we disagree with the proposed exclusion criteria
of patients less than 18 years old. Many IRFs treat patients younger than 21
when necessary, is reflected by the Functional Independence Measure (FIM) and
IRF-Patient Assessment Instrument (PAI), both of which are used to assess
patients age seven or older. ARN encourages CMS not to exclude patients under
18 years old from the discharge measures. We also recommend that CMS ensure
the data collection time frame is the same for all PAC settings. Currently,
the time frame for the initial data collection for the project varies from one
year (SNFs), two years (IRFs and LTCHs), and three years (HHAs), we urge the
Agency to implement one standard reporting time frame across PAC providers.
While reporting may be based on either one year of data, two years of data,
etc., we strongly recommend CMS and its subcontractors address the
inconsistent reporting periods. Moreover, in regards to the within-stay
criteria, IRFs have experienced a rise in the number of patients who must
return to the acute inpatient care setting within 48-72 hours of admission due
to the disparity between the level of care which their condition (either a
co-morbidity or complication secondary to the presenting diagnosis) requires
and the level of care that an IRF is able to provide. An example of this is
leukemia patients as many times they require inpatient rehabilitation to
discharge them from the hospital and that the patient’s survival may be
related to their functional status and rehabilitation can improve function and
symptoms such as fatigue, well-being, and pain. To this end, ARN disagrees
with the within-stay criteria delineated for IRFs and believes that in
specific instances, readmissions are a necessity for patient safety, and not
necessarily preventable. Finally, while ARN is generally supportive of the
potentially preventable readmissions measure specifications, we have several
concerns. As ARN has stated in previous comment letters, the IRF measure is
based on 24 months of data while the SNF measure is based on 12 months of
data. PAC facilities should not be penalized for conditions that prompt
readmissions that are unrelated to the patient’s initial reason for admission.
Moreover, as previously stated, we oppose CMS’s proposal to require PAC
providers to utilize 30-day readmission claims data to determine their
readmission rates. Using claims data to calculate readmission rates will be
difficult for IRFs and other PAC settings, as claims data are cumbersome to
use and access. Employing a 30-day readmission rate measure will not provide
meaningful insight or have an impact on quality improvement efforts if PAC
settings do not have unrestricted access to the data. (Submitted by:
Association of Rehabilitation Nurses)
- (Early public comment)This set of potentially preventable
readmission (PPR) measures for post-acute care (PAC) estimates the
risk-standardized rate of unplanned, potentially preventable readmissions for
patients (Medicare fee-for-service [FFS] beneficiaries) who receive services
in one of the following post-acute care provider types: skilled nursing
facilities (SNFs), inpatient rehabilitation facilities (IRFs), long-term care
hospitals (LTCH), and home health agencies (HHA). These outcome measures
reflect readmission rates for patients who are readmitted to a short-stay
acute-care hospital or an LTCH with a principal diagnosis considered to be
unplanned and potentially preventable. Six PPR PAC measures are being
developed: • Four of these measures assess PPR within a 30-day window
following discharge from PAC—one measure for each PAC setting (i.e., SNF,
IRF, LTCH, and HH)—and are being developed to meet the requirements of the
IMPACT Act. • An additional SNF measure (SNF PPR), which is being developed
to meet the PAMA requirements, assesses PPR during the 30-day period following
a hospital discharge to a SNF setting. • An additional IRF measure assesses
PPR during the IRF stay (referred to as the within-stay window) which is being
developed for use in the IRF Quality Reporting Program. Of note with respect
to potentially preventable readmissions and a patient’s occupational therapy
needs, several recent studies consider whether returning to the community from
a recent hospitalization with unmet activities of daily living (ADL) need was
associated with probability of readmission. The findings from these studies
indicate that this indeed may be a considerable risk factor. The studies
reveal that any older patients are discharged from the hospital with ADL
disability. Those who report unmet need for new ADL disabilities after they
return home from the hospital are particularly vulnerable to readmission. This
area is not typically addressed in a thorough manner through current discharge
practices. This needs to change. Patients' functional needs after discharge
should be carefully evaluated and addressed. Factors such as enabling
self-management and ensuring appropriate medication management and ADLs, such
as cooking and eating are addressed, can have a direct effect on readmissions
The profession of occupational therapy is built on delivering
patient-centered care, seeking to keep the patient at the highest functional
level in the least restrictive setting and to reduce caregiver burden and
health care system resource utilization. Occupational therapy directly
addresses the enablement of successful performance of ADLs. This focus,
experience and research base in occupational therapy must be fully tapped to
address this component of readmission prevention. A further issue is that
Self-management is a key element in successful care, and occupational
therapists are experts in motivation, task analysis, and psychosocial
contexts, which all contribute to enabling positive outcomes. In order to
successfully re-establish or establish new routines and habits to meet health
care needs, such as medication management, proper sleep hygiene, and following
other medical directives, is within the scope and proven effectiveness of
occupational therapy. AOTA would encourage CMS to examine more fully,
perhaps through pilot testing, the value of occupational therapy evaluation
and intervention participation as part of discharge planning. This could
identify more clearly specific ADL limitations prior to and after discharge
and assure proper interventions are provided that address fully and completely
the range of ADL and other activity restrictions and capacities to enable
optimum recovery from the condition as well as optimum participation of the
client in their own care. With respect to the IRF Readmission measure, AOTA
makes the following comments: • IRFs are subject to a reduced payment if the
patient is transferred to the acute care hospital before meeting the average
length of stay for the condition. Therefore, if there is a measure that tracks
readmissions occurring during the IRF stay, the IRF could be subject to two
payment reductions simultaneously: one payment reduction for the transfer and
a second for the readmission. For this reason, AOTA recommends that the PPR
penalty only apply to IRF transfers not subject to the transfer policy. • AOTA
recommends that the draft Specifications for IRF PPR measure risk adjustment
consider the following factors: o Age; o Sex; o Original reason for Medicare
entitlement (age, disability, or ESRD); o Surgery category, if present;
o Receiving dialysis in prior short-term stay; o Principal diagnosis on prior
short-term claim; o Comorbidities from secondary diagnoses on the prior
short-term claim and diagnoses from earlier short-term stays up to one year
before the post-acute care admission; o Aggregates of the IRF case-mix groups
(IRF-specific exclusion) AOTA has reviewed the readmissions measures released
for comment and makes the following general comments: • The PPR measures
Numerator and Denominator definition language are consistent from previous
materials. • The Readmissions Measures are based on two years of claims data.
Use of multiple years is acceptable in the measure review process. • The
exclusion criteria for the various measures are associated with the Yale/New
Haven readmission measures. Co-developed by the Centers for Medicare &
Medicaid Services (CMS) and researchers at Yale University, estimates the
risk-standardized rate of unplanned, all-cause readmissions to a hospital for
any eligible condition within 30 days of hospital discharge for patients aged
18 and older. The CMS/Yale measure is specified for evaluating hospital
performance. AOTA would prefer for the exclusion criteria to be specified for
evaluating performance in post-acute care settings. (Submitted by: American
Occupational Therapy Association)
- (Early public comment)At least one NRHI member has expressed
concerns regarding this measure. Specifically, clinical staff at
HealthInsight have concerns with inclusion of this measure due to the validity
of and complicated methodologies used for "risk adjustment for patient
characteristics and a statistical estimate of the facility effect beyond
patient mix." This methodology is frequently cited as the basis for
determining potentially avoidable hospital facility admissions. This
methodology is not well-established. (Submitted by: Network for Regional
Healthcare Improvement)
- (Early public comment)We are generally supportive of measuring PAC
providers on potentially preventable readmissions and believe that much of the
work performed for these measures is positive, such as the risk adjustment
methodology. We believe that the PAC industry should embrace measures, such
as these PPR measures, that help patients stay at home – a central tenant of
post-acute care. Accordingly, we value these PPR measures as useful tools in
advancing that goal. We have several comments that will serve as constructive
additions to the development of these measures. We hope that NQF and the
measure developers will analyze and consider these comments and how they could
improve the PPR measure development for IRFs. B. USE OF UPSTREAM DRGS;
DIFFERENCES IN SETTING-SPECIFIC MEASURES COULD CAUSE DIFFICULTY IN DATA
COMPARISONS The various PPR measure proposals each propose to rely on DRGs
from the initial hospital stay as the anchor condition for a PPR in a PAC
setting. We are concerned that the high level of variability in DRG coding
practices amongst upstream hospitals will present problems in the resulting
PAC PPR data because lack of consistency in initial DRG coding will have an
effect on the number of patients at a given PAC provider are “eligible” for
inclusion in a condition-based PPR measure. This dynamic would create a
barrier to making sound apples-to-apples PPR data comparisons. Another issue
with using DRG codes for the initial hospital stay is that such codes are
often unreliable indicators as to why a particular patient is referred to a
particular PAC setting, not to mention why they are eventually readmitted
after the PAC stay. For example, a patient admitted to the hospital for
congestive heart failure and who is treated in a subsequent PAC setting may
end up returning to the hospital during the 30-day post-PAC discharge window
not for reasons associated with congestive heart failure, but because he was
not properly hydrating. Although this readmission would count under the PPR
measure, it would not capture the actual reason the patient was readmitted.
By implementing a post-PAC discharge PPR measure that is coded all the way
back to the initial hospital DRG risks missing the clinical reason that was
present within the particular PAC setting at the time of readmission.
Similarly, we note that IRFs are the only provider for which a “within stay”
measure is being developed (for the IRF QRP, not under the IMPACT Act per se).
Although already in place for HHAs, we believe that such “within stay” PPR
measures could also be helpful and are possible for LTCHs as well, and ask CMS
and RTI to consider creating such a measure to enable more congruity into
future PPR comparisons between all PAC providers. The SNF 30-day post
hospital discharge measure, while covering at least some part of a SNF stay,
is also incongruent because it would fail to capture any “within stay” PPRs
that occur when a patient is still in a SNF 30 days after discharge from the
acute hospital. Although these differences are minor, they present concerns
when considering the ability of future policy makers to make direct
comparisons within the PAC industry. C. RISK ADJUSTMENT FOR
SOCIODEMOGRAPHIC AND FUNCTIONAL STATUS The draft specifications indicate that
the PPR measures will all be risk-adjusted for multiple variables, including
age, sex, dialysis status, and for the IRF measures, aggregates of the IRF
case-mix groups. We support this broad range of risk adjustment, but also
believe that CMS and RTI should consider including risk adjustment for
sociodemographic factors and functional status as well. Recent academic
literature has added evidence to the notion that readmissions back to
hospitals are driven by more directly by patient status factors and not by the
quality of care delivered. Furthermore, NQF in April began a two-year trial
program of a temporary policy change that would allow risk adjustment of
performance measures for socioeconomic and other demographic factors, a
departure from earlier quality measurement positions that viewed
sociodemographic risk adjustment as inappropriate. However, with evidence
that sociodemographic risk is real and impact readmission rates, we recommend
that the measure developers consider including it in the list of risk
adjustment factors for these measures. We also believe adjusting for
functional status would benefit the accuracy of the PPR measures. Functional
status has a direct correlation with a patient’s ability to remain healthy at
home after PAC services have ended, meaning that PAC providers who treat more
functionally impaired patients will likely have a higher PPR rate.
Accordingly, we recommend that the measure developers consider how to apply an
additional risk-adjustment factor for functional status in the overall risk
adjustment methodology. D. RISK OF CONFUSION IN MULTIPLE READMISSION MEASURES
As part of the existing IRF PPS Quality Reporting Program (“IRF QRP”), IRFs
already report All-cause Unplanned Readmission (NQF #2502) and are scheduled
to have this measure publicly reported beginning next year. Other PAC types
will also require public reporting of a general all-cause readmissions
measure. We are concerned that, as required by the IMPACT Act, the eventual
public reporting of these PPR measures (which are essentially a subset of the
more general all-cause measures) will result in substantial confusion amongst
members of the public. For example, if both measures are publicly reported,
PAC providers will have one all-cause unplanned readmission rate, but likely a
different PPR rate. We question whether the crucial distinctions between
these two different, but related, readmissions measures will be readily
apparent to members of the public who take the time to assess different PAC
providers based on readmission rates. Similarly, providers may have trouble
accurately understanding the purpose and ultimate use of additional
readmissions measures. IRF providers already receive annual PEPPER reports
and also report on the All-cause measure (NQF #2502). With the addition of a
“within stay” measure and a post-discharge PPR measure to these existing
readmission measures, CMS should take deliberate steps to clearly communicate
the intended use for each of these four readmission tools and how they will
relate to one another. Without such clarifying communication, providers may
find themselves adrift in various readmissions data without a clear idea of
how it is all being used by the Agency. This is another example, similar
to the IRF short-stay/transfer case considerations discussed above, of the
reconciliation issues that CMS must face in overlaying IMPACT Act requirements
with existing PAC regulations, and insofar as NQF and the measure developers
can eliminate the duplicative requirements of IMPACT Act implementation,
including overlapping public reporting of two “flavors” of readmissions, we
highly encourage them to do so. Indeed, the IMPACT Act encourages CMS to
refrain from duplication in methods for data collection, and we recommend that
this theme be extended to other parts of IMPACT Act implementation as well.
NQF also has policies against endorsing measures that have unnecessarily
duplicative functions with existing measures. (Submitted by:
HealthSouth)
(Program: Inpatient Rehabilitation Facility Quality
Reporting Program; MUC ID: MUC15-497) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The AHA agrees with the MAP’s comments on this measure. Furthermore, we
strongly urge that any categories and lists of “potentially preventable
readmissions” be based on careful evaluation by clinical experts and detailed
testing. We appreciate that a technical expert panel (TEP) was consulted on
the list of categories and codes of readmissions considered “potential
preventable.” However, we strongly encourage CMS to undertake additional
empirical testing to ensure there is evidence that the codes actually are
associated with the identified categories. In addition, we are concerned that
this measure may be duplicative of the existing IRF readmission measure. The
existing IRF readmission measure assesses “all cause” readmissions, while this
proposed measure focuses on ‘potentially preventable’ readmissions.
Conceptually, there is potential value to focusing readmission measurement
efforts on those readmissions that are truly preventable. However, the measure
is similar enough to the existing IRF measure that we believe using both could
lead to confusion about the true state of performance. (Submitted by: American
Hospital Association (AHA))
- We are generally supportive of measuring PAC providers on potentially
preventable readmissions and believe that much of the work performed for these
measures is positive, such as the risk adjustment methodology. We believe
that the PAC industry should embrace measures, such as these PPR measures,
that help patients stay at home – a central tenant of post-acute care.
Accordingly, we value these PPR measures as useful tools in advancing that
goal. We have several comments that will serve as constructive additions to
the development of these measures. We hope that NQF and the measure
developers will analyze and consider these comments and how they could improve
the PPR measure development for IRFs. A. THE IRF “WITHIN STAY” MEASURE SHOULD
ACCOUNT FOR THE EXISTING THREE-DAY SHORT STAY AND TRANSFER CARE POLICIES FOR
IRFS The measure specification document states that the IRF “within stay”
measure “is intended to capture readmissions during the IRF stay (i.e. program
interruptions where the patient is readmitted to the acute care setting) and
readmissions (i.e. [sic] acute care transfers) at the end of the IRF stay.”
This specification does not detail precisely when the measure would begin
capturing such readmissions, but the “within stay” measure should not apply
until day four or after from a patient’s date of admission to the IRF. IRFs
are currently subject to a policy under the IRF Prospective Payment System
(“PPS”) that provides a uniform payment for certain cases with a
length-of-stay not exceeding 3 days. This three-day window was designed by
CMS to help ensure that IRFs have enough time to fully assess whether a
patient admitted to the IRF remains in need of IRF services. According to
CMS, “an IRF is eligible to receive the IRF short stay payment for 3 days or
less if a patient’s thorough preadmission screening shows that the patient is
an appropriate candidate for IRF care but then something unexpected happens
between the preadmission screening and the IRF admission such that the patient
is no longer an appropriate candidate for IRF care on admission and the day
count is greater than 3.” Therefore, since the IRF PPS already accounts
for admission of some patients who are subsequently determined by day 3 of the
IRF stay as no longer needing IRF services by reimbursing the IRF by paying a
lower rate, the IRF “within stay” PPR measure should not further penalize IRFs
for readmissions that occur within the same time period. There is precedent
for this accommodation for short-stay policies within other PAC readmissions
measures already: the existing home health “within stay” rehospitalization
measure specifically excludes stays that begin with a Low-Utilization Payment
Adjustment (“LUPA”) (i.e., stays with four or fewer home health visits, the
equivalent of short-stays in IRFs). Short stays in any PAC provider should be
excluded from the PPR measure because the PAC provider will not have the
opportunity to meaningfully deliver care to a patient. As such, it would be
unfair to attribute the cause of the readmission to the PAC provider when they
are so limited in what they can do within the short-stay window. To the
extent that CMS and RTI develop true “within stay” PPR measures for SNFs and
LTCHs in the future, we believe those measures should also account for short
stays policies. Similarly, the existing IRF transfer policy provides
that, for patients who are transferred from an IRF to a hospital, LTCH, SNF,
or other IRF, and whose length of stay is less than the average length of stay
for the pertinent CMG, the transferring IRF receives a per diem payment, the
rate of which is calculated by dividing the typical per discharge CMG payment
by the average length of stay. Therefore, because this policy reduces IRF
payment automatically from the normal CMG payment for cases that are
discharged early, it functions to discourage IRFs from making such early
discharges. If a “within stay” PPR measure were to start too early into IRF
stays, these two policies would overlap and any transfers would effectively
cause a double penalty – a lower payment under the transfer policy as well as
a PPR “ding.” Accordingly, in order to avoid applying two separate payment
disincentives to a single event, an IRF “within stay” PPR measure should
either begin capturing readmissions after the average length of stay passes,
or currently-defined transfers that would also qualify as a PPR should no
longer be counted as transfers. We recommend that NQF and the measure
developers consider the intersections of these potentially overlapping
policies and structure the IRF “within stay” PPR measure to begin on or after
day four of the IRF stay, and not to conflict with the existing transfer
policy. B. USE OF UPSTREAM DRGS; DIFFERENCES IN
SETTING-SPECIFIC MEASURES COULD CAUSE DIFFICULTY IN DATA COMPARISONS The
various PPR measure proposals each propose to rely on DRGs from the initial
hospital stay as the anchor condition for a PPR in a PAC setting. We are
concerned that the high level of variability in DRG coding practices amongst
upstream hospitals will present problems in the resulting PAC PPR data because
lack of consistency in initial DRG coding will have an effect on the number of
patients at a given PAC provider are “eligible” for inclusion in a
condition-based PPR measure. This dynamic would create a barrier to making
sound apples-to-apples PPR data comparisons. Another issue with using DRG
codes for the initial hospital stay is that such codes are often unreliable
indicators as to why a particular patient is referred to a particular PAC
setting, not to mention why they are eventually readmitted after the PAC stay.
For example, a patient admitted to the hospital for congestive heart failure
and who is treated in a subsequent PAC setting may end up returning to the
hospital during the 30-day post-PAC discharge window not for reasons
associated with congestive heart failure, but because he was not properly
hydrating. Although this readmission would count under the PPR measure, it
would not capture the actual reason the patient was readmitted. By
implementing a post-PAC discharge PPR measure that is coded all the way back
to the initial hospital DRG risks missing the clinical reason that was present
within the particular PAC setting at the time of readmission. Similarly,
we note that IRFs are the only provider for which a “within stay” measure is
being developed (for the IRF QRP, not under the IMPACT Act per se). Although
already in place for HHAs, we believe that such “within stay” PPR measures
could also be helpful and are possible for LTCHs as well, and ask CMS and RTI
to consider creating such a measure to enable more congruity into future PPR
comparisons between all PAC providers. The SNF 30-day post hospital discharge
measure, while covering at least some part of a SNF stay, is also incongruent
because it would fail to capture any “within stay” PPRs that occur when a
patient is still in a SNF 30 days after discharge from the acute hospital.
Although these differences are minor, they present concerns when considering
the ability of future policy makers to make direct comparisons within the PAC
industry. C. RISK ADJUSTMENT FOR SOCIODEMOGRAPHIC AND FUNCTIONAL STATUS
The draft specifications indicate that the PPR measures will all be
risk-adjusted for multiple variables, including age, sex, dialysis status, and
for the IRF measures, aggregates of the IRF case-mix groups. We support this
broad range of risk adjustment, but also believe that CMS and RTI should
consider including risk adjustment for sociodemographic factors and functional
status as well. Recent academic literature has added evidence to the notion
that readmissions back to hospitals are driven by more directly by patient
status factors and not by the quality of care delivered. Furthermore, NQF in
April began a two-year trial program of a temporary policy change that would
allow risk adjustment of performance measures for socioeconomic and other
demographic factors, a departure from earlier quality measurement positions
that viewed sociodemographic risk adjustment as inappropriate. However, with
evidence that sociodemographic risk is real and impact readmission rates, we
recommend that the measure developers consider including it in the list of
risk adjustment factors for these measures. We also believe adjusting for
functional status would benefit the accuracy of the PPR measures. Functional
status has a direct correlation with a patient’s ability to remain healthy at
home after PAC services have ended, meaning that PAC providers who treat more
functionally impaired patients will likely have a higher PPR rate.
Accordingly, we recommend that the measure developers consider how to apply an
additional risk-adjustment factor for functional status in the overall risk
adjustment methodology. D. RISK OF CONFUSION IN MULTIPLE READMISSION MEASURES
As part of the existing IRF PPS Quality Reporting Program (“IRF QRP”), IRFs
already report All-cause Unplanned Readmission (NQF #2502) and are scheduled
to have this measure publicly reported beginning next year. Other PAC types
will also require public reporting of a general all-cause readmissions
measure. We are concerned that, as required by the IMPACT Act, the eventual
public reporting of these PPR measures (which are essentially a subset of the
more general all-cause measures) will result in substantial confusion amongst
members of the public. For example, if both measures are publicly reported,
PAC providers will have one all-cause unplanned readmission rate, but likely a
different PPR rate. We question whether the crucial distinctions between
these two different, but related, readmissions measures will be readily
apparent to members of the public who take the time to assess different PAC
providers based on readmission rates. Similarly, providers may have trouble
accurately understanding the purpose and ultimate use of additional
readmissions measures. IRF providers already receive annual PEPPER reports
and also report on the All-cause measure (NQF #2502). With the addition of a
“within stay” measure and a post-discharge PPR measure to these existing
readmission measures, CMS should take deliberate steps to clearly communicate
the intended use for each of these four readmission tools and how they will
relate to one another. Without such clarifying communication, providers may
find themselves adrift in various readmissions data without a clear idea of
how it is all being used by the Agency. This is another example, similar
to the IRF short-stay/transfer case considerations discussed above, of the
reconciliation issues that CMS must face in overlaying IMPACT Act
requirements with existing PAC regulations, and insofar as NQF and the measure
developers can eliminate the duplicative requirements of IMPACT Act
implementation, including overlapping public reporting of two “flavors” of
readmissions, we highly encourage them to do so. Indeed, the IMPACT Act
encourages CMS to refrain from duplication in methods for data collection, and
we recommend that this theme be extended to other parts of IMPACT Act
implementation as well. NQF also has policies against endorsing measures that
have unnecessarily duplicative functions with existing measures. (Submitted
by: HealthSouth)
- The proposed measure “Percentage of care episodes or stays in which a drug
regimen review was conducted at the Admission /SOC /ROC, and timely follow-up
with a physician occurred each time potentially significant medication issues
were identified throughout the care episode or stay” is intended to be
collected by 3 items: • Item 1 asks providers if a complete drug regimen
review conducted at admission identified any “potentially clinically
significant issues” for a patient. • Item 2 asks providers if they contacted
a physician within one calendar day and completed the recommended course of
action for the “identified clinically significant medication issues” found at
admission, if any. • Item 3 asks providers if they contacted a physician and
completed the recommended actions within one calendar day each time clinically
significant medication issues were identified following admission. While the
IMPACT Act designated “medication reconciliation” as one of several domains
for which cross-setting quality measures are required, the proposed measure
instead utilizes “drug regimen review” to calculate the measure numerator.
Although there is an overlap between “medication reconciliation” and “drug
regimen review,” drug regimen review is a fundamentally distinct process from
medication reconciliation. According to the definition of “drug regimen
review” as stated by the Home Health (HH) Conditions of Participation (CoPs)
at §484.55c, the intent is to “review medications a patient is currently using
in order to identify potential adverse effects or drug reactions.” This most
notably includes noncompliance with drug therapy, significant side effects,
and ineffective drug therapy – all of which are typically infeasible for an
admitting facility to assess during a medication reconciliation process at
admission. Such drug regimen review is distinct from the medication
reconciliation act of “comparing the medications a patient is taking (and
should be taking) with newly ordered medications in order to identify and
resolve discrepancies, including omissions, duplications, contraindications,
unclear information, and changes.” Furthermore, the proposed drug regimen
review tracks medication issues at any point during the care episode or stay
(dividing the episode of care into “admission” and “after admission”) even
though medication reconciliation occurs only during transitions of care, i.e.
admission, transfer, and discharge. According to The Joint Commission,
medication reconciliation occurs at transition points of care where new
medications are ordered or existing orders are rewritten. The Institute for
Healthcare Improvement also considers the medication reconciliation process to
occur at transition points only: “Each time a patient moves from one setting
to another where orders change or must be renewed, clinicians should review
previous medication orders alongside new orders and plans for care, and
reconcile any differences. If this process does not occur in a standardized
manner that is designed to ensure complete reconciliation, medication errors
may lead to adverse events and harm.” A measure that tracks variables
associated with drug regimen review throughout the patient’s stay (as proposed
by the measure) is fundamentally different from a measure that tracks
variables associated with the medication reconciliation processes that occur
only when the patient moves from one setting to another. Additionally, by
lumping discharge into the overly-general “after admission” timeframe, the
proposed measure also fails to adequately capture the discharge process, even
though CMS’ proposed Drug Regimen Review Measure Justification Form lists the
importance of discharge as a critical part of medication reconciliation:
“Hospital discharge is one high risk time point with evidence that there are
high levels of discrepancy. In fact, there is evidence that 50% of patients
experience a clinically important medication error after hospital discharge.”
A thorough and complete medication reconciliation as part of the discharge
planning process is critical for a patient’s successful transition to her/his
discharge destination, whether to home or community or to another inpatient
care setting. It is troubling that the proposed medication reconciliation
measure fails to distinguish this important aspect of a patient’s episode of
care in a post-acute setting. We encourage CMS to propose a “medication
reconciliation” measure that focuses on medication review at transition points
of care and remove elements related to drug regimen review, as they
fundamentally differ in scope and definition. Our comments related to the
existing measure as proposed follow: COMMENTS RELATED TO ITEMS 1 AND 2 Drug
regimen review activities that occur prior to the medication order The term
“medication reconciliation” as defined by The Joint Commission NPSG 03.06.01,
and used in the proposed measure, involves comparing “the medication
information the patient brought to the hospital [either from the discharging
facility or from home] with the medications ordered for the patient by the
hospital in order to identify and resolve discrepancies.” Based on this
definition, medication reconciliation only includes medications that have been
ordered for the patient, but not medications that were prevented from being
ordered by a drug regimen process. For example, hospitals that use an
electronic medical record (“EMR”) typically utilize computer physician order
entry (“CPOE”) that has safeguards in place to prevent a physician from
ordering medications which may have potential adverse effects and drug
reactions for the particular patient. Since these medications were never
ordered, they would not be part of the medication reconciliation and drug
regimen review as defined by the proposed quality measure. We ask that CMS
clarify whether the measure is intended to include or exclude instances where
a drug was reviewed for potential adverse effects and drug reactions prior to
the medication actually being ordered (thus eliminating potential adverse
effects and drug reactions). For example, patients admitted to inpatient
rehabilitation hospitals are typically on anticoagulation therapy. If a
physician attempts to submit an order for the anticoagulant Coumadin in the
EMR, a CPOE may trigger an alert to the physician that this medication
duplicates the existing order for Lovenox, another anticoagulant. The
physician could then cancel the prescription and the medication would never be
ordered, thus avoiding a potential “duplicate drug therapy” result. Because
Coumadin was never actually “ordered,” the process engineered by the CPOE’s
alert system would not be captured as an act of medication reconciliation in
the proposed quality measure. It is unclear whether such processes were
intended to be captured as part of the drug regimen review since, in this
illustrative example, the potentially clinically significant medication issues
were avoided by virtue of a drug order never being executed in the first
place. Further, the physician can accept or override this type of alert in a
CPOE system depending on patient-specific circumstances and his/her own
clinical judgment. If they choose to override the alert, the medication would
be ordered and therefore become subject to a medication reconciliation process
and drug regimen review. While an EMR allows these changes and alerts to be
identified and tracked before a medication is actually ordered, this would be
far more difficult to capture in a non-electronic system, if these decisions
occurred prior to the ordering process. Referring to the previous
anticoagulation example, if a physician considered writing a prescription for
Coumadin but caught this potential “duplicate drug therapy” issue prior to
writing the actual order, no one would ever know. Definition of “Clinically
significant medication issue” We encourage the measure developers to
specifically define, and NQF to ask, what constitutes a “potential clinically
significant medication issue.” Without an explicit and detailed definition of
this term, it will likely vary widely across providers and care settings,
which will in turn cause serious integrity issues for the resulting quality
measure data. It is also important to specify what would not constitute a
“potential clinically significant medication issue.” For HealthSouth’s
recommendations of “potential clinically significant medication issue,” please
see Appendix A. Subjectivity of “Potential” The proposed measure asks
clinicians to predict if a medication issue (potential adverse effect or drug
reaction) found during a drug regimen review would be “potentially clinically
significant.” While some medication issues might undoubtedly cause clinically
significant issues (however such issues are defined), others would be left to
subjective judgment about whether the issue would or would not potentially
cause clinically significant patient effects. This type of subjectivity is
concerning when developing a measure that will be utilized by a wide variety
of clinicians across post-acute care settings, and one that is intended to
achieve standardized data points for subsequent comparison between such
settings. As such, this high level of subjectivity would be a significant
concern to reliability and validity of the proposed quality measure. Item 1 –
Answers “0/1/9” It is unclear how a hospital would answer Item 1 if they found
medication issues that were considered “issues,” but not deemed to be
“potentially clinically significant.” It is implied that 0 “No, no issues
found” and 1 “Yes, issues found” apply only to “potentially clinically
significant medication issues” (particularly given the logic that an answer of
“1” requires Item 2 to be completed), not any “issue” at all. Therefore, if a
hospital finds a medication issue they deem not clinically significant (by the
defined term), there is no available answer option. Accordingly, we recommend
that, for answers 0 and 1, the language be clarified from “issues” to
“potential clinically significant medication issues” and an additional
selection be added for “Yes, medication issues were identified but were not
deemed potentially clinically significant.” This additional answer choice
would also presumably skip Item 2, like current selections “0” and “9”. Item 2
- Medication Follow-Up Under Item 2, it is unclear whether the facility/agency
has one calendar day to “complete prescribed/recommended actions in response
to the identified clinically significant medication issue” or whether that
applies only to contacting the physician (or physician designee). If the
proposed measure is intended to capture whether the physician was contacted
and the recommendation action all occurred in one calendar day, this could be
reworded to clarify. Notably, in Item 3, providers are given one calendar day
for both actions. Admission Clarification The assessment timing for Item 1 and
Item 2 are identified as “admission” for SNF, IRF, LTCH, and SOC/ROC for HH.
However, “admission” remains undefined. Admission orders at a receiving IRF
(and likely SNF and LTCH) typically follow the discharging orders from the
prior level of care until a full reconciliation of the medical record and
medication history can occur. This includes an evaluation by the pharmacist,
a discussion with the patient and/or family, and a review by a physician.
While medication review and reconciliation are initiated immediately upon
admission it can take up to 48 hours for a full “admission medication
reconciliation” to be completed. Therefore, we suggest the “admission”
timeframe be 2 calendar days – the day of admission and the following calendar
day. COMMENTS RELATED TO ITEM 3 The proposed quality measure information
begins with a definition of medication reconciliation and drug regimen review:
Medication reconciliation – the process of comparing the medications a
patient is taking (and should be taking) with newly ordered medications in
order to identify and resolve discrepancies. (Reference: The Joint Commission,
National Patient Safety Goals). Drug regimen review – a review of all
medications the patient is currently using in order to identify any potential
adverse effects and drug reactions, including ineffective drug therapy,
significant side effects, significant drug interactions, duplicate drug
therapy, and noncompliance with drug therapy. (Reference: Home Health
Conditions of Participation Home Health §484.55c). Medication reconciliation
and drug regimen review are intended to identify and avoid potential
medication issues, but the wording of Item 3 omits the word “potential.” We
ask CMS to clarify whether Item 3 is intended to measure potential clinically
significant medication issues or clinically significant medication issues that
have already occurred. This is a critically important distinction.
Reconciling medication instructions before the administration of medication is
a structured, deliberate clinical activity. But handling a clinically
significant issue, such as an adverse drug reaction, is highly variable and
may call for anything from the application of a reversal agent to readmission
to a general acute hospital. Treating these two types of medication-related
events under one measure conflates two processes that are fundamentally
different from one another. While we agree that measuring the timeliness of
notifying the physician after a clinically significant medication issue is
extremely important to patient safety, we believe it is outside the scope of
“medication reconciliation” – which is intended to identify potential issues
before medication is administered. Measuring physician notification after a
clinically significant medication event happens is a separate and distinct
quality measure, and one that should almost never take a full calendar day to
occur. ADDITIONAL COMMENTS Unintended Consequences The purpose of medication
reconciliation is to find and correct errors. No measure, either now or in
the future, should be designed so as to discourage clinicians from reporting
and correcting errors in patient medication. Numerator/Denominator
Exclusions Patients who were admitted and unexpectedly discharged prior to a
medication reconciliation process being completed should be excluded from this
measure. It is assumed this would be indicated on the respective assessment
instruments with a dash (“-“) as currently documented for other quality
measures. Care Setting Differences The drug regimen review that may occur in a
home health setting would be significantly different from an inpatient setting
where the patient is receiving 24-hour care. If clinically significant
medication issues occur in the inpatient setting, they are handled more
immediately than in home health settings. Larger Emphasis on Medication
Reconciliation at Discharge We encourage CMS to consider an aspect of
“medication reconciliation” specifically at the discharge timeframe. A
thorough and complete medication reconciliation and drug regimen review at
this point in the patient’s care is part of the discharge planning process, as
it is critical for a patient’s successful transition to her/his discharge
destination, whether to home or community or to another inpatient care
setting. APPENDIX A Clinical Significant Medication Issue A medication issue
is any undesirable experience or adverse event associated with the use of a
medical product in a patient. 1. The event would be deemed clinically
significant when the medication issue would likely cause: a. Death – if the
patient’s death is suspected as being a direct outcome of the adverse event;
b. Life-Threatening – if the patient was at substantial risk of dying at the
time of the adverse event or it is suspected that the use of continued use of
the product would result in the patient’s death; c. Hospitalization (initial
or prolonged) – if admission to the hospital or prolongation of a hospital
stay results because of the adverse event; d. Disability – Report if the
adverse event resulted in a significant, persistent, or permanent change,
impairment, damage or disruption in the patient’s body function/structure,
physical activities or quality of life. e. Requires Intervention to Prevent
Permanent Impairment or Damage – if the use of a medical product may result in
a condition which requires medical or surgical intervention to preclude
permanent impairment or damage to a patient. 2. A clinically significant
medication issue does not include: a. Adverse effects of the drug which are
expected, well-known reactions which do not result in changing the care of the
patient. These adverse effects are those effects occurring predictably or
effects whose intensity and occurrence are related to the size of the dose. b.
Drug withdrawal, drug-abuse syndromes, accidental poisoning, and drug-overdose
complications also should not be defined as clinically significant medication
issues (e.g., drowsiness from diphenhydramine). c. Reactions which are
extensions of the pharmacologic effect for which the drug is given (e.g., bone
marrow suppression with antineoplastic agents). d. Disturbances totally
dependent on the pathological state (e.g., diarrhea from cancer and not from a
laxative). (Submitted by: HealthSouth)
- FAH supports the workgroup's recommendation and rationale. FAH shares many
of the workgroup's concerns, particularly the concern about appropriate risk
adjustment and the potential conflict with other readmission measures. We
strongly urge NQF to require developers to explore additional SDS factors
beyond the current variables that are often used in the analysis (e.g., dual
eligible status, race) and ask that MAP make clear recommendations to CMS that
a broader set of variables should be included in the measures submitted for
future consideration. We request that the measure be fully tested before it is
considered for a future payment program. (Submitted by: Federation of American
Hospitals)
- AMRPA would refer NQF and the MAP to the comments made regarding MUC 496,
as they relate to our suggested modifications to the concept of a potentially
preventable readmissions (PPR) and the risk adjustment methodology. As
drafted, we believe the definition of a PPR has the potential to unfairly
penalize IRFs and will need to be adjusted to truly improve outcomes for the
patients we treat. We also believe that the collection of data beyond claims
data will be critical. We are concerned that the confluence of payment and
quality policies has the potential to inappropriately target IRFs in two ways
if there is a PPR during the IRF stay. Specifically, we do not think that a
“within stay” measure should be applicable until day four or after from the
date of admission to the IRF. We recommend this for two reasons. First, if a
within stay measure is applied too early after the date of admission to the
IRF, it might be a barrier to admission for patients especially for sicker
patients who are more likely to be readmitted to the acute care hospital would
negatively impact the IRF’s quality score. Second, at this time the Inpatient
Rehabilitation Facility Prospective Payment System (IRF PPS) includes a
payment policy that provides a lower payment to the IRF if the patient is
transferred back to the acute care hospital before day four after admission to
the IRF. Therefore, if the within stay measure as drafted does not account for
this payment policy, an IRF who transfers a patient back to the acute care
hospital prior to day four after admission would face double potential payment
reductions: one under the IRF PPS transfer policy and a second for the
readmission quality metric. It is unreasonable to apply two financial
penalties simultaneously for the same event. We remain concerned that this
measure is not fully developed. Therefore, it may be premature to endorse this
measure for the purpose of the IRF QRP. (Submitted by: American Medical
Rehabilitation Providers Association)
- (Early public comment)AMRPA would refer NQF and the MAP to the
comments made regarding MUC 496, as they relate to our suggested modifications
to the concept of a potentially preventable readmissions (PPR) and the risk
adjustment methodology. As drafted, we believe the definition of a PPR has the
potential to unfairly penalize IRFs and will need to be adjusted to truly
improve outcomes for the patients we treat. We also believe that the
collection of data beyond claims data will be critical. We are concerned that
the confluence of payment and quality policies has the potential to
inappropriately target IRFs in two ways if there is a PPR during the IRF stay.
Specifically, we do not think that a “within stay” measure should be
applicable until day four or after from the date of admission to the IRF. We
recommend this for two reasons. First, if a within stay measure is applied too
early after the date of admission to the IRF, it might be a barrier to
admission for patients especially for sicker patients who are more likely to
be readmitted to the acute care hospital would negatively impact the IRF’s
quality score. Second, at this time the Inpatient Rehabilitation Facility
Prospective Payment System (IRF PPS) includes a payment policy that provides a
lower payment to the IRF if the patient is transferred back to the acute care
hospital before day four after admission to the IRF. Therefore, if the within
stay measure as drafted does not account for this payment policy, an IRF who
transfers a patient back to the acute care hospital prior to day four after
admission would face double potential payment reductions: one under the IRF
PPS transfer policy and a second for the readmission quality metric. It is
unreasonable to apply two financial penalties simultaneously for the same
event. We remain concerned that this measure is not fully developed.
Therefore, it may be premature to endorse this measure for the purpose of the
IRF QRP. (Submitted by: American Medical Rehabilitation Providers
Association)
- (Early public comment)While we appreciate CMS' consideration for a
readmission measure that an IRF may be able to control, we are highly
concerned that measure development has not yet been completed, and that
measure level testing has not been completed in such a way as to determine
whether measure results will meet criteria for being reliable and valid. We
are also concerned that the measure materials provided to date do not provide
sufficient information related to how the measure will account for "program
interruptions" that occur within the IRF stay and do not require the IRF to
discharge the patient. We also wonder whether testing results will show
differences between the different facility types, and whether risk-adjustment
methodologies are being considered to account for differences between
facilities. (Submitted by: UDSMR)
- (Early public comment)In regards to the within-stay criteria, IRFs
have experienced a rise in the number of patients who must return to the acute
inpatient care setting within 48-72 hours of admission due to the disparity
between the level of care which their condition (either a co-morbidity or
complication secondary to the presenting diagnosis) requires and the level of
care that an IRF is able to provide. An example of this is leukemia patients
as many times they require inpatient rehabilitation to discharge them from the
hospital and that the patient’s survival may be related to their functional
status and rehabilitation can improve function and symptoms such as fatigue,
well-being, and pain. To this end, ARN disagrees with the within-stay criteria
delineated for IRFs and believes that in specific instances, readmissions are
a necessity for patient safety, and not necessarily preventable. (Submitted
by: Association of Rehabilitation Nurses)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)At least one NRHI member has expressed
concerns regarding this measure. Specifically, clinical staff at
HealthInsight have concerns with inclusion of this measure due to the validity
of and complicated methodologies used for "risk adjustment for patient
characteristics and a statistical estimate of the facility effect beyond
patient mix." This methodology is frequently cited as the basis for
determining potentially avoidable hospital facility admissions. This
methodology is not well-established. (Submitted by: Network for Regional
Healthcare Improvement)
- (Early public comment)We are generally supportive of measuring PAC
providers on potentially preventable readmissions and believe that much of the
work performed for these measures is positive, such as the risk adjustment
methodology. We believe that the PAC industry should embrace measures, such
as these PPR measures, that help patients stay at home – a central tenant of
post-acute care. Accordingly, we value these PPR measures as useful tools in
advancing that goal. We have several comments that will serve as constructive
additions to the development of these measures. We hope that NQF and the
measure developers will analyze and consider these comments and how they could
improve the PPR measure development for IRFs. A. THE IRF “WITHIN STAY”
MEASURE SHOULD ACCOUNT FOR THE EXISTING THREE-DAY SHORT STAY AND TRANSFER CARE
POLICIES FOR IRFS The measure specification document states that the IRF
“within stay” measure “is intended to capture readmissions during the IRF stay
(i.e. program interruptions where the patient is readmitted to the acute care
setting) and readmissions (i.e. [sic] acute care transfers) at the end of the
IRF stay.” This specification does not detail precisely when the measure
would begin capturing such readmissions, but the “within stay” measure should
not apply until day four or after from a patient’s date of admission to the
IRF. IRFs are currently subject to a policy under the IRF Prospective Payment
System (“PPS”) that provides a uniform payment for certain cases with a
length-of-stay not exceeding 3 days. This three-day window was designed by
CMS to help ensure that IRFs have enough time to fully assess whether a
patient admitted to the IRF remains in need of IRF services. According to
CMS, “an IRF is eligible to receive the IRF short stay payment for 3 days or
less if a patient’s thorough preadmission screening shows that the patient is
an appropriate candidate for IRF care but then something unexpected happens
between the preadmission screening and the IRF admission such that the patient
is no longer an appropriate candidate for IRF care on admission and the day
count is greater than 3.” Therefore, since the IRF PPS already accounts
for admission of some patients who are subsequently determined by day 3 of the
IRF stay as no longer needing IRF services by reimbursing the IRF by paying a
lower rate, the IRF “within stay” PPR measure should not further penalize IRFs
for readmissions that occur within the same time period. There is precedent
for this accommodation for short-stay policies within other PAC readmissions
measures already: the existing home health “within stay” rehospitalization
measure specifically excludes stays that begin with a Low-Utilization Payment
Adjustment (“LUPA”) (i.e., stays with four or fewer home health visits, the
equivalent of short-stays in IRFs). Short stays in any PAC provider should be
excluded from the PPR measure because the PAC provider will not have the
opportunity to meaningfully deliver care to a patient. As such, it would be
unfair to attribute the cause of the readmission to the PAC provider when they
are so limited in what they can do within the short-stay window. To the
extent that CMS and RTI develop true “within stay” PPR measures for SNFs and
LTCHs in the future, we believe those measures should also account for short
stays policies. Similarly, the existing IRF transfer policy provides
that, for patients who are transferred from an IRF to a hospital, LTCH, SNF,
or other IRF, and whose length of stay is less than the average length of stay
for the pertinent CMG, the transferring IRF receives a per diem payment, the
rate of which is calculated by dividing the typical per discharge CMG payment
by the average length of stay. Therefore, because this policy reduces IRF
payment automatically from the normal CMG payment for cases that are
discharged early, it functions to discourage IRFs from making such early
discharges. If a “within stay” PPR measure were to start too early into IRF
stays, these two policies would overlap and any transfers would effectively
cause a double penalty – a lower payment under the transfer policy as well as
a PPR “ding.” Accordingly, in order to avoid applying two separate payment
disincentives to a single event, an IRF “within stay” PPR measure should
either begin capturing readmissions after the average length of stay passes,
or currently-defined transfers that would also qualify as a PPR should no
longer be counted as transfers. We recommend that NQF and the measure
developers consider the intersections of these potentially overlapping
policies and structure the IRF “within stay” PPR measure to begin on or after
day four of the IRF stay, and not to conflict with the existing transfer
policy. B. USE OF UPSTREAM DRGS; DIFFERENCES IN
SETTING-SPECIFIC MEASURES COULD CAUSE DIFFICULTY IN DATA COMPARISONS The
various PPR measure proposals each propose to rely on DRGs from the initial
hospital stay as the anchor condition for a PPR in a PAC setting. We are
concerned that the high level of variability in DRG coding practices amongst
upstream hospitals will present problems in the resulting PAC PPR data because
lack of consistency in initial DRG coding will have an effect on the number of
patients at a given PAC provider are “eligible” for inclusion in a
condition-based PPR measure. This dynamic would create a barrier to making
sound apples-to-apples PPR data comparisons. Another issue with using DRG
codes for the initial hospital stay is that such codes are often unreliable
indicators as to why a particular patient is referred to a particular PAC
setting, not to mention why they are eventually readmitted after the PAC stay.
For example, a patient admitted to the hospital for congestive heart failure
and who is treated in a subsequent PAC setting may end up returning to the
hospital during the 30-day post-PAC discharge window not for reasons
associated with congestive heart failure, but because he was not properly
hydrating. Although this readmission would count under the PPR measure, it
would not capture the actual reason the patient was readmitted. By
implementing a post-PAC discharge PPR measure that is coded all the way back
to the initial hospital DRG risks missing the clinical reason that was present
within the particular PAC setting at the time of readmission. Similarly,
we note that IRFs are the only provider for which a “within stay” measure is
being developed (for the IRF QRP, not under the IMPACT Act per se). Although
already in place for HHAs, we believe that such “within stay” PPR measures
could also be helpful and are possible for LTCHs as well, and ask CMS and RTI
to consider creating such a measure to enable more congruity into future PPR
comparisons between all PAC providers. The SNF 30-day post hospital discharge
measure, while covering at least some part of a SNF stay, is also incongruent
because it would fail to capture any “within stay” PPRs that occur when a
patient is still in a SNF 30 days after discharge from the acute hospital.
Although these differences are minor, they present concerns when considering
the ability of future policy makers to make direct comparisons within the PAC
industry. C. RISK ADJUSTMENT FOR SOCIODEMOGRAPHIC AND FUNCTIONAL STATUS
The draft specifications indicate that the PPR measures will all be
risk-adjusted for multiple variables, including age, sex, dialysis status, and
for the IRF measures, aggregates of the IRF case-mix groups. We support this
broad range of risk adjustment, but also believe that CMS and RTI should
consider including risk adjustment for sociodemographic factors and functional
status as well. Recent academic literature has added evidence to the notion
that readmissions back to hospitals are driven by more directly by patient
status factors and not by the quality of care delivered. Furthermore, NQF in
April began a two-year trial program of a temporary policy change that would
allow risk adjustment of performance measures for socioeconomic and other
demographic factors, a departure from earlier quality measurement positions
that viewed sociodemographic risk adjustment as inappropriate. However, with
evidence that sociodemographic risk is real and impact readmission rates, we
recommend that the measure developers consider including it in the list of
risk adjustment factors for these measures. We also believe adjusting for
functional status would benefit the accuracy of the PPR measures. Functional
status has a direct correlation with a patient’s ability to remain healthy at
home after PAC services have ended, meaning that PAC providers who treat more
functionally impaired patients will likely have a higher PPR rate.
Accordingly, we recommend that the measure developers consider how to apply an
additional risk-adjustment factor for functional status in the overall risk
adjustment methodology. D. RISK OF CONFUSION IN MULTIPLE READMISSION MEASURES
As part of the existing IRF PPS Quality Reporting Program (“IRF QRP”), IRFs
already report All-cause Unplanned Readmission (NQF #2502) and are scheduled
to have this measure publicly reported beginning next year. Other PAC types
will also require public reporting of a general all-cause readmissions
measure. We are concerned that, as required by the IMPACT Act, the eventual
public reporting of these PPR measures (which are essentially a subset of the
more general all-cause measures) will result in substantial confusion amongst
members of the public. For example, if both measures are publicly reported,
PAC providers will have one all-cause unplanned readmission rate, but likely a
different PPR rate. We question whether the crucial distinctions between
these two different, but related, readmissions measures will be readily
apparent to members of the public who take the time to assess different PAC
providers based on readmission rates. Similarly, providers may have trouble
accurately understanding the purpose and ultimate use of additional
readmissions measures. IRF providers already receive annual PEPPER reports
and also report on the All-cause measure (NQF #2502). With the addition of a
“within stay” measure and a post-discharge PPR measure to these existing
readmission measures, CMS should take deliberate steps to clearly communicate
the intended use for each of these four readmission tools and how they will
relate to one another. Without such clarifying communication, providers may
find themselves adrift in various readmissions data without a clear idea of
how it is all being used by the Agency. This is another example, similar
to the IRF short-stay/transfer case considerations discussed above, of the
reconciliation issues that CMS must face in overlaying IMPACT Act requirements
with existing PAC regulations, and insofar as NQF and the measure developers
can eliminate the duplicative requirements of IMPACT Act implementation,
including overlapping public reporting of two “flavors” of readmissions, we
highly encourage them to do so. Indeed, the IMPACT Act encourages CMS to
refrain from duplication in methods for data collection, and we recommend that
this theme be extended to other parts of IMPACT Act implementation as well.
NQF also has policies against endorsing measures that have unnecessarily
duplicative functions with existing measures. (Submitted by:
HealthSouth)
(Program: Long-Term Care Hospital Quality Reporting Program; MUC ID:
MUC15-498) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The AHA agrees with the MAP’s comments on this measure. Furthermore, we
strongly urge that any categories and lists of “potentially preventable
readmissions” be based on careful evaluation by clinical experts and detailed
testing. We appreciate that a technical expert panel (TEP) was consulted on
the list of categories and codes of readmissions considered “potential
preventable.” However, we strongly encourage CMS to undertake additional
empirical testing to ensure there is evidence that the codes actually are
associated with the identified categories. In addition, we are concerned that
this measure may be duplicative of the existing LTCH readmission measure. The
existing LTCH readmission measure assesses “all cause” readmissions, while
this proposed measure focuses on ‘potentially preventable’ readmissions.
Conceptually, there is potential value to focusing readmission measurement
efforts on those readmissions that are truly preventable. However, the measure
is similar enough to the existing LTCH measure that we believe using both
could lead to confusion about the true state of performance. (Submitted by:
American Hospital Association (AHA))
- FAH supports the workgroup's recommendation and rationale. FAH shares many
of the workgroup's concerns, particularly the concern about appropriate risk
adjustment and the potential conflict with other readmission measures. We
strongly urge NQF to require developers to explore additional SDS factors
beyond the current variables that are often used in the analysis (e.g., dual
eligible status, race) and ask that MAP make clear recommendations to CMS that
a broader set of variables should be included in the measures submitted for
future consideration. We request that the measure be fully tested before it is
considered for a future payment program. (Submitted by: Federation of American
Hospitals)
- Concerns regarding cross-setting comparisons In MAP’s rationale for its
preliminary decisions, the members did not raise concerns about the
appropriateness of the measures for cross-setting comparisons. Across PAC
provider settings, there are significant differences in patient severity and
acuity. LTCHs care for Medicare patients that include the most medically
complex and resource-intensive patients. The differences in acuity may
contribute to large differences between outcomes for LTCHs compared to other
PAC settings. Assessment data should be used to construct these measures
While Medicare claims data are more readily available than other data
sources, they may not capture finer distinctions across patients that may
affect the patients’ outcomes and facility to which they are discharged.
Therefore, a process to include assessment data in the measure calculations,
once available, needs to be established and followed. Issues related to risk
adjustment We agree with MAP that there are potential unintended consequences
of the measures and the need for appropriate risk adjustments for the
discharge to community measure and the potentially preventable 30-day
post-discharge readmission measure. We recommend adjusting for factors that
play a significant role in determining resource use and outcomes in the LTCH
setting, such as prolonged mechanical ventilation, multiple organ failure, and
three or more days in an intensive care unit. We also recommend adjustment
based on socioeconomic factors. (Submitted by: National Association of Long
Term Hospitals)
- (Early public comment)We would like to note the following concerns
regarding the development of these measures: 1. Measure development for the
IMPACT Act appears to create 4 separate measures that are site specific with
their own set of criteria and risk adjustment factors. The IMPACT Act aims to
create quality measurement within Post-Acute Care (PAC) that is "standardized
and interoperable". By developing measures which differ in their calculation,
such as site-specific inclusion/exclusion criteria or risk-adjustment factors,
PAC sites will be subjected to comparisons of quality that do not differ based
upon the quality of care provided, but rather the differences inherent in the
measure calculations. We strongly recommend that CMS and the measure
developers produce a measure that is calculated in a "standardized and
interoperable" manner with inclusion/exclusion criteria and risk-adjustment
factors the are applied consistently across all PAC sites. 2. The measures
developed for the IMPACT Act hold PAC providers responsible for circumstances
that occur outside of their control. While PAC providers are responsible for
providing care that allows patients safe transitions to their next setting or
home, holding these providers accountable fora time period in which they are
not furnishing care should not differentiate the quality of care they actually
provided. In Appendix A, Table A1 lists various conditions that define
potentially preventable hospital readmission for 30-days post-PAC discharge.
In this list, conditions such as Asthma, Congestive Heart Failure, and
Dehydration are listed as a reason for a potentially preventable readmission.
So if the patient fails to care for themselves post-discharge (against the
advice and discharge instructions provided by a PAC provider) and requires
readmission to Acute Care for one of these conditions, the PAC provider is
penalized even though the patient is no longer being cared for by the PAC
provider. We strongly recommend that CMS and the measure developers produce a
measure that represents the quality of care provided by PAC providers while
the patient is in their care. (Submitted by: UDSMR)
- (Early public comment)This measure will encourage post-acute care
providers to optimize care for patients before discharge. (Submitted by:
Smith & Nephew )
- (Early public comment)This set of potentially preventable
readmission (PPR) measures for post-acute care (PAC) estimates the
risk-standardized rate of unplanned, potentially preventable readmissions for
patients (Medicare fee-for-service [FFS] beneficiaries) who receive services
in one of the following post-acute care provider types: skilled nursing
facilities (SNFs), inpatient rehabilitation facilities (IRFs), long-term care
hospitals (LTCH), and home health agencies (HHA). These outcome measures
reflect readmission rates for patients who are readmitted to a short-stay
acute-care hospital or an LTCH with a principal diagnosis considered to be
unplanned and potentially preventable. Six PPR PAC measures are being
developed: • Four of these measures assess PPR within a 30-day window
following discharge from PAC—one measure for each PAC setting (i.e., SNF,
IRF, LTCH, and HH)—and are being developed to meet the requirements of the
IMPACT Act. • An additional SNF measure (SNF PPR), which is being developed
to meet the PAMA requirements, assesses PPR during the 30-day period following
a hospital discharge to a SNF setting. • An additional IRF measure assesses
PPR during the IRF stay (referred to as the within-stay window) which is being
developed for use in the IRF Quality Reporting Program. Of note with respect
to potentially preventable readmissions and a patient’s occupational therapy
needs, several recent studies consider whether returning to the community from
a recent hospitalization with unmet activities of daily living (ADL) need was
associated with probability of readmission. The findings from these studies
indicate that this indeed may be a considerable risk factor. The studies
reveal that any older patients are discharged from the hospital with ADL
disability. Those who report unmet need for new ADL disabilities after they
return home from the hospital are particularly vulnerable to readmission. This
area is not typically addressed in a thorough manner through current discharge
practices. This needs to change. Patients' functional needs after discharge
should be carefully evaluated and addressed. Factors such as enabling
self-management and ensuring appropriate medication management and ADLs, such
as cooking and eating are addressed, can have a direct effect on readmissions
The profession of occupational therapy is built on delivering
patient-centered care, seeking to keep the patient at the highest functional
level in the least restrictive setting and to reduce caregiver burden and
health care system resource utilization. Occupational therapy directly
addresses the enablement of successful performance of ADLs. This focus,
experience and research base in occupational therapy must be fully tapped to
address this component of readmission prevention. A further issue is that
Self-management is a key element in successful care, and occupational
therapists are experts in motivation, task analysis, and psychosocial
contexts, which all contribute to enabling positive outcomes. In order to
successfully re-establish or establish new routines and habits to meet health
care needs, such as medication management, proper sleep hygiene, and following
other medical directives, is within the scope and proven effectiveness of
occupational therapy. AOTA would encourage CMS to examine more fully,
perhaps through pilot testing, the value of occupational therapy evaluation
and intervention participation as part of discharge planning. This could
identify more clearly specific ADL limitations prior to and after discharge
and assure proper interventions are provided that address fully and completely
the range of ADL and other activity restrictions and capacities to enable
optimum recovery from the condition as well as optimum participation of the
client in their own care. AOTA has reviewed the readmissions measures
released for comment and makes the following general comments: • The PPR
measures Numerator and Denominator definition language are consistent from
previous materials. • The Readmissions Measures are based on two years of
claims data. Use of multiple years is acceptable in the measure review
process. • The exclusion criteria for the various measures are associated
with the Yale/New Haven readmission measures. Co-developed by the Centers for
Medicare & Medicaid Services (CMS) and researchers at Yale University,
estimates the risk-standardized rate of unplanned, all-cause readmissions to a
hospital for any eligible condition within 30 days of hospital discharge for
patients aged 18 and older. The CMS/Yale measure is specified for evaluating
hospital performance. AOTA would prefer for the exclusion criteria to be
specified for evaluating performance in post-acute care settings. (Submitted
by: American Occupational Therapy Association)
- (Early public comment)At least one NRHI member has expressed
concerns regarding this measure. Specifically, clinical staff at
HealthInsight have concerns with inclusion of this measure due to the validity
of and complicated methodologies used for "risk adjustment for patient
characteristics and a statistical estimate of the facility effect beyond
patient mix." This methodology is frequently cited as the basis for
determining potentially avoidable hospital facility admissions. This
methodology is not well-established (Submitted by: Network for Regional
Healthcare Improvement)
- (Early public comment)According to the RTI measure specifications,
The PPHR measures are constructed by multiplying a standardized risk ratio by
the unadjusted average rate of readmission in the specific PAC setting’s
population. The average readmission rates used in the calculation are not
adjusted for patient clinical differences between PAC settings. As a result,
the differences in the PPHRs between PAC settings (e.g., LTCH, SNF, IRF, and
HHA) may reflect differences in patient clinical differences rather than
differences in care quality. There exist significant differences in patient
severity and acuity across PAC provider settings. For example, according to
RTI analysis of 2012-2013 Medicare claims data, the unadjusted unplanned
30-day mean readmission rate among LTCHs with at least 25 index stays was
24.3% whereas the comparable rate for inpatient rehabilitation facilities was
12.4%. While focusing on PPHRs may close some of this gap, patients admitted
to LTCHs may be more susceptible to some of the PPHRs than other patients.
The PPHR measures require a short-term acute-care stay within 30 days prior
to a PAC admission. This requirement would mostly exclude patients discharged
from LTCHs to less intensive care settings in calculating the readmission
rates of those less intensive care settings. For example, if a patient is
discharged from a short term acute care (STCH) to a LTCH and spends more than
30 days in the LTCH before being discharged to a skilled nursing facility
(SNF), that patient would not be included in calculating readmission rates for
that SNF. Patients who transition from more intensive care settings (such as
LTCHs) to less intensive care settings (such as SNFs and HHA) are likely to
have higher observed and unobserved severity relative to those who transition
from acute care stay to the less intensive PAC setting directly or within a
30-day period. Therefore, this requirement would cause the PPHR measure for
the less intensive care settings to be based on a limited and less severe
portion of their broader population, potentially exacerbating the differences
in patient acuity across PAC settings described above. We recommend that this
requirement is changed so that episodes in which a patient moves through the
continuum of care following discharge from an acute care hospital are not
systematically excluded from the measure sample. This could be done looking
back at contiguous inpatient stays prior to admission to the PAC admission
(pre-PAC episode). Any admission to a short-term acute care hospital within
that pre-PAC episode would serve as the anchor stay. These cases would be
included in the measure even if the STCH stay occurred more than 30 days prior
to admission to the PAC. This revised requirement would ensure that the PPHR
measures are based on a patient population that has experienced a STCH stay
without selecting a less severe portion of the population for the measure
computation. In defining potentially preventable hospital readmissions, RTI's
draft measure specifications do not distinguish across PAC settings. The
draft measure specifications cite studies on readmission from SNFs and
inpatient rehabilitation facilities, but do not cite any studies on for LTCHs.
It would be important to include potentially preventable readmissions that
have been identified for the LTCH setting and using readmissions that are
specific to each PAC setting in constructing the measure. (Submitted by:
National Association of Long Term Hospitals)
(Program: Home Health Quality
Reporting Program; MUC ID: MUC15-523) |
- TESTING ACROSS PAYERS AND AGES (Submitted by: Children's Hospital
Association)
- FAH supports the workgroup's recommendation and rationale. FAH shares many
of the workgroup's concerns, particularly the concern about appropriate risk
adjustment and the potential conflict with other readmission measures. We
strongly urge NQF to require developers to explore additional SDS factors
beyond the current variables that are often used in the analysis (e.g., dual
eligible status, race) and ask that MAP make clear recommendations to CMS that
a broader set of variables should be included in the measures submitted for
future consideration. We request that the measure be fully tested before it is
considered for a future payment program. (Submitted by: Federation of American
Hospitals)
- NAHC agrees with the comments presented by the MAP. NAHC strongly urges
that the measure be appropriately risk adjusted, tested, and validated for
home health care prior to implementation. (Submitted by:
NAHC)
- AAPM&R commends NQF for evolving its work to understand how measures
are being developed and implemented across settings and how they impact
payment reform. This is a huge endeavor that AAPM&R stands behind in
concept. However, AAPM&R cautions NQF to ensure their processes and
review of measures are adequately reported back to CMS and other rule-making
entities to ensure the NQF’s measurement expertise is realized in rule making.
While this measure addresses functional improvement , it does not address
the practical value of the measurable improvement or the ability of a patient
to return to the community. For example, a patient with a complete cervical
spinal cord injury or dense hemiplegia from a stroke may not make significant
functional gains (i.e., they may remain dependent in many domains of mobility
and/or activities of daily living). However, with expert and comprehensive
patient and family/care-giver education and training by the rehabilitation
team, the patient may return to the community despite not meeting the
thresholds that are suggested by the quality measures. The Academy believes
that measurement of patient and family engagement with the process of care and
with education and training must be considered in the evaluation of models of
PAC. Another concern is that without factors related to psychosocial and
family financial support in prediction models, changes in function from
admission to discharge do not tell the entire story. The Academy urges CMS to
support the development of quality measures that relate to patient and family
engagement as PAC reform implementation evolves. AAPM&R believes there
needs to be further discussions about psychosocial issues. (Submitted by:
American Academy of Physical Medicine and Rehabilitation )
- ARN is supportive of a measure that works to identify unplanned
(re)admissions; however, we have concerns with identifying unplanned
(re)admissions based on the planned readmissions algorithm used in NQF measure
#2510: SNF 30-Day All-Cause Readmission Measure (SNFRM); NQF #2502: All-Cause
Unplanned Readmission Measure for 30 Days Post Discharge from IRFs; NQF #2512:
All-Cause Unplanned Readmission Measure for 30 Days Post Discharge from LTCHs;
and NQF #2380: Re-hospitalization During the First 30 Days of Home Health.
The exclusion criteria included within NQF #2510 for SNF stays where the
patient had one or more intervening PAC admissions to an IRF that occurred
either between the prior proximal hospital discharge and SNF admission or
after the SNF discharge within the 30-day risk window fails to allow for a
medically complex patient that is treated in an IRF and readmitted to the SNF
within 30 days for a condition that may initially have been treated as a
comorbidity. We disagree with the rationale provided for exclusion, for while
the measure assesses readmission rates while accounting for patient
demographics, principal diagnosis in the prior hospitalization, comorbidities,
and other patient factors, often, this may not be the reason for admission to
a SNF. ARN believes the measure should include the principal diagnosis during
the prior proximal hospitalization, comorbidities based on the secondary
medical diagnoses listed on the patient’s prior proximal hospital claim and
diagnoses from prior hospitalizations that occurred in the previous 365 days,
length of stay during the patient’s prior proximal hospitalization, length of
stay in the intensive care unit, body system specific surgical indicators,
End-Stage Renal Disease (ESRD) status, whether the patient was disabled, and
the number of prior hospitalizations in the previous 365 days. It also would
be beneficial to understand the comorbidities being evaluated in the
risk-adjustment model. ARN urges the Centers for Medicare and Medicaid
Services (CMS) to develop of a list of comorbidities, comparable to the IRF
Prospective Payment System list of comorbidities and we encourage CMS to
categorize an intervening admission to an IRF as a proximal hospitalization.
Additionally, ARN has serious concerns with CMS’s proposal to require PAC
providers to utilize Medicare claims data to calculate their 30-day
readmission rates. Using claims data to calculate readmission rates is
difficult for health care providers, as claims data are cumbersome to use and
access. Employing a 30-day readmission rate measure will not provide
meaningful insight or have an impact on quality improvement efforts if the PAC
settings do not have unrestricted access to the data. Further, ARN believes
that patients who have been discharged to the community and expire within the
post-discharge window should not be included within the quality measure, given
the variation in patient characteristics across the four settings. For
example, as compared to all Medicare beneficiaries, the SNF and LTCH patient
populations represent the most disabled, elderly, and frail beneficiaries. The
Medicare Payment Advisory Commission’s March 2015 Report to Congress found
that compared with other beneficiaries, “SNF users are older, frailer, and
disproportionately female, disabled, living in an institution, and dually
eligible for both Medicare and Medicaid.” Moreover, as compared with all
Medicare beneficiaries, those admitted to LTCHs are “disproportionately
disabled (under age 65), over age 85, or diagnosed with [ESRD]. They are also
more likely to be African American.” ARN urges CMS to exclude patients that
pass away within the post-discharge window after being discharged to the
community from the discharge to community quality measure, as the types of
patients treated in each setting greatly varies and can lead to an inaccurate
reflection of the quality of care. ARN is pleased the CMS has proposed
discharge measure exclusions; however, we have concerns with the proposed
exclusion of post-acute stays that end in transfer to the same level of care,
and specifically, CMS’s proposal to include only the final post-acute provider
in the discharge to community measure. The Agency’s proposed exclusion
criteria fails to consider when a patient’s “home” is a custodial nursing
facility and the patient’s post-acute episode involves a discharge back to his
or her “home.” In such circumstances, including the final post-acute provider
in the discharge to community measure when a patient is discharged to the
originating level of care, but in essence, is returning home, may distort the
findings of the quality measure. We encourage CMS to design a quality measure
that is capable of capturing the difference between a patient’s return to his
or her home and a patient’s post-acute episode that involves transfer to the
same level of care. (Submitted by: Association of Rehabilitation
Nurses)
- (Early public comment)APTA supports the goal of improving the
quality of health care. Physical therapists are committed to providing
high-quality, timely care and to the promotion of evidence-based and
patient-centered practice. Furthermore, APTA feels that it is essential that
we move towards a common set of quality measures across the continuum of care.
APTA supports the implementation of a discharge to community measure across
the care settings. We believe that successful transitions to the community
following discharge from the respective post-acute care settings will decrease
potentially preventable readmissions. However, the APTA does have some
concerns regarding the proposed measure methodology. These concerns are
discussed below. APTA believes that a patient’s level of function does impact
a patients ability to transition successfully back to the community. Recent
evidence indicates that patient function is associated with increased risk of
30-day all-cause hospital readmissions and may be an important factor in
preventing readmissions for Medicare seniors that is not currently accounted
for in measure methodologies1. APTA was pleased to see “activity of daily
living” scores in the home health setting included in the risk adjustment
methodology for the readmissions measures, and we recently commented,
encouraging the use of patient function in the risk adjustment methodology for
the post-acute care setting readmissions measures. We believe that
readmissions and discharge to community are closely related measures and that
patient function may also be an important risk adjustment variable for
discharge to community. APTA appreciates that CMS has strict deadlines for
the implementation of measures under the IMPACT act, however, as these
measures will be new to the respective post-acute care settings, we encourage
that settings have the ability to review this data as early as possible in
order to understand and, more importantly, so that the respective setting have
time to implement strategies to decrease readmissions where necessary. As
many of these settings do not always receive feedback on the readmissions of
their patients post-discharge, this data will be new to many facilities.
APTA recognizes that the overall goal of IMPACT is for PAC providers (HH,
IRF, SNF and LTCH) to collect and report standardized and interoperable
patient assessment data, quality and resource use measures. We acknowledge
that during the initial IMPACT implementation years that there will be a
transition period which will include the addition of new measures into all of
the post-acute care settings. We believe that achieving a standardized and
interoperable patient assessment data set and stable quality measures as
quickly as possible will allow for better cross-setting comparisons as well as
the evolution of better quality measures with uniform risk standardization,
thus achieving the true aim of IMPACT. 1 Greysen SR, Cenzer IS, Auerbach AD,
Covinsky KE. Functional Impairment and Hospital Readmission in Medicare
Seniors. JAMA Intern Med. 2015;175(4):559-565. (Submitted by: American
Physical Therapy Association)
- (Early public comment)• MUC15-523: Discharge to Community-Post
Acute Care (PAC) Home Health Quality Reporting Program (Required under the
IMPACT Act). There is a difference between the measure noted in the 2015
National Impact Assessment of the Centers for Medicare & Medicaid Services
(CMS) Quality Measures Report of Patients Able to Live in the Community at
Discharge and the measure under consideration, Discharge to Community-Post
Acute Care. The numerator in the measure under consideration includes a risk
adjustment for patient characteristics. There is no information on what
patient characteristics were taken into account. The List of Measures under
Consideration for December 1, 2015, stated there is considerable variation in
discharge to community rates within and across post-acute settings. Studies
show geographic variation, variation across patient socioeconomic
characteristics (for example, race and ethnicity), and variation by facility
characteristics (for profit vs. nonprofit, freestanding vs. hospital-based,
urban vs. rural). The lack of information on what patient characteristics
would be included in the risk adjustment, and the considerable variation of
outcomes noted in studies leads us to recommend that this measure requires
continued development. (Submitted by: LeadingAge)
- (Early public comment)We have the following concerns related to
this measure: 1. The inclusion of unplanned readmissions in the discharge
to community measure development and calculation. Our concerns related to the
inclusion of unplanned readmissions in the discharge to community measure
development and calculation can be defined as follows: a.
Duplication/commingling of quality metrics With the inclusion of unplanned
readmissions in the discharge to community measure development and
calculation, there is the potential for there to be a strong correlation
between the performances of the two measures. In other words, those PAC
providers that perform poorly with the unplanned readmission measure are more
likely to perform poorly on this measure, while those PAC providers that
perform well with the unplanned readmission measure have a better opportunity
to perform well on this measure. Take for instance the scenario of two
facilities with similar patient populations (age, sex, etc.), where provider A
discharges 75% to a community setting with a 5% readmission rate while
provider B discharges 72% to a community setting with a 2% readmission rate.
Which facility performs better at discharging patients to a community setting?
Is the discharge to community measure truly representative of the ability of
the post-acute care provider to provide services that get the patient back to
a community setting, or is too much emphasis being placed upon the ability of
the patient to stay in a community setting? b. Inclusion of a factor
that is outside of post-acute care provider control While a post-acute care
provider can provide services that impact the ability of a patient to be
discharged back to a community setting, whether or not a patient returns to an
acute care facility in the 30 days following that PAC discharge can be
completely unrelated to the services furnished by the PAC provider. For
instance, a patient is discharged home from a post-acute care provider but is
re-admitted to acute care 10 days later for pneumonia (which is listed as a
diagnosis category that cannot be considered planned). Should the post-acute
care provider’s discharge to community percentage be penalized if the
readmission is completely unrelated to the services provided within post-acute
care? With the concerns noted above, we would recommend that the measure
developers remove the unplanned readmission component from the discharge to
community measurement, and provide side-by-side comparison of these two
separate and unique quality measures. 2. Potential for site-specific
risk adjustment for a “cross-setting” measure. While we note that the risk
adjustment variables are “under consideration”, we are very concerned that the
variables noted in the draft specification designate certain variables as
being applicable to unique or specific post-acute care providers. The IMPACT
Act requires the specification of quality measures and resource use metrics
that are standardized and interoperable across PAC settings. In creating a
measure where consideration is being given to risk adjustment variables that
differ by post-acute care setting, is CMS truly meeting the definition of
“standardized and interoperable”? As an example, “Activities of Daily Living”
(ADLs) are noted as one of the Clinical conditions variables, yet is noted for
“the HHA setting only”. If the measure developer can show that ADLs can be
used to differentiate the performance within the HHA population, couldn’t ADLs
also be used to differentiate the performance of all post-acute care settings
and produce a measurement value that is “standardized and interoperable”? We
urge CMS and the measure developers to introduce risk-adjustment variables
that are “standardized and interoperable” in order to meet the IMPACT Act
requirements. (Submitted by: UDSMR)
- (Early public comment)Similar to the PPR measure, NAHC has concern
that HH providers will be held accountable for unavoidable readmissions within
30 days post discharge to the community. Also, the PPR and discharge to
community measures overlap both in structure and purpose. Both measure
readmissions 30 days post-discharge. (Submitted by: National Assocition
for Home Care & Hospice (NAHC))
- (Early public comment)The Alliance supports the development of this
measure, but has concerns that it articulated to the measure development
contractors in recent comments. Most significantly, the discharge to
community measure is structured as a single measure, but the target
populations are not standardized among the various settings. Specifically, the
target population for the home health setting is all Medicare fee-for-service
persons admitted to home health care. An acute care discharge in the 30 days
preceding the start of the home health episode is not required; by contrast,
for the SNF, IRF and LTCH settings, the target population is only those who
were admitted within 30 days of discharge from an acute care hospital. As a
result, for home health settings, the discharge to community measure is not
solely a post-acute care measure. Further, as drafted in the specifications,
the measure as applied to home health care would be a unique home health
measure that is inconsistent with the intent of the IMPACT Act to standardize
patient assessment data in post-acute care. If the intent of the IMPACT Act
is to be able to compare patient outcomes and characteristics across
post-acute care settings, the unique target population for home health care
will confound the ability to achieve the goals of the IMPACT Act. The Alliance
recommends that the target population for home health match that of the other
settings so that only those admitted to home health within 30 days of
discharge from an acute care hospital are included in the target population.
The Alliance’s full comments on this measure can be found at:
http://ahhqi.org/images/uploads/Alliance_Comments_on_Discharge_to_Comm_112315.pdf.
In addition, the Alliance notes that for the other settings’ (SNF, IRF and
LTCH) discharge to community measures, both to home health and discharge home
(without home health) are considered a discharge to community. The Alliance
urges stratification that will enable identification of those discharged to
home health and those sent to home without home health care. This will enable
improved analysis of provider performance and practice in bundled payment
arrangements such as the comprehensive care for joint replacement model. The
Alliance urges testing of this measure and reconsideration before it is
finalized. Both this measure and the potentially preventable readmission
measure are based on risk-adjusted estimates. Testing and validation should be
no less than six months with an opportunity to modify the measure prior to
finalizing it. A similar approach was used for many of the OASIS-based
measures that CMS uses for home health agencies. (Submitted by: Alliance for
Home Health Quality and Innovation)
- (Early public comment)We support the goal of the IMPACT act to
align quality measures across post-acute providers and to promote
patient-centeredness in quality efforts. With respect to the draft measure
developed by RTI we have particular concerns related to the definition of
discharge to the community for other post-acute care providers that includes
patients discharged from their setting with home health services while
discharges from home health includes only those patients without home health
services. Patients discharged from SNFs, IRFs, and LTCHs with home health
services will have a greater chance of achieving the discharge to the
community measure, not incurring an unplanned readmission, and potentially
remaining alive for the 31 day period. Cross-setting comparisons of this
quality measure would not be appropriate. Similarly, we believe that the
inclusion of patients who did not have a hospitalization within the past 30
days only in the home health calculation and not for other post-acute care
providers would create different measures that would not be comparable. We
support the exclusion of patients discharged to hospice from the measure
calculation. We have always disagreed with the Discharge to the Community
OASIS-based quality measure’s definition that patients transferred to a
non-institutional hospice are considered an unfavorable outcome. We would
recommend the addition of any patient that elects hospice during the 31-day
window and not just those that are discharged directly to hospice. Patients
may be hospice-eligible but choose to delay their election for a variety of
reasons. This measure does not acknowledge the role that personal
care/non-medical home care services can provide in keeping a patient in the
community. We support the collection of this information across the PAC
providers and its inclusion in the risk adjustment model. We support the
inclusion of this measure in the CASPER reports as soon as possible to provide
agencies with data on their performance. (Submitted by: Association of Home
& Hospice Care of NC/SC Home Care & Hospice Association)
- (Early public comment)The ultimate goals of post-acute care are
avoiding institutionalization and returning patients to their previous level
of independence and functioning, with discharge to community being the primary
goal for the majority of post-acute patients. For many, home is a symbol of
independence, privacy, and competence. Discharge to community is considered a
valuable outcome to measure because it is a multifaceted measure that captures
the patient’s functional status, cognitive capacity, physical ability, and
availability of social support at home. There is considerable variation in
discharge to community rates within and across post-acute settings. Studies
show geographic variation, variation across patient socioeconomic
characteristics (for example, race and ethnicity), and variation by facility
characteristics (for profit vs. nonprofit, freestanding vs. hospital-based,
urban vs. rural). In the IRF setting, discharge to community rates vary across
providers, ranging from about 60% to 75%. The 2015 MedPAC report shows that,
in FY 2013, the facility-level, mean risk-adjusted discharge to community rate
for IRFs within 100 days of admission was 75.8%, and the mean observed rate
was 74.7%. Discharge to community rates also vary widely in the SNF setting,
ranging from as low as 31% to as high as 65%. The 2015 MedPAC report shows a
mean risk-adjusted discharge to community rate of 37.5% for SNFs within 100
days of admission, and mean observed rate of 40.1%. A multicenter study of 23
LTCHs reported that only 28.8% of 1,061 patients who were ventilator-dependent
on admission were discharged to home or assisted living facility. A study of
66,510 Medicare beneficiaries during pre- and post-HH episodes, revealed that
64 percent of beneficiaries discharged from HH did not use any other
Medicare-reimbursed acute or post-acute services in the 30 days following HH
discharge. Significant numbers of patients were admitted to inpatient
facilities (29percent) and lesser numbers to skilled nursing facilities (7.6
percent), inpatient rehabilitation (1.5 percent) and home health (7.2 percent)
or hospice (3.3 percent) within 30 days of HH discharge (Wolff et al., 2008).
II. Feedback Overall, there is not enough detail on the measure
specifications to provide adequate feedback. However, despite the lack of
detail, a response is included below on the discharge to community measure for
LTCH, IRF, SNF, and HH. Description Patients discharged to the community
following PAC stay/episode and do not have an unplanned admission to an acute
care hospital or LTCH in 31 days after community discharge and remain alive
• Although not explicitly stated, it appears that this measure is only holding
the last PAC setting responsible for the discharge? Given what is known about
multiple sites of PAC use either from LTCH/IRF patients are often discharged
to SNF before community discharge, as it is currently worded this measure will
penalize the SNF for the more difficult patients that could not be discharged
from the prior PAC setting. • Research has shown that PAC patients re-enter
the healthcare system through multiple doors after the PAC community
discharge why are these not captured in the measure as a failed transition I
recommend that the numerator should not include individuals who were admitted
to a SNF after PAC community discharge during the 30-day measure window.
Numerator & Denominator There is not enough detail to provide feedback on
the risk adjustment of the numerator. Without details on the variables
included, the origin of those variables, and methods of risk adjustment it is
difficult to provide feedback. Recommend providing further detail. Recommend
including functional status, functional cognition, presence of social support
(e.g., does the individual live alone), and comorbid conditions as risk
adjustors Exclusion There is no discussion of excluding long-stay nursing home
residents in this measure. Long-stay residents that have an acute medical
event, are admitted to an acute care hospital, discharged to PAC for care, and
then transitioned back to long-term care should be excluded from the measure.
These individuals are not returning to the community, while the nursing home
is their home, the effort and processes required for transitioning a long-stay
nursing home resident from PAC back to custodial care is very different that
transitioning a community- residing older adult back to their residence in the
community after a PAC stay. Recommend excluding long stay nursing home
residents from the measure. (Submitted by: American Occupational Therapy
Association)
- (Early public comment)ARN is supportive of a measure that works to
identify unplanned (re)admissions; however, we have concerns with identifying
unplanned (re)admissions based on the planned readmissions algorithm used in
NQF measure #2510: SNF 30-Day All-Cause Readmission Measure (SNFRM); NQF
#2502: All-Cause Unplanned Readmission Measure for 30 Days Post Discharge from
IRFs; NQF #2512: All-Cause Unplanned Readmission Measure for 30 Days Post
Discharge from LTCHs; and NQF #2380: Re-hospitalization During the First 30
Days of Home Health. The exclusion criteria included within NQF #2510 for SNF
stays where the patient had one or more intervening PAC admissions to an IRF
that occurred either between the prior proximal hospital discharge and SNF
admission or after the SNF discharge within the 30-day risk window fails to
allow for a medically complex patient that is treated in an IRF and readmitted
to the SNF within 30 days for a condition that may initially have been treated
as a comorbidity. We disagree with the rationale provided for exclusion, for
while the measure assesses readmission rates while accounting for patient
demographics, principal diagnosis in the prior hospitalization, comorbidities,
and other patient factors, often, this may not be the reason for admission to
a SNF. ARN believes the measure should include the principal diagnosis during
the prior proximal hospitalization, comorbidities based on the secondary
medical diagnoses listed on the patient’s prior proximal hospital claim and
diagnoses from prior hospitalizations that occurred in the previous 365 days,
length of stay during the patient’s prior proximal hospitalization, length of
stay in the intensive care unit (ICU), body system specific surgical
indicators, End-Stage Renal Disease (ESRD) status, whether the patient was
disabled, and the number of prior hospitalizations in the previous 365 days.
It also would be beneficial to understand the comorbidities being evaluated in
the risk-adjustment model. ARN urges the Centers for Medicare and Medicaid
Services (CMS) to develop of a list of comorbidities, comparable to the IRF
Prospective Payment System (PPS) list of comorbidities and we encourage CMS to
categorize an intervening admission to an IRF as a proximal hospitalization.
Additionally, ARN has serious concerns with CMS’s proposal to require PAC
providers to utilize Medicare claims data to calculate their 30-day
readmission rates. Using claims data to calculate readmission rates is
difficult for health care providers, as claims data are cumbersome to use and
access. Employing a 30-day readmission rate measure will not provide
meaningful insight or have an impact on quality improvement efforts if the PAC
settings do not have unrestricted access to the data. Further, ARN believes
that patients who have been discharged to the community and expire within the
post-discharge window should not be included within the quality measure, given
the variation in patient characteristics across the four settings. For
example, as compared to all Medicare beneficiaries, the SNF and LTCH patient
populations represent the most disabled, elderly, and frail beneficiaries. The
Medicare Payment Advisory Commission’s (MedPAC) March 2015 Report to Congress
found that compared with other beneficiaries, “SNF users are older, frailer,
and disproportionately female, disabled, living in an institution, and dually
eligible for both Medicare and Medicaid.” Moreover, as compared with all
Medicare beneficiaries, those admitted to LTCHs are “disproportionately
disabled (under age 65), over age 85, or diagnosed with [ESRD]. They are also
more likely to be African American.” ARN urges CMS to exclude patients that
pass away within the post-discharge window after being discharged to the
community from the discharge to community quality measure, as the types of
patients treated in each setting greatly varies and can lead to an inaccurate
reflection of the quality of care. ARN is pleased the CMS has proposed
discharge measure exclusions; however, we have concerns with the proposed
exclusion of post-acute stays that end in transfer to the same level of care,
and specifically, CMS’s proposal to include only the final post-acute provider
in the discharge to community measure. The Agency’s proposed exclusion
criteria fails to consider when a patient’s “home” is a custodial nursing
facility and the patient’s post-acute episode involves a discharge back to his
or her “home.” In such circumstances, including the final post-acute provider
in the discharge to community measure when a patient is discharged to the
originating level of care, but in essence, is returning home, may distort the
findings of the quality measure. We encourage CMS to design a quality measure
that is capable of capturing the difference between a patient’s return to his
or her home and a patient’s post-acute episode that involves transfer to the
same level of care. (Submitted by: Association of Rehabilitation
Nurses)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program: Skilled Nursing
Facility Quality Reporting System; MUC ID: MUC15-527) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. AHCA is pleased to have the opportunity to comment on the MAP
Preliminary Decisions and MAP Draft Report ”. Thank you again for the
opportunity to provide these comments. Please contact me at DGifford@ahca.org
with any questions or for additional information. We support the MAP’s
preliminary decision to “encourage continued development” of this measure.
However, in the draft report, the MAP must clearly state that encouraging
continued development of this measures should not be taken as support of
inclusion of this measure in the SNF QRP. We also think the report needs to
include the comments and recommendations made by the MAP workgroup on each
measure since that is the primary role of the MAP to provide DHHS with
feedback on the MUC list and DHHS needs to respond to those comments in any
proposed rule. Without inclusion of these comments, if DHHS decided to
implement this measure for rule making via the Federal Register process, CMS
does not need to provide a rationale for their decision. In the draft report,
the MAP should also include a statement that before a measure from one setting
is implemented into another setting, it must be tested in the new setting.
Additionally, for the sake of transparency and enhanced stakeholder feedback
the draft report should include the specific public comments submitted. Our
specific comments on this measure are as follows. 1. While this measure has
been endorsed by NQF, it was developed, tested and validated in the IRF
setting for IRF patients. It was not developed for SNF setting. We do not
think it is appropriate to take a measure from one setting and assume it is
reliable and valid in another setting. If this logic is to be followed
through, there are several other NQF endorsed functional measure that rely on
the CARE tool item set, which is what is used for this measure. We believe,
the MAP process must review and consider all NQF endorsed measures that are
similar, in particular NQF measure 2612 and 2287. 2. In addition, the
proposed measure relies on CARE tool items that were not added to section GG
in the IRF, SNF or LTCH setting. As such, the specifications of this measure
do not match the available data in the PAC assessment tools for SNF, IRF, and
LTCH setting. 3. The specifications are based on ICD-9 but all providers as
of October 2015 are required to use ICD-10 and no cross walk with ICD-10 is
provided, yet the measure will be used during time periods when only ICD-10
data is available. 4. AHCA recommends that, before a measure developed in one
setting is applied to another, that cross-setting measure testing be
performed. Such testing is critically important because of the clinical
sorting that goes on between the settings, with benefit rules, Medicare
enrollment requirements, and the general suitability of the settings resulting
in certain kinds of patients tending to go to SNFs, and other patients tending
to go to IRFs. For example, the IRF benefit rule that patients can receive
three or more hours of therapy each day means that certain groups of patients
who would have difficulty walking will tend to sort into the SNF setting
rather than the IRF setting. This phenomena will also occur on self-care
domains. For example, differences in the proportion and types of stroke
patients between SNF and IRF make application of an IRF measure inaccurate in
the SNF setting. Because CMS has not tested whether the distribution of risk
adjusted measure scores in the SNF setting are the same or widely different
from those in the IRF setting, we are left with a serious concern that the
measure’s distribution will be shifted up in the IRF setting and down in the
SNF setting, without anything to do with the quality of care being provided in
each setting. Last, we recognize that it is entirely possible that the
measures perform adequately after cross-setting measure testing; however, if
this testing is not performed before the measures are rolled out into live
public use, CMS risks promoting a risk adjustment model that does not work as
well for the SNFs compared to the IRF Quality Reporting Programs. (Submitted
by: American Health Care Association )
- ARN is supportive of the IRF functional measures; however, there are
several key differences between the existing and new proposed function items
that may result in variation in the resident assessment results including: (1)
data collection and associated data collection instructions; (2) rating scales
used to score a resident’s level of independence; and (3) item definitions.
Utilizing multiple data collection systems and instruments as well as a
different rating scale and item definitions is both cumbersome and burdensome.
Additionally, functional measures are not a “one size fits all,” and measures
should account for the benefits of the quality of life domain for patients
with these extreme conditions. ARN encourages the Agency to revise the
measures to reflect the following attributes: a low collection burden for
providers and beneficiaries; comprehensibility for beneficiaries; a high level
of significance to patients and providers; and data that is routinely
captured. While we are supportive of functional outcome measures, we are
concerned with that several of these quality indicators are nearly identical
that were submitted and approved by NQF for use by different vendors.
(Submitted by: Association of Rehabilitation Nurses)
- FAH supports the workgroup's recommendation and rationale. We request
that the measure be fully tested before it is considered for a future payment
program. (Submitted by: Federation of American Hospitals)
- (Early public comment)This measure is currently in early
development and measure specifications are in preliminary stages of
clarification. The proposed application could create inaccuracy in
measurement of patient condition when used in other PAC settings. Terms have
not been defined within the exclusions (i.e. "incomplete stays") or clarified
regarding time parameters (i.e. “residents who are not Medicare Fee for
Service beneficiaries” – does this mean they have never been, recently changed
coverage prior to care or changed after care was provided?). No testing of
the measure in non-IRF settings has been done. These could create inaccurate
data capture throughout PAC venues. The Technical Expert Panel indicated that
this measure needs extensive work to assure accuracy and to meet the purpose
for which it was intended. Because there is potential for accuracy this
measure should continue to be developed. (Submitted by: Genesis Health
Care)
- (Early public comment)AHCA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. Thank you again for the opportunity to provide these comments. Please
contact me at DGifford@ahca.org with any questions or for additional
information. 1. While this measure has been endorsed by NQF, it was
developed, tested and validated in the IRF setting for IRF patients. It was
not developed for SNF setting. We do not think it is appropriate to take a
measure from one setting and assume it is reliable and valid in another
setting. If this logic is to be followed through, there are several other NQF
endorsed functional measure that rely on the CARE tool item set, which is what
is used for this measure. We believe, the MAP process must review and consider
all NQF endorsed measures that are similar, in particular NQF measure 2612 and
2287. 2. In addition, the proposed measure relies on CARE tool items that
were not added to section GG in the IRF, SNF or LTCH setting. As such, the
specifications of this measure do not match the available data in the PAC
assessment tools for SNF, IRF, and LTCH setting. 3. The specifications are
based on ICD-9 but all providers as of October 2015 are required to use ICD-10
and no cross walk with ICD-10 is provided, yet the measure will be used during
time periods when only ICD-10 data is available. 4. AHCA recommends that,
before a measure developed in one setting is applied to another, that
cross-setting measure testing be performed. Such testing is critically
important because of the clinical sorting that goes on between the settings,
with benefit rules, Medicare enrollment requirements, and the general
suitability of the settings resulting in certain kinds of patients tending to
go to SNFs, and other patients tending to go to IRFs. For example, the IRF
benefit rule that patients can receive three or more hours of therapy each day
means that certain groups of patients who would have difficulty walking will
tend to sort into the SNF setting rather than the IRF setting. This phenomena
will also occur on self-care domains. For example, differences in the
proportion and types of stroke patients between SNF and IRF make application
of an IRF measure inaccurate in the SNF setting. Because CMS has not tested
whether the distribution of risk adjusted measure scores in the SNF setting
are the same or widely different from those in the IRF setting, we are left
with a serious concern that the measure’s distribution will be shifted up in
the IRF setting and down in the SNF setting, without anything to do with the
quality of care being provided in each setting. Last, we recognize that it is
entirely possible that the measures perform adequately after cross-setting
measure testing; however, if this testing is not performed before the measures
are rolled out into live public use, CMS risks promoting a risk adjustment
model that does not work as well for the SNFs compared to the IRF Quality
Reporting Programs. Therefore, for these reasons, we believe this measure
does not meet NQF MAP criteria for endorsement but rather should receive a
vote of “encourage continued development” only after NQF MAP process has
reviewed the other NQF endorsed functional measures to determine which the
best to be recommended is. (Submitted by: American Health Care Association
)
- (Early public comment)This is a measure tested and validated in the
IRF setting. it cannot be assumed to have validity in the SNF setting without
testing. The populations are different and mobility may not be the goal for
the SNF patient receiving skilled services. This measure also needs risk
adjustment for acuity, as many patients are sent to SNF for skilled services
related to complex medical care, in addition to rehab services - but these may
not all address mobility. Thus risk adjustment for acuity, functional status
prior to admission and pt goals much be taken into account (Submitted by:
Leadingage)
- (Early public comment)First, the IRF endorsement of this measure
was conditional, requiring updates when data is available (after October 2016)
to display the reliability and validity of the measure, among other things.
We strongly urge the MAP PAC/LTC committee to consider whether or not to
approve and/or implement a measure that has not been shown to meet NQF
requirements for reliability and validity. Second, this measure should be
identified as a competing measure with NQF #2612 - CARE: Improvement in
Mobility, developed by AHCA and endorsed earlier this year by NQF. These
measures are similar in that they utilize functional items creates as part of
the CARE tool development project or PAC-PRD, but have differences in the
functional items included, inclusion/exclusion criteria, and risk-adjustment
methodologies. Third, a "best-in-class" determination related to the
functional improvement or change in self-care is required and necessary. This
measure has already been found to compete with a UDSMR developed measure (NQF
#2321), and NQF staff chose not to make a "best-in-class" decision until such
a time as additional measure testing was available. With the additional
consideration for the AHCA measure that is already NQF endorsed noted
previously, there exist 3 different ways for measuring the same functional
construct. The IMPACT Act requirements indicate that measures for PAC
settings should be "standardized and interoperable", yet implementation of the
IMPACT Act is burdening PAC providers with the data collection of functional
items for payment and similar but different functional items for quality. PAC
providers should not bear the burden of data collection for measures that may
not be identified as "best-in-class". (Submitted by: UDSMR)
- (Early public comment) This measure was developed for the IRF and
as such may not be usable in the SNF without further development and testing.
The admission criteria for a patient entering an IRF is different than a SNF,
therefore IRF patients may be different than SNF patients. Therefore,
measuring mobility could use different items for a SNF patient than measuring
mobility for an IRF patient. This measure requires testing and validation
before it could be used for SNF patients. (Submitted by: National
Association for the Support of Long Term Care)
- (Early public comment)ARN is supportive of the IRF functional
measures; however, there are several key differences between the existing and
new proposed function items that may result in variation in the resident
assessment results including: (1) data collection and associated data
collection instructions; (2) rating scales used to score a resident’s level of
independence; and (3) item definitions. Utilizing multiple data collection
systems and instruments as well as a different rating scale and item
definitions is both cumbersome and burdensome. Additionally, functional
measures are not a “one size fits all,” and measures should account for the
benefits of the quality of life domain for patients with these extreme
conditions. ARN encourages the Agency to revise the measures to reflect the
following attributes: a low collection burden for providers and beneficiaries;
comprehensibility for beneficiaries; a high level of significance to patients
and providers; and data that is routinely captured. (Submitted by: Association
of Rehabilitation Nurses)
- (Early public comment)AMDA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
AMDA - The Society for Post-Acute and Long-Term Care Medicine (AMDA)
represents over 5,500 physician medical directors, attending physicians, and
other practitioners who work in post-acute and long-term care settings.
Thank you again for the opportunity to provide these comments. Please contact
me at abardakh@amda.com with any questions or for additional information.
1. While this measure has been endorsed by NQF, it was developed, tested and
validated in the IRF setting for IRF patients. It was not developed for SNF
setting. We do not think it is appropriate to take a measure from one setting
and assume it is reliable and valid in another setting. If this logic is to be
followed through, there are several other NQF endorsed functional measure that
rely on the CARE tool item set, which is what is used for this measure. We
believe, the MAP process must review and consider all NQF endorsed measures
that are similar. In particular, NQF measure 2612 and 2687 which rely on the
CARE tool items. 2. In addition, the proposed measure relies on CARE tool
items that were not added to section GG in the IRF, SNF or LTCH setting. As
such, the specifications of this measure does not match the available data in
the PAC assessment tools for SNF, IRF, and LTCH setting. 3. The
specifications are based on ICD-9 but all providers as of October 2015 are
required to use ICD-10 and no cross walk with ICD-10 is provided, yet the
measure will be used during time periods when only ICD-10 data is available.
4. AMDA recommends that, before a measure developed in one setting is applied
to another, that cross-setting measure testing be performed. Such testing is
critically important because of the clinical sorting that goes on between the
settings, with benefit rules, Medicare enrollment requirements, and the
general suitability of the settings resulting in certain kinds of patients
tending to go to SNFs, and other patients tending to go to IRFs. For example,
the IRF benefit rule that patients can receive three or more hours of therapy
each day means that certain groups of patients who would have difficulty
walking will tend to sort into the SNF setting rather than the IRF setting.
This phenomena will also occur on self-care domains. For example, differences
in the proportion and types of stroke patients between SNF and IRF make
application of an IRF measure inaccurate in the SNF setting. Because CMS has
not tested whether the distribution of risk adjusted measure scores in the SNF
setting are the same or widely different from those in the IRF setting, we are
left with a serious concern that the measure’s distribution will be shifted up
in the IRF setting and down in the SNF setting, without anything to do with
the quality of care being provided in each setting. Last, we recognize that it
is entirely possible that the measures perform adequately after cross-setting
measure testing; however, if this testing is not performed before the measures
are rolled out into live public use, CMS risks promoting a risk adjustment
model that does not work as well for the SNFs compared to the IRF Quality
Reporting Programs. Therefore, for these reasons, we believe this measure
does not meet NQF MAP criteria for endorsement but rather should receive a
vote of “encourage continued development” only after NQF MAP process has
reviewed the other NQF endorsed functional measure to determine which the best
to be recommended is. (Submitted by: AMDA-The Society for Post-Acute and
Long-Term Care Medicine)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)At least one NRHI member has expressed
concerns regarding this measure. Specifically, clinical staff at
HealthInsight have concerns with designation of functional status scores such
as "self-care score" and "mobility score" that will rate the performance of
facilities. (Submitted by: Network for Regional Healthcare
Improvement)
(Program: Skilled Nursing
Facility Quality Reporting System; MUC ID: MUC15-528) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. AHCA is pleased to have the opportunity to comment on the MAP
Preliminary Decisions and MAP Draft Report ”. Thank you again for the
opportunity to provide these comments. Please contact me at DGifford@ahca.org
with any questions or for additional information. We support the MAP’s
preliminary decision to “encourage continued development” of this measure.
However, in the draft report, the MAP must clearly state that encouraging
continued development of this measures should not be taken as support of
inclusion of this measure in the SNF QRP. We also think the report needs to
include the comments and recommendations made by the MAP workgroup on each
measure since that is the primary role of the MAP to provide DHHS with
feedback on the MUC list and DHHS needs to respond to those comments in any
proposed rule. Without inclusion of these comments, if DHHS decided to
implement this measure for rule making via the Federal Register process, CMS
does not need to provide a rationale for their decision. In the draft report,
the MAP should also include a statement that before a measure from one setting
is implemented into another setting, it must be tested in the new setting.
Additionally, for the sake of transparency and enhanced stakeholder feedback
the draft report should include the specific public comments submitted. Our
specific comments on this measure are as follows. 1. While this measure has
been endorsed by NQF, it was developed, tested and validated in the IRF
setting for IRF patients. It was not developed for SNF setting. We do not
think it is appropriate to take a measure from one setting and assume it is
reliable and valid in another setting. If this logic is to be followed
through, there are several other NQF endorsed functional measure that rely on
the CARE tool item set, which is what is used for this measure. We believe,
the MAP process must review and consider all NQF endorsed measures that are
similar, in particular NQF measures 2613 and 2286. 2. In addition, the
proposed measure relies on CARE tool items that were not added to section GG
in the IRF, SNF or LTCH setting. As such, the specifications of this measure
do not match the available data in the PAC assessment tools for SNF, IRF, and
LTCH setting. 3. AHCA recommends that, before a measure developed in one
setting is applied to another, that cross-setting measure testing be
performed. Such testing is critically important because of the clinical
sorting that goes on between the settings, with benefit rules, Medicare
enrollment requirements, and the general suitability of the settings resulting
in certain kinds of patients tending to go to SNFs, and other patients tending
to go to IRFs. For example, the IRF benefit rule that patients can receive
three or more hours of therapy each day means that certain groups of patients
who would have difficulty walking will tend to sort into the SNF setting
rather than the IRF setting. This phenomena will also occur on self-care
domains. For example, differences in the proportion and types of stroke
patients between SNF and IRF make application of an IRF measure inaccurate in
the SNF setting Because CMS has not tested whether the distribution of risk
adjusted measure scores in the SNF setting are the same or widely different
from those in the IRF setting, we are left with a serious concern that the
measure’s distribution will be shifted up in the IRF setting and down in the
SNF setting, without anything to do with the quality of care being provided in
each setting. Last, we recognize that it is entirely possible that the
measures perform adequately after cross-setting measure testing; however, if
this testing is not performed before the measures are rolled out into live
public use, CMS risks degrading the integrity of the SNF and IRF Quality
Reporting Programs by introducing measures that may become publicly known to
be unusable for their intended purpose, or at worst need to be retracted and
redeveloped. 4. The specifications are based on ICD-9 but all providers as of
October 2015 are required to use ICD-10 and no cross walk with ICD-10 is
provided, yet the measure will be used during time periods when only ICD-10
data is available. (Submitted by: American Health Care Association
)
- ARN is supportive of the IRF functional measures; however, there are
several key differences between the existing and new proposed function items
that may result in variation in the resident assessment results including: (1)
data collection and associated data collection instructions; (2) rating scales
used to score a resident’s level of independence; and (3) item definitions.
Utilizing multiple data collection systems and instruments as well as a
different rating scale and item definitions is both cumbersome and burdensome.
Additionally, functional measures are not a “one size fits all,” and measures
should account for the benefits of the quality of life domain for patients
with these extreme conditions. ARN encourages the Agency to revise the
measures to reflect the following attributes: a low collection burden for
providers and beneficiaries; comprehensibility for beneficiaries; a high level
of significance to patients and providers; and data that is routinely
captured. While we are supportive of functional outcome measures, we are
concerned with that several of these quality indicators are nearly identical
that were submitted and approved by NQF for use by different vendors.
(Submitted by: Association of Rehabilitation Nurses)
- FAH supports the workgroup's recommendation and rationale. We request
that the measure be fully tested before it is considered for a future payment
program. (Submitted by: Federation of American Hospitals)
- (Early public comment)This measure is currently in early
development and measure specifications are in preliminary stages of
clarification. The proposed application could create inaccuracy in
measurement of patient condition when used in other PAC settings. Terms have
not been defined within the exclusions (i.e. "incomplete stays") and patient
coverage parameters have not been clarified (i.e. “residents not covered by
the Medicare Fee for Service program”---does this mean never under Medicare or
having recently changed from Medicare or having changed coverage after
services were provided?). Also, there is no clinical explanation or
justification for excluding patients discharged to hospice. No testing of the
measure in non-IRF settings has been done. These could create inaccurate data
capture throughout PAC venues. The Technical Expert Panel indicated that this
measure needs work to assure accuracy and to meet the purpose for which it was
intended. Because there is potential for accuracy this measure should continue
to be developed. (Submitted by: Genesis Health Care)
- (Early public comment)AHCA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. Thank you again for the opportunity to provide these comments. Please
contact me at DGifford@ahca.org with any questions or for additional
information. 1. While this measure has been endorsed by NQF, it was
developed, tested and validated in the IRF setting for IRF patients. It was
not developed for SNF setting. We do not think it is appropriate to take a
measure from one setting and assume it is reliable and valid in another
setting. If this logic is to be followed through, there are several other NQF
endorsed functional measure that rely on the CARE tool item set, which is what
is used for this measure. We believe, the MAP process must review and consider
all NQF endorsed measures that are similar, in particular NQF measures 2613
and 2286. 2. In addition, the proposed measure relies on CARE tool items that
were not added to section GG in the IRF, SNF or LTCH setting. As such, the
specifications of this measure do not match the available data in the PAC
assessment tools for SNF, IRF, and LTCH setting. 3. AHCA recommends that,
before a measure developed in one setting is applied to another, that
cross-setting measure testing be performed. Such testing is critically
important because of the clinical sorting that goes on between the settings,
with benefit rules, Medicare enrollment requirements, and the general
suitability of the settings resulting in certain kinds of patients tending to
go to SNFs, and other patients tending to go to IRFs. For example, the IRF
benefit rule that patients can receive three or more hours of therapy each day
means that certain groups of patients who would have difficulty walking will
tend to sort into the SNF setting rather than the IRF setting. This phenomena
will also occur on self-care domains. For example, differences in the
proportion and types of stroke patients between SNF and IRF make application
of an IRF measure inaccurate in the SNF setting Because CMS has not tested
whether the distribution of risk adjusted measure scores in the SNF setting
are the same or widely different from those in the IRF setting, we are left
with a serious concern that the measure’s distribution will be shifted up in
the IRF setting and down in the SNF setting, without anything to do with the
quality of care being provided in each setting. Last, we recognize that it is
entirely possible that the measures perform adequately after cross-setting
measure testing; however, if this testing is not performed before the measures
are rolled out into live public use, CMS risks degrading the integrity of the
SNF and IRF Quality Reporting Programs by introducing measures that may become
publicly known to be unusable for their intended purpose, or at worst need to
be retracted and redeveloped. 4. The specifications are based on ICD-9 but all
providers as of October 2015 are required to use ICD-10 and no cross walk with
ICD-10 is provided, yet the measure will be used during time periods when only
ICD-10 data is available. Therefore, for these reasons, we believe this
measure does not meet NQF MAP criteria for endorsement but rather should
receive a vote of “encourage continued development” only after NQF MAP process
has reviewed the other NQF endorsed functional measures to determine which the
best to be recommended is. (Submitted by: American Health Care Association
)
- (Early public comment)While this measure was previously endorsed
for IRFs, we would note that endorsement of a similar measure (NQF #2633)
utilizing the same measure items and risk adjustment methodology was
conditional with requirements for updates on the reliability and validity of
the measure. We strongly urge the MAP committee to review and determine
whether or not this measure meets NQF requirements for reliability and
validity, especially in the SNF setting. Second, we would note that the
functional items identified in this measure differ from those endorsed to
measure improvement in self-care as developed by AHCA. While a majority of
these items are the same, we question which set of items can be shown to
produce reliable and valid results for measuring quality. Finally, we are very
concerned that the implementation of these measures is causing the need to
collect one set of functional items for payment and a similar but different
set of functional items for quality. Until such a time as a best-in-class
decision is made on which functional items are most representative of quality
and payment, PAC providers are burdened with dual data collection. (Submitted
by: UDSMR)
- (Early public comment)This measure compares an actual score with an
expected score. This is an IRF measure that is proposed to be used for SNF.
SNF patients are going to have different expected scores than IRF patients.
So, this IRF measure cannot be used for SNF patients without testing its
reliability and validity. (Submitted by: National Association for the
Support of Long Term Care)
- (Early public comment)ARN is supportive of the IRF functional
measures; however, there are several key differences between the existing and
new proposed function items that may result in variation in the resident
assessment results including: (1) data collection and associated data
collection instructions; (2) rating scales used to score a resident’s level of
independence; and (3) item definitions. Utilizing multiple data collection
systems and instruments as well as a different rating scale and item
definitions is both cumbersome and burdensome. Additionally, functional
measures are not a “one size fits all,” and measures should account for the
benefits of the quality of life domain for patients with these extreme
conditions. ARN encourages the Agency to revise the measures to reflect the
following attributes: a low collection burden for providers and beneficiaries;
comprehensibility for beneficiaries; a high level of significance to patients
and providers; and data that is routinely captured. (Submitted by: Association
of Rehabilitation Nurses)
- (Early public comment)AMDA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
AMDA - The Society for Post-Acute and Long-Term Care Medicine (AMDA)
represents over 5,500 physician medical directors, attending physicians, and
other practitioners who work in post-acute and long-term care settings.
Thank you again for the opportunity to provide these comments. Please contact
me at abardakh@amda.com with any questions or for additional information.
1. While this measure has been endorsed by NQF, it was developed, tested and
validated in the IRF setting for IRF patients. It was not developed for SNF
setting. We do not think it is appropriate to take a measure from one setting
and assume it is reliable and valid in another setting. If this logic is to be
followed through, there are several other NQF endorsed functional measure that
rely on the CARE tool item set, which is what is used for this measure. We
believe, the MAP process must review and consider all NQF endorsed measures
that are similar. In particular, NQF measure 2613 and 2686 which rely on the
CARE tool items. 2. AMDA recommends that, before a measure developed in one
setting is applied to another, that cross-setting measure testing be
performed. Such testing is critically important because of the clinical
sorting that goes on between the settings, with benefit rules, Medicare
enrollment requirements, and the general suitability of the settings resulting
in certain kinds of patients tending to go to SNFs, and other patients tending
to go to IRFs. For example, the IRF benefit rule that patients can receive
three or more hours of therapy each day means that certain groups of patients
who would have difficulty walking, and/or significant deconditioning,
functional quadriplegia, dysphagia, or gastrostomy, will tend to sort into the
SNF setting rather than the IRF setting. This phenomena will also occur on
self-care domains. For example, differences in the proportion and types of
stroke patients between SNF and IRF make application of an IRF measure
inaccurate in the SNF setting Because CMS has not tested whether the
distribution of risk adjusted measure scores in the SNF setting are the same
or widely different from those in the IRF setting, we are left with a serious
concern that the measure’s distribution will be shifted up in the IRF setting
and down in the SNF setting, without anything to do with the quality of care
being provided in each setting. Last, we recognize that it is entirely
possible that the measures perform adequately after cross-setting measure
testing; however, if this testing is not performed before the measures are
rolled out into live public use, CMS risks degrading the integrity of the SNF
and IRF Quality Reporting Programs by introducing measures that may become
publicly known to be unusable for their intended purpose, or at worst need to
be retracted and redeveloped. 3. In addition, the proposed measure relies on
CARE tool items that were not added to section GG in the IRF, SNF or LTCH
setting. As such, the specifications of this measure does not match the
available data in the PAC assessment tools for SNF, IRF, and LTCH setting.
4. The specifications are based on ICD-9 but all providers as of October 2015
are required to use ICD-10 and no cross walk with ICD-10 is provided, yet the
measure will be used during time periods when only ICD-10 data is available.
5. AMDA recommends that, before a measure developed in one setting is applied
to another, that cross-setting measure testing be performed. Such testing is
critically important because of the clinical sorting that goes on between the
settings, with benefit rules, Medicare enrollment requirements, and the
general suitability of the settings resulting in certain kinds of patients
tending to go to SNFs, and other patients tending to go to IRFs. For example,
the IRF benefit rule that patients can receive three or more hours of therapy
each day means that certain groups of patients who would have difficulty
walking will tend to sort into the SNF setting rather than the IRF setting.
This phenomena will also occur on self-care domains. For example, differences
in the proportion and types of stroke patients between SNF and IRF make
application of an IRF measure inaccurate in the SNF setting. Because CMS has
not tested whether the distribution of risk adjusted measure scores in the SNF
setting are the same or widely different from those in the IRF setting, we are
left with a serious concern that the measure’s distribution will be shifted up
in the IRF setting and down in the SNF setting, without anything to do with
the quality of care being provided in each setting. Last, we recognize that it
is entirely possible that the measures perform adequately after cross-setting
measure testing; however, if this testing is not performed before the measures
are rolled out into live public use, CMS risks promoting a risk adjustment
model that does not work as well for the SNFs compared to the IRF Quality
Reporting Programs. Therefore, for these reasons, we believe this measure
does not meet NQF MAP criteria for endorsement but rather should receive a
vote of “encourage continued development” only after NQF MAP process has
reviewed the other NQF endorsed functional measure to determine which the best
to be recommended is. (Submitted by: AMDA-The Society for Post-Acute and
Long-Term Care Medicine)
- (Early public comment)The measure does not appear to consider
performance skills and cognitive capacities of self-care such as sequencing,
problem-solving, temporal appropriateness (e.g., whether to dress for day or
bed), memory, and activity planning. Nor does the measure consider
performance of activities of daily living, including the broader instrumental
activities of daily living (IADLs), which significantly impact a patient’s
ability to function and live independently in the community. This IRF
measure has been risk adjusted for the SNF setting. It remains unclear how
this measure is distinctly different from the "Change in" Self Care measure.
(Submitted by: American Occupational Therapy Association)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)At least one NRHI member has expressed
concerns regarding this measure. Specifically, clinical staff at
HealthInsight have concerns with designation of functional status scores such
as "self-care score" and "mobility score" that will rate the performance of
facilities. (Submitted by: Network for Regional Healthcare
Improvement)
(Program: Skilled Nursing
Facility Quality Reporting System; MUC ID: MUC15-529) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. AHCA is pleased to have the opportunity to comment on the MAP
Preliminary Decisions and MAP Draft Report ”. Thank you again for the
opportunity to provide these comments. Please contact me at DGifford@ahca.org
with any questions or for additional information. We support the MAP’s
preliminary decision to “encourage continued development” of this measure.
However, in the draft report, the MAP must clearly state that encouraging
continued development of this measures should not be taken as support of
inclusion of this measure in the SNF QRP. We also think the report needs to
include the comments and recommendations made by the MAP workgroup on each
measure since that is the primary role of the MAP to provide DHHS with
feedback on the MUC list and DHHS needs to respond to those comments in any
proposed rule. Without inclusion of these comments, if DHHS decided to
implement this measure for rule making via the Federal Register process, CMS
does not need to provide a rationale for their decision. In the draft report,
the MAP should also include a statement that before a measure from one setting
is implemented into another setting, it must be tested in the new setting.
Additionally, for the sake of transparency and enhanced stakeholder feedback
the draft report should include the specific public comments submitted. Our
specific comments on this measure are as follows. 1. While this measure has
been endorsed by NQF, it was developed, tested and validated in the IRF
setting for IRF patients. It was not developed for SNF setting. We do not
think it is appropriate to take a measure from one setting and assume it is
reliable and valid in another setting. If this logic is to be followed
through, there are several other NQF endorsed functional measure that rely on
the CARE tool item set, which is what is used for this measure. We believe,
the MAP process must review and consider all NQF endorsed measures that are
similar, in particular NQF measures 2612 and 2287. 2. In addition, the
proposed measure relies on CARE tool items that were not added to section GG
in the IRF, SNF or LTCH setting. As such, the specifications of this measure
do not match the available data in the PAC assessment tools for SNF, IRF, and
LTCH setting. 3. AHCA recommends that, before a measure developed in one
setting is applied to another, that cross-setting measure testing be
performed. Such testing is critically important because of the clinical
sorting that goes on between the settings, with benefit rules, Medicare
enrollment requirements, and the general suitability of the settings resulting
in certain kinds of patients tending to go to SNFs, and other patients tending
to go to IRFs. For example, the IRF benefit rule that patients can receive
three or more hours of therapy each day means that certain groups of patients
who would have difficulty walking will tend to sort into the SNF setting
rather than the IRF setting. Because CMS has not tested whether the
distribution of risk adjusted measure scores in the SNF setting are the same
or widely different from those in the IRF setting, we are left with a serious
concern that the measure’s distribution will be shifted up in the IRF setting
and down in the SNF setting, without anything to do with the quality of care
being provided in each setting. Last, we recognize that it is entirely
possible that the measures perform adequately after cross-setting measure
testing; however, if this testing is not performed before the measures are
rolled out into live public use, CMS risks degrading the integrity of the SNF
and IRF Quality Reporting Programs by introducing measures that may become
publicly known to be unusable for their intended purpose, or at worst need to
be retracted and redeveloped. 4. The specifications are based on ICD-9 but all
providers as of October 2015 are required to use ICD-10 and no cross walk with
ICD-10 is provided, yet the measure will be used during time periods when only
ICD-10 data is available. (Submitted by: American Health Care Association
)
- ARN is supportive of the IRF functional measures; however, there are
several key differences between the existing and new proposed function items
that may result in variation in the resident assessment results including: (1)
data collection and associated data collection instructions; (2) rating scales
used to score a resident’s level of independence; and (3) item definitions.
Utilizing multiple data collection systems and instruments as well as a
different rating scale and item definitions is both cumbersome and burdensome.
Additionally, functional measures are not a “one size fits all,” and measures
should account for the benefits of the quality of life domain for patients
with these extreme conditions. ARN encourages the Agency to revise the
measures to reflect the following attributes: a low collection burden for
providers and beneficiaries; comprehensibility for beneficiaries; a high level
of significance to patients and providers; and data that is routinely
captured. While we are supportive of functional outcome measures, we are
concerned with that several of these quality indicators are nearly identical
that were submitted and approved by NQF for use by different vendors.
(Submitted by: Association of Rehabilitation Nurses)
- FAH agrees with the workgroup's recommendation for continued development
with caution about interpretation of measure results. Significant testing
must be undertaken to determine if there are unintended consequences of the
measure and to assess whether it captures information that is clinically
useful and can inform clinical decisions/improvement. (Submitted by:
Federation of American Hospitals)
- (Early public comment)This measure is currently in early
development and measure specifications are in preliminary stages of
clarification. The proposed application could create inaccuracy in
measurement of patient condition when used in other PAC settings. Terms have
not been defined within the exclusions (i.e. "incomplete stays") and patient
coverage parameters have not been clarified (i.e. “residents not covered by
the Medicare Fee for Service program”---does this mean never under Medicare or
having recently changed from Medicare or having changed coverage after
services were provided?). Also, there is no clinical explanation or
justification for excluding patients discharged to hospice. No testing of the
measure in non-IRF settings has been done. These could create inaccurate data
capture throughout PAC venues. The Technical Expert Panel indicated that this
measure needs work to assure accuracy and to meet the purpose for which it was
intended. Because there is potential for accuracy this measure should continue
to be developed. (Submitted by: Genesis Health Care)
- (Early public comment)While this is a validated measure, it is only
tested in the IRF setting. Furthermore, it is not relying on assessment data
available in the PAC setting. the measure does not adjust for clinical risk,
nor does it take into account an individual's goals for outcome. While IRF
patients are selected because of their ability to participate in 3 or more
hours of therapy, SNF pts may have much more modest functional goals, and
also may be discharge to home with home health before 100% of goals are met.
(Submitted by: LeadingAge)
- (Early public comment)AHCA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
The American Health Care Association (AHCA) represents more than 12,000
non-profit and proprietary skilled nursing centers and assisted living
communities. Rather than having many of our individual members who have
contacted us with comments and to more efficiently provide NQF with feedback,
we have received from our various members, we have summarized their comments
here. Thank you again for the opportunity to provide these comments. Please
contact me at DGifford@ahca.org with any questions or for additional
information. 1. While this measure has been endorsed by NQF, it was
developed, tested and validated in the IRF setting for IRF patients. It was
not developed for SNF setting. We do not think it is appropriate to take a
measure from one setting and assume it is reliable and valid in another
setting. If this logic is to be followed through, there are several other NQF
endorsed functional measure that rely on the CARE tool item set, which is what
is used for this measure. We believe, the MAP process must review and consider
all NQF endorsed measures that are similar, in particular NQF measures 2612
and 2287. 2. In addition, the proposed measure relies on CARE tool items that
were not added to section GG in the IRF, SNF or LTCH setting. As such, the
specifications of this measure do not match the available data in the PAC
assessment tools for SNF, IRF, and LTCH setting. 3. AHCA recommends that,
before a measure developed in one setting is applied to another, that
cross-setting measure testing be performed. Such testing is critically
important because of the clinical sorting that goes on between the settings,
with benefit rules, Medicare enrollment requirements, and the general
suitability of the settings resulting in certain kinds of patients tending to
go to SNFs, and other patients tending to go to IRFs. For example, the IRF
benefit rule that patients can receive three or more hours of therapy each day
means that certain groups of patients who would have difficulty walking will
tend to sort into the SNF setting rather than the IRF setting. Because CMS has
not tested whether the distribution of risk adjusted measure scores in the SNF
setting are the same or widely different from those in the IRF setting, we are
left with a serious concern that the measure’s distribution will be shifted up
in the IRF setting and down in the SNF setting, without anything to do with
the quality of care being provided in each setting. Last, we recognize that it
is entirely possible that the measures perform adequately after cross-setting
measure testing; however, if this testing is not performed before the measures
are rolled out into live public use, CMS risks degrading the integrity of the
SNF and IRF Quality Reporting Programs by introducing measures that may become
publicly known to be unusable for their intended purpose, or at worst need to
be retracted and redeveloped. 4. The specifications are based on ICD-9 but all
providers as of October 2015 are required to use ICD-10 and no cross walk with
ICD-10 is provided, yet the measure will be used during time periods when only
ICD-10 data is available. Therefore, for these reasons, we believe this
measure does not meet NQF MAP criteria for endorsement but rather should
receive a vote of “encourage continued development” only after NQF MAP process
has reviewed the other NQF endorsed functional measures to determine which the
best to be recommended is. (Submitted by: American Health Care Association
)
- (Early public comment)While this measure was previously endorsed
for IRFs, we would note that endorsement of a similar measure (NQF #2634)
utilizing the same measure items and risk adjustment methodology was
conditional with requirements for updates on the reliability and validity of
the measure. We strongly urge the MAP committee to review and determine
whether or not this measure meets NQF requirements for reliability and
validity, especially in the SNF setting. Second, we would note that the
functional items identified in this measure differ from those endorsed to
measure improvement in mobility as developed by AHCA. While a majority of
these items are the same, we question which set of items can be shown to
produce reliable and valid results for measuring quality. Finally, we are very
concerned that the implementation of these measures is causing the need to
collect one set of functional items for payment and a similar but different
set of functional items for quality. Until such a time as a best-in-class
decision is made on which functional items are most representative of quality
and payment, PAC providers are burdened with dual data collection. (Submitted
by: UDSMR)
- (Early public comment)This measure compares an expected score
against an actual score. This measure was designed for the IRF patient and is
proposed to be used for the SNF patient. The SNF patient will have a
different expected score than the IRF patient. This measure cannot be
transferred to be used in the SNF without testing reliability and validity.
(Submitted by: National Association for the Support of Long Term
Care)
- (Early public comment)ARN is supportive of the IRF functional
measures; however, there are several key differences between the existing and
new proposed function items that may result in variation in the resident
assessment results including: (1) data collection and associated data
collection instructions; (2) rating scales used to score a resident’s level of
independence; and (3) item definitions. Utilizing multiple data collection
systems and instruments as well as a different rating scale and item
definitions is both cumbersome and burdensome. Additionally, functional
measures are not a “one size fits all,” and measures should account for the
benefits of the quality of life domain for patients with these extreme
conditions. ARN encourages the Agency to revise the measures to reflect the
following attributes: a low collection burden for providers and beneficiaries;
comprehensibility for beneficiaries; a high level of significance to patients
and providers; and data that is routinely captured. (Submitted by: Association
of Rehabilitation Nurses)
- (Early public comment)AMDA is pleased to have the opportunity to
comment on the List of Measures under Consideration for December 1, 2015”.
AMDA - The Society for Post-Acute and Long-Term Care Medicine (AMDA)
represents over 5,500 physician medical directors, attending physicians, and
other practitioners who work in post-acute and long-term care settings.
Thank you again for the opportunity to provide these comments. Please contact
me at Abardakh@amda.com with any questions or for additional information.
1. While this measure has been endorsed by NQF, it was developed, tested and
validated in the IRF setting for IRF patients. It was not developed for SNF
setting. We do not think it is appropriate to take a measure from one setting
and assume it is reliable and valid in another setting. If this logic is to be
followed through, there are several other NQF endorsed functional measure that
rely on the CARE tool item set, which is what is used for this measure. We
believe, the MAP process must review and consider all NQF endorsed measures
that are similar. In particular, NQF measure 2612 and 2687 which rely on the
CARE tool items. 2. In addition, the proposed measure relies on CARE tool
items that were not added to section GG in the IRF, SNF or LTCH setting. As
such, the specifications of this measure does not match the available data in
the PAC assessment tools for SNF, IRF, and LTCH setting. 3. AMDA recommends
that, before a measure developed in one setting is applied to another, that
cross-setting measure testing be performed. Such testing is critically
important because of the clinical sorting that goes on between the settings,
with benefit rules, Medicare enrollment requirements, and the general
suitability of the settings resulting in certain kinds of patients tending to
go to SNFs, and other patients tending to go to IRFs. For example, the IRF
benefit rule that patients can receive three or more hours of therapy each day
means that certain groups of patients who would have difficulty walking,
and/or significant deconditioning, functional quadriplegia, dysphagia, or
gastrostomy, will tend to sort into the SNF setting rather than the IRF
setting. Because CMS has not tested whether the distribution of risk adjusted
measure scores in the SNF setting are the same or widely different from those
in the IRF setting, we are left with a serious concern that the measure’s
distribution will be shifted up in the IRF setting and down in the SNF
setting, without anything to do with the quality of care being provided in
each setting. Last, we recognize that it is entirely possible that the
measures perform adequately after cross-setting measure testing; however, if
this testing is not performed before the measures are rolled out into live
public use, CMS risks degrading the integrity of the SNF and IRF Quality
Reporting Programs by introducing measures that may become publicly known to
be unusable for their intended purpose, or at worst need to be retracted and
redeveloped. 4. In addition, the proposed measure relies on CARE tool items
that were not added to section GG in the IRF, SNF or LTCH setting. As such,
the specifications of this measure does not match the available data in the
PAC assessment tools for SNF, IRF, and LTCH setting. 5. The specifications
are based on ICD-9 but all providers as of October 2015 are required to use
ICD-10 and no cross walk with ICD-10 is provided, yet the measure will be used
during time periods when only ICD-10 data is available. Therefore, for these
reasons, we believe this measure does not meet NQF MAP criteria for
endorsement but rather should receive a vote of “encourage continued
development” only after NQF MAP process has reviewed the other NQF endorsed
functional measure to determine which the best to be recommended is.
(Submitted by: AMDA-The Society for Post-Acute and Long-Term Care
Medicine)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
- (Early public comment)At least one NRHI member has expressed
concerns regarding this measure. Specifically, clinical staff at
HealthInsight have concerns with designation of functional status scores such
as "self-care score" and "mobility score" that will rate the performance of
facilities. (Submitted by: Network for Regional Healthcare
Improvement)
(Program: Long-Term
Care Hospital Quality Reporting Program; MUC ID: MUC15-530)
|
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Academy of Managed
Care Pharmacy)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program: Hospital
Inpatient Quality Reporting and EHR Incentive Program; MUC ID: MUC15-531)
|
- The Infectious Diseases Society of America (IDSA) supports the endorsement
of NQF #2720 National Healthcare Safety Network (NHSN) Antimicrobial Use (AU)
Measure. The utilization of the NHSN AU measure is a necessary initial step
that will provide healthcare with vital data in a novel, standardized format
on the potential overuse of high value antimicrobials. Without vigilance, the
use of powerful, board-spectrum antibiotics will lead to even greater
incidence of antibiotic resistant infections, which is associated with
increased patient morbidity and mortality. Additionally, as healthcare is
shifting towards value-based care, the NHSN AU measure stratification based on
hospital patient care location, hospital type, and hospital bedsize aligns
with that trend as the stratification data can inform the allocation of
resources within a hospital to focus efforts in decreasing rates of
inappropriate antibiotic use and subsequent bacterial resistance. As stated
in the overarching issues section of the Patient Safety 2015 Draft Report for
Comment, the Patient Safety Standing Committee believes that, “measures that
are proxies for important patient safety actions are useful.” The NHSN AU
measure can be a proxy for important patient safety interventions and we are
hopeful that this measure will provide a foundation for future work related to
antimicrobial stewardship, which promotes the appropriate use of
antimicrobials. IDSA believes that antimicrobial stewardship is imperative to
combat the bacterial resistant pandemic and applauds NQF’s efforts in
promoting the advancement of antimicrobial stewardship within healthcare
through the National Quality Partner’s Antibiotic Stewardship Action Team.
(Submitted by: The Infectious Diseases Society of America)
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- Antimicrobial use is an important topic and will support antibiotic
stewardship QI efforts. However, as specified, and because the lack of
experience with this measure, it is not ready for hospital accountability.
Some issues with this measure for use as a hospital accountability measure
include: lack of risk adjustment; hospital with higher acuity will likely
have more patients that need to be on antibiotics; and lack of clarity on how
publicly reporting this will inform the public at this point. Further, the
measure developer has stated that the measure needs to be used for several
years before publicly reported; we support the developers input on its
immediate use. (Submitted by: Children's Hospital Association)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Society of
Hospital Medicine)
- The AHA strongly supports antimicrobial stewardship efforts, which are
aimed at minimizing the overuse of antibiotics to preserve their effectiveness
and reduce the emergence of drug-resistant bacteria. However, we do not
believe this measure is appropriate for the IQR program at this time, and urge
the MAP not to support it. As we understand it, the measure under review is
intended for surveillance and internal improvement efforts. It also may help
to create a foundation for future measures assessing the appropriate use of
antibiotics by capturing information on overall antibiotic use. We agree that
a national standard for capturing overall antibiotic use will be helpful to
future efforts, but do not believe the measure is appropriate for public
reporting or pay-for-performance at this time for two reasons. First, as noted
by committee, the testing sample for the measure is small, providing limited
insight into any potential unintended consequences of reporting the measure on
a national scale. Second, the use of the measure in public reporting may
result in misleading comparisons of hospital performance. We believe a number
of factors can contribute to the differences in antibiotic use rates. For
example, we would expect that tertiary and quaternary care referral hospitals
would have higher rates of antibiotic use than smaller hospitals given the
complexity of their patient population. (Submitted by: American Hospital
Association (AHA))
- ACS does not support this measure for inclusion in HIQR. ACS supports the
appropriate use of antibiotics but this measure is too general and it is
unclear as to what it is measuring. Furthermore, National Healthcare Safety
Network (NHSN) stated that they and wish to gain greater experience and gather
more information before using it for reporting or payment. This measure could
be further developed and used for internal hospital improvement but requires a
lot more work if it will be used for accountability purposes. (Submitted by:
American College of Surgeons)
- GNYHA does not support adoption of this measure in the Hospital Inpatient
Quality Reporting (IQR) Program. GNYHA is currently working with its member
hospitals on implementing antibiotic stewardship practices, including
effective monitoring of antimicrobial use. GNYHA and its members fully
support the rationale and potential benefits that the availability of
standardized antimicrobial use data offer to a hospital’s antimicrobial
stewardship activities. However, CDC has reported that as of October 2015,
only about 100 US hospitals were participating in the NSHN Antimicrobial Use
module to track this measure. This is due at least in part to the technical
difficulty associated with obtaining the required data in the required format
for submission to NHSN. While not all Electronic Health Record (EHR) vendors
have the capability to capture and submit this data to NHSN, those that do,
have quoted prohibitive costs for hospitals to purchase the antibiotic
reporting module. Furthermore, those hospitals that are collecting this
measure have observed a significant variability associated with this data
across facilities, calling into question data validity and accuracy. While
GNYHA is in favor of encouraging hospitals to participate in CDC Antibiotic
Use module, the technical difficulties and inexperience with the use of the
data produced in this measure suggest that the measure is not yet ready for
CMS implementation and public reporting. (Submitted by: Greater New York
Hospital Association)
- (Early public comment)We strongly support the inclusion of this
measure in the Hospital Inpatient Quality Reporting System (HIQR). As we
noted in earlier comments to NQF encouraging endorsement of the measure, CDC
estimates that more than half of all hospital patients receive an antibiotic,
yet 30-50 percent of hospital antibiotic use is unnecessary or inappropriate,
spurring the growth of resistant bacteria and difficult- or
impossible-to-treat infections. , Tracking of antibiotic prescribing and
resistance patterns in hospitals is therefore a crucial element of effective
antibiotic stewardship programs. The inclusion of the antimicrobial use
measure in the Hospital Inpatient Quality Reporting System – as a first step
toward inclusion in the Value-Based Payment system – will help facilities
establish a baseline to better understand prescribing patterns and track how
practices change as they implement antimicrobial stewardship programs. In
addition, reporting through NHSN will allow comparison across hospitals to
help them better evaluate their facilities against national data, and to help
the public health community identify system-wide level opportunities for
improving population health. (Submitted by: Trust for America's
Health)
- (Early public comment)We support efforts to assess antimicrobial
use; however, this is a new measure with minimal national experience and
challenges in collection and reporting. Moreover, the measure developer has
stated that the measure should not be introduced into public reporting or
payment programs for at least 3 years. (Submitted by: Premier)
- (Early public comment)SHEA agrees with the statements in the
rationale regarding the potential benefits that the availability of
standardized antimicrobial use data offer to a hospital’s antimicrobial
stewardship activities. However, as recently as October 2015, CDC reported
that only about 100 US hospitals are participating in the NSHN AUR module.
This is due at least in part to the technical difficulty associated with
obtaining the required data in the required format for submission to NHSN.
Many electronic health records are not currently able to provide the
antibiotic use data in the required format thus resulting in the need for
extensive manual manipulation of the data. The HIQR program would be helpful
in facilitating the support needed at the local hospital level to capture this
data effectively. While SHEA is in favor of encouraging hospitals to
participate in the program, the technical difficulties and inexperience with
the use of the data produced in this measure suggest that the measure is not
yet ready for implementation. If reporting were required, but not for at least
a few years, hospitals could use the time to prepare the data. (Submitted
by: The Society for Healthcare Epidemiology of America)
(Program: Prospective Payment System-Exempt Cancer
Hospital Quality Reporting Program; MUC ID: MUC15-532) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: The Infectious
Diseases Society of America)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- Conditionally Support: This measure was previously adopted for the PCHQR
program during FY2016 rulemaking, and it appears that the current MAP review
will focus on a revised risk adjustment methodology (Adjusted Ranking Metric,
or ARM). We support rigorous risk adjustment to produce equitable comparisons
across providers. In the absence of specific details, we are unable to
provide substantive feedback on this updated measure. • The risk adjustment
methodology proposed needs review in order to provide informed feedback • No
additional reporting burden is anticipated in continued reporting (Submitted
by: Alliance of Dedicated Cancer Centers)
- (Early public comment)The measure should be reviewed for
endorsement for use with immunocompromised populations and at a minimum,
tested in this population. The measure will provide meaningful information on
the quality of care provided to cancer hospital patients, we have some
concerns applying the SIR measures to cancer hospitals. The risk model used to
determine the expected events does not consider that cancer hospitals have an
immunocompromised population and would have a higher expected infection rate
than other hospitals. Accordingly, we caution against comparing the
performance of cancer hospitals with other hospitals. (Submitted by:
Premier)
- (Early public comment)This measure was previously adopted for the
PCHQR program during FY2016 rulemaking, and it appears that the current MAP
review will focus on a revised risk adjustment methodology (Adjusted Ranking
Metric, or ARM). We are unable to provide specific comments in the absence of
a detailed description of the revised risk adjustment methodology.
(Submitted by: Alliance of Dedicated Cancer Centers)
- (Early public comment)This measure has already been selected for
use in acute care hospitals. Given that MRSA bacteremia is an important
outcome in PPS-exempt cancer hospitals, it seems quite reasonable to include
this measure in the PCHQR as well. (Submitted by: The Society for Healthcare
Epidemiology of America)
(Program: Prospective
Payment System-Exempt Cancer Hospital Quality Reporting Program; MUC ID:
MUC15-533) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: The Infectious
Diseases Society of America)
- The FAH supports the workgroup's decision and rationale. (Submitted by:
Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The measure should be reviewed for endorsement for use with
immunocompromised populations and at a minimum, tested in this population. The
measure will provide meaningful information on the quality of care provided to
cancer hospital patients, we have some concerns applying the SIR measures to
cancer hospitals. The risk model used to determine the expected events does
not consider that cancer hospitals have an immunocompromised population and
would have a higher expected infection rate than other hospitals. Accordingly,
we caution against comparing the performance of cancer hospitals with other
hospitals. (Submitted by: Premier)
- The ADCC Conditionally Supports: This measure was previously adopted for
the PCHQR program during FY2016 rulemaking, and it appears that the current
MAP review will focus on a revised risk adjustment methodology (ARM). We
support rigorous risk adjustment to produce equitable comparisons across
providers. In the absence of specific details, we are unable to provide
substantive feedback on this updated measure. • The risk adjustment
methodology proposed needs review in order to provide informed feedback • No
additional reporting burden is anticipated in continued reporting (Submitted
by: Alliance of Dedicated Cancer Centers)
- (Early public comment)The measure should be reviewed for
endorsement for use with immunocompromised populations and at a minimum,
tested in this population. The measure will provide meaningful information on
the quality of care provided to cancer hospital patients, we have some
concerns applying the SIR measures to cancer hospitals. The risk model used to
determine the expected events does not consider that cancer hospitals have an
immunocompromised population and would have a higher expected infection rate
than other hospitals. Accordingly, we caution against comparing the
performance of cancer hospitals with other hospitals. (Submitted by:
Premier)
- (Early public comment)This measure was previously adopted for the
PCHQR program during FY2016 rulemaking, and it appears that the current MAP
review will focus on a revised risk adjustment methodology (Adjusted Ranking
Metric, or ARM). We are unable to provide specific comments in the absence of
a detailed description of the revised risk adjustment methodology. (Submitted
by: Alliance of Dedicated Cancer Centers)
- (Early public comment)This measure has already been selected for
use in acute care hospitals. Given that CDI is an important outcome in
PPS-exempt cancer hospitals, it seems quite reasonable to include this measure
in the PCHQR as well. (Submitted by: The Society for Healthcare Epidemiology
of America)
(Program: Hospital Acquired Condition Reduction Program; MUC ID:
MUC15-534) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Johns Hopkins
Armstrong Institute for Patient Safety and Quality)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- We agree with MAP that the measure should be added to IQR after successful
NQF review and endorsement of measure updates. (Submitted by:
Premier)
- We agree with MAP that the measure should be added to HIQR after
successful NQF review and endorsement of measure updates. The measure should
only be included in HACRP after one year of successful reporting in HIQR.
(Submitted by: Premier)
- Because this is a self-reported surgical site infection (SSI) measure
there is a lot of variability regarding case ascertainment in the National
Healthcare Safety Network (NHSN) data set. Therefore, the NHSN data should not
be compared to data with more accurate documentation of SSI, such as data
collected via ACS National Surgical Quality Improvement Program (NSQIP). To
this end, this measure should not be used for accountability purposes.
(Submitted by: American College of Surgeons)
- (Early public comment)It is unclear how this meausre has been
revised and if the revisions have been NQF endorsed. Once the revised measure
receives endorsement it should be included in IQR only and then incorporated
into the other payment programs after gaining experience in IQR. (Submitted
by: Premier)
- (Early public comment)The risk of surgical site infections (SSIs)
can be lowered with appropriate clinical protocols and wound dressings.
Improved performance on this measure would improve the quality of care while
advancing CMS policy objectives. (Submitted by: Smith & Nephew
)
- (Early public comment)Our practioneers would like to know how this
measure intends to deal with non-compliant patients whose infection is the
result of non-compliance instead of hospital technique and care. (Submitted
by: Intermountain Healthcare)
- (Early public comment)The American College of Obstetricians and
Gynecologists supports this measure. (Submitted by: American College of
Obstetricians and Gynecologists)
(Program: Hospital Inpatient Quality Reporting and EHR Incentive Program;
MUC ID: MUC15-534) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- Because this is a self-reported surgical site infection (SSI) measure
there is a lot of variability regarding case ascertainment in the National
Healthcare Safety Network (NHSN) data set. Therefore, the NHSN data should not
be compared to data with more accurate documentation of SSI, such as data
collected via ACS National Surgical Quality Improvement Program (NSQIP). To
this end, this measure should not be used for accountability purposes.
(Submitted by: American College of Surgeons)
- (Early public comment)It is unclear how this meausre has been
revised and if the revisions have been NQF endorsed. Once the revised measure
receives endorsement it should be included in IQR only and then incorporated
into the other payment programs after gaining experience in IQR. (Submitted
by: Premier)
- (Early public comment)SHEA is supportive of harmonizing SSI
reporting efforts. Currently, hospitals must report separately, using
different systems and different protocols, to NHSN and NSQIP. This leads to
duplicative work and, often, results that are discrepant (i.e., hospitals may
perform well using one system and poorly using the other). One potential
downside to this measure appears to be very limited risk adjustment (age and
ASA score only) as compared with the NHSN system that adjusts for several
other factors. Finally, SHEA is unaware of published information about the
performance of this measure. With adequate validation of this measure, SHEA
would be in favor of a harmonized approach. Another concern, unrelated to the
details of the measure, is its inclusion in multiple programs (HVBP, HIQR)
that could result in hospitals being penalized twice for poor performance.
(Submitted by: The Society for Healthcare Epidemiology of
America)
(Program: Hospital Value-Based Purchasing Program; MUC ID: MUC15-534)
|
- FAH supports the workgroup's recommendation and rationale. (Submitted by:
Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- We agree with MAP that the measure should be added to HIQR after
successful NQF review and endorsement of measure updates. The measure should
only be included in HVBP after one year of successful reporting in HIQR.
(Submitted by: Premier)
- Because this is a self-reported surgical site infection (SSI) measure
there is a lot of variability regarding case ascertainment in the National
Healthcare Safety Network (NHSN) data set. Therefore, the NHSN data should not
be compared to data with more accurate documentation of SSI, such as data
collected via ACS National Surgical Quality Improvement Program (NSQIP). To
this end, this measure should not be used for accountability purposes.
(Submitted by: American College of Surgeons)
- (Early public comment)Edwards supports use of this outcome measure
in the Hospital Value Based Purchasing/Hospital Inpatient Quality
Reporting/PPS-exempt Cancer Hospital Quality Reporting/HAC Reduction programs,
as SSIs are a recognized complication of surgery and prevention
recommendations have been published to reduce their incidence. A high rate of
SSI indicates an opportunity for improvement in processes and protocols during
the perioperative time period, potentially relating to surgical processes,
post-operative monitoring, or post-discharge care coordination. (Submitted
by: Edwards Lifesciences)
- (Early public comment)It is unclear how this meausre has been
revised and if the revisions have been NQF endorsed. Once the revised measure
receives endorsement it should be included in IQR only and then incorporated
into the other payment programs after gaining experience in IQR. (Submitted
by: Premier)
(Program: Prospective Payment System-Exempt Cancer Hospital Quality
Reporting Program; MUC ID: MUC15-534) |
- ADCC Supports: This measure was previously adopted for the PCHQR program
during FY2014 rulemaking. It appears that the only change being made is to
the measure title, for which we have no concerns. • The proposed change
relates to a naming convention adjustment. No discernible change in the
measure from its current application. • No additional reporting burden is
anticipated in continued reporting (Submitted by: Alliance for Dedicated
Cancer Centers)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- Because this is a self-reported surgical site infection (SSI) measure
there is a lot of variability regarding case ascertainment in the National
Healthcare Safety Network (NHSN) data set. Therefore, the NHSN data should not
be compared to data with more accurate documentation of SSI, such as data
collected via ACS National Surgical Quality Improvement Program (NSQIP). To
this end, this measure should not be used for accountability purposes.
(Submitted by: American College of Surgeons)
- We agree with MAP that the measure should be added to HIQR after
successful NQF review and endorsement of measure updates. The measure should
only be included in HVBP after one year of successful reporting in HIQR.
(Submitted by: Premier)
- (Early public comment)It is unclear how this meausre has been
revised and if the revisions have been NQF endorsed. Once the revised measure
receives endorsement it should be included in IQR only and then incorporated
into the other payment programs after gaining experience in IQR. (Submitted
by: Premier)
- (Early public comment)This measure was previously adopted for the
PCHQR program during FY2014 rulemaking. It appears that the only change being
made is to the measure title, for which we have no concerns. (Submitted by:
Alliance of Dedicated Cancer Centers)
(Program: End-Stage Renal Disease
Quality Incentive Program; MUC ID: MUC15-575) |
- MUC 15-575—Standardized Mortality Ratio (SMR)-Modified. KCP concurs with
the MAP recommendation of “Do not support.” As the rationale indicates, KCP
strongly recommends that ratio measures be avoided and that year-over-year
normalized rates be used. (Submitted by: Kidney Care Partners)
- CAPC supports the MAP’s recommendation “Do not support” for the inclusion
of MUC15-575 in the End-Stage Renal Disease Quality Incentive Program
(ESRD-QIP). As proposed, the use of this measure would penalize Dialysis
Centers that are able to provide high-quality goals of care discussions with
their patients, particularly if those discussions lead to a patient’s decision
to discontinue hemodialysis. We appreciate the MAP’s position on this measure,
and reiterate the MAP’s suggestion to consider additional exclusions such as
starting hospice after the start of dialysis. (Submitted by: Center to Advance
Palliative Care)
- The National Kidney Foundation does not support this measure in the ESRD
QIP as it does not clearly encourage quality improvement nor provide
meaningful information to patients. This measure does not stratify by causes
of mortality that are attributable to the care that a patient receives by the
dialysis care team and does not adequately adjust for comorbidities. For
example, clinics caring for patients with high levels of comorbidity, poor
functional status and frailty will be penalized. This may create disincentives
to accept patients with complex illness. Lastly, patients acknowledge concern
about dialysis units that have high SMRs, but do not have enough information
to interpret SMR as it reflects quality dialysis care delivery. (Submitted by:
National Kidney Foundation)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- We strongly agree with the listed MAP rationale for this measure, as well
as the need to include hospice after the start of dialysis as an exclusion (as
stated, and additionally, as some people receive dialysis while on hospice for
an unrelated diagnosis). We do not support this measure as currently written.
(Submitted by: American Academy of Hospice and Palliative
Medicine)
- Standardized Hospitalization Ratio (SHR) – Modified Standardized
Mortality Ratio (SMR) – Modified ASN supports both the SMR and SHR measure in
concept; however ASN has several concerns with the current version. One major
area of concern is related to CMS’ Five Star program. In this context, it is
important to view metrics in the manner in which they are currently being
applied rather than as theoretical constructs. As of now, the SMR is used as
a rigid point estimate without any accounting for potential variance. When a
metric is used before endorsement, we have an interesting opportunity to
comment on whether the current use is appropriate; in this case, endorsement
of this metric would de facto endorse the current improper use of this
particular measure as a rigid ordinal ranking system, which is counter to its
design and its statistical qualities. Secondly, ASN would like to see some
refinement of the denominator (expected) adjustments. Currently, the 1st
stage model is adjusted for age, race, ethnicity, sex, diabetes, duration of
ESRD, nursing home status, patient comorbidities at incidence, calendar year
and body mass index (BMI) at incidence. This should be updated to look at
claims with a lag as is likely being done with more recently developed
measures. This would also have the benefit of encouraging parsimony in
measure methodology. Until these changes are made, ASN continues to have
concerns with the measures as proposed. If these measures are endorsed, ASN
urges NQF to comment on the appropriate use of these measures and the
inappropriate use of ordinal ranking without accounting for statistical
variance. (Submitted by: American Society of Nephrology (ASN))
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
- (Early public comment)MUC 15-575—Standardized Mortality Ratio
(SMR)-Modified. KCP notes that NQF 0369 is the existing NQF-endorsed SMR.
For the MUC list, however, CMS makes no reference to NQF 0369 (although
elsewhere it does include NQF numbers), so we must assume MUC 15-575 modifies
NQF 0369 because the information provided by CMS in the MUC list lack the
specificity required to fully evaluate it. It is essential that the full
details of the risk model be made transparent and available for comment during
the MAP process through the CMS list or an external link. Absent this
information, KCP cannot support the measure at this time because we cannot
evaluate it. KCP also strongly recommends that ratio measures be avoided and
that year-over-year normalized rates be used. (Submitted by: Kidney Care
Partners)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-576)
|
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- This comment is for both 576 and 577. Preventing avoidable ambulatory
sensitive condition admissions is clinically important and relevant to
measuring effectiveness (outcomes) - however, the PQI composite measures
cannot be consistently replicated and therefore call into question their
usefulness when attempting to modify behavior. Additionally, for MSSP
programs, they receive their quality measures once a year, six months after
the close of their designated year, BUT need feedback much more often. As
structured, these measures (576, 577) do not meet their needs for delivering
value-based quality care. (Submitted by: American Medical Group Association -
KF)
- Novo Nordisk supports MAP’s recommendation for continued development of
the Prevention Quality Chronic Composite for potential adoption into the MIPS
and MSSP programs in the coming years. The measure has been developed and
validated by the Agency for Healthcare Research and Quality (AHRQ) and
addresses complications for high impact chronic conditions. Considering
patients’ needs in a holistic manner, through the use of a composite measure,
is critical. When considering a composite measure as complex as this one,
however, we caution AHRQ and MAP to ensure that the measure is actionable and
will allow for a system to use the results to make changes that result in
tangible clinical improvements. We know today that two components of the
composite measure (admissions for heart failure and chronic obstructive
pulmonary disease (COPD)) are currently included in the MSSP program.
Inclusion of the broader composite measure to address additional high impact
conditions, including diabetes, could enhance both the MSSP and MIPS programs
and support high quality care for patients with these conditions in order to
prevent unnecessary admissions. Novo Nordisk appreciates MAP’s concerns
regarding the need for risk adjustment for this measure and would support an
updated measure with appropriate risk adjustment incorporated. (Submitted by:
Novo Nordisk)
- PQI 91: Prevention Quality Acute Composite and PQI 92: Prevention Quality
Chronic Composite The MAP draft report references two composite measures under
consideration, MUC 15-577 and MUC 15-576 (PQI 91: Prevention Quality Acute
Composite and PQI 92: Prevention Quality Chronic Composite, respectively) that
were discussed extensively. The AAMC has significant concerns with the use of
these measures in the MIPS program and the shared savings ACO program. The
Association was pleased to see that the MAP discussed the limitations and
potential unintended consequences of these measures, noting the impact that
socio-demographic factors may have on the outcomes addressed by these
measures, and the fact that these measures were designed for use at the
“population level,” not the “clinician level.” The PQIs were originally
designed to measure ambulatory sensitive conditions at a community level and
the rate calculated per 100,000 population. Such a large sample size allows
communities to evaluate their primary care system at a macro level. These
measures were not tested or endorsed by NQF for use at the clinician level,
where the population is much smaller. If implemented in the MIPS program, it
is possible that physician practices with only 20 attributed patients could be
held accountable for performance under this measure. We have major concerns
with applying measures that are intended to address overall admission rates at
a population level to individual physicians in the MIPS program and to ACOs
that have much smaller populations than 100,000. These measures would also
penalize physicians that treat complex patients with multiple chronic
conditions given that there is no appropriate clinical risk adjustment. The
characteristics of the attributed Medicare beneficiaries can vary widely by
physician group practice. Not accounting for the clinical variation in the
underlying population is extremely misleading and disproportionately affects
the physicians who care for the most complex patients. These measures should
have appropriate clinical risk adjustment prior to implementation in any
program. In addition, as admissions and readmissions are often connected to
the broader community, CMS should consider adding an adjustment or
stratification to account for socio-demographic factors. Despite these
challenges with the measure, CMS is currently using these PSI measures under
the physician value-based modifier program. In the 2015 Value Modifier
Experience Report, groups in the low-quality and/or high-cost categories had
worse performance on these measures. These cohorts tended to have patients
with a higher risk score, and therefore this group is unfairly penalized under
the current value-based modifier program. The use of this measure at the ACO
level also would have similar challenges with population size and risk
adjustment. An ACO patient population is typically much smaller than 100,000.
In addition, an ACO is already accountable for costs and has an incentive to
reduce admissions and readmissions. Therefore, use of an additional measure
involving admissions and readmissions would be duplicative and inappropriate.
We recommend that the issues related to risk adjustment, sociodemographic
factors, and attribution be addressed and that these measures be endorsed by
NQF prior to implementation in the MIPS program or the shared savings ACO
program. (Submitted by: Association of American Medical Colleges
(AAMC))
- The MAP’s recommendations for MUC15-576 are to encourage continued
development for use in the MIPS program. The AMA does not support this
recommendation for several reasons. First, these measures were developed to
be reported at the metropolitan area or county level (per 100,000) and still
have not been sufficiently developed and tested for use at the individual
physician level. Currently, CMS modified the measure to enable reporting at
the ACO level but these changes and associated impact on the reliability and
validity of the measure have never been submitted to NQF for review.
Depending on the composition and size of the physician’s practice, this
measure will very likely be found to be infeasible to implement in the MIPS
and we are not confident that data at the individual physician level could
yield performance results that would be considered reliable and valid due to
small sample sizes and the lack of applicability to a broad number of
specialties. We also are concerned that these measures may encourage
inappropriate uses of resources by the physician. In addition, and perhaps
more importantly, it assumes that the physician is the final arbiter and
decision-maker for a patient’s admission or readmission. There are many
individuals and entities involved in a patient’s care and it would seem
imprudent to attribute sole responsibility to an individual physician. In
addition, the MAP rationale notes that the risk model is under development and
the AMA strongly urges CMS to address the potential sociodemographic (SDS)
factors that may play an important role in impacting an ACO’s ability to limit
admissions or readmissions. To date, the results that developers have
provided during the NQF’s SDS trial period are limited to factors such as dual
eligible status and race. CMS and its developers must look beyond the
traditional SDS factors and begin to address variables including, but not
limited to, employment status, and geographic regions. Until the potential
impact that these variables have on performance are analyzed and used, there
is risk that the measures will inappropriately attribute poor care to
physicians and misconstrue where true improvements are needed. Information
on how the measures perform at the ACO level, the composite constructs,
attribution, weighting and other issues have not been vetted by experts
outside of AHRQ, data has not been provided for these measures currently
reported in the Medicare Shared Saving Program or Value-based Payment Modifier
nor have the measures been submitted to NQF for review. We urge the MAP to
change the recommendation to “do not support” for these measures until testing
has been completed and the measures with these results are submitted to NQF
for review. (Submitted by: American Medical Association)
- The American Academy of Ophthalmology opposes MAP’s recommendation for
this measure. We further would oppose the inclusion of this measure in federal
programs. We lack clarity around the intended use for this measure. While the
MUC listing references MIPS as the intended program, it seems that this
measure may be used as a claims-based quality measure that all MIPS
participants would be evaluated against. Such a measure would be flawed, as it
would hold EPs accountable for inpatient admissions related to conditions they
do not treat. This would also unfairly penalize EPs that treat high risk
patients with multiple chronic conditions, especially given that there appears
to be no risk adjustment outlined. (Submitted by: American Academy of
Ophthalmology)
- (Early public comment)These measures are intended to be implemented
and reported at the metropolitan area or county level (per 100,000) and have
been endorsed as such by the National Quality Forum (NQF) with the exception
of PQI 8 (Heart Failure), which is at the health plan/integrated delivery
system level. Applying measures that are intended to assess overall admission
rates at a population level to individual physicians in the MIPS program seems
imprudent; particularly, as there may be significant concerns with small
sample sizes and applicability to the various physician specialties. In
addition, PQI 91 and 92 have not been endorsed by the NQF and therefore the
composite constructs, attribution, weighting and other issues have not been
vetted by experts outside of AHRQ. We recommend that MAP does not support
these measures until additional information on how these measures would be
implemented in MIPS are provided.
While the MUC listing lists MIPS
as the intended program, it seems that this measure may be used as a
claims-based quality measure that all MIPS participants would be evaluated
against. Such a measure would be flawed, as it would hold EPs accountable for
inpatient admissions related to conditions they do not treat. This would also
unfairly penalize EPs that treat high risk patients with multiple chronic
conditions, especially given that there appears to be no risk adjustment
outlined. (Submitted by: American Medical Association)
- (Early public comment)The American Academy of Ophthalmology
encourages MAP to oppose the inclusion of this measure in federal programs. We
lack clarity around the intended use for this measure. While the MUC listing
references MIPS as the intended program, it seems that this measure may be
used as a claims-based quality measure that all MIPS participants would be
evaluated against. Such a measure would be flawed, as it would hold EPs
accountable for inpatient admissions related to conditions they do not treat.
This would also unfairly penalize EPs that treat high risk patients with
multiple chronic conditions, especially given that there appears to be no risk
adjustment outlined. (Submitted by: American Academy of
Ophthalmology)
(Program:
Medicare Shared Savings Program; MUC ID: MUC15-576) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Johns Hopkins
Armstrong Institute for Patient Safety and Quality)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- Novo Nordisk supports MAP’s recommendation for continued development of
the Prevention Quality Chronic Composite for potential adoption into the MIPS
and MSSP programs in the coming years. The measure has been developed and
validated by the Agency for Healthcare Research and Quality (AHRQ) and
addresses complications for high impact chronic conditions. Considering
patients’ needs in a holistic manner, through the use of a composite measure,
is critical. When considering a composite measure as complex as this one,
however, we caution AHRQ and MAP to ensure that the measure is actionable and
will allow for a system to use the results to make changes that result in
tangible clinical improvements. We know today that two components of the
composite measure (admissions for heart failure and chronic obstructive
pulmonary disease (COPD)) are currently included in the MSSP program.
Inclusion of the broader composite measure to address additional high impact
conditions, including diabetes, could enhance both the MSSP and MIPS programs
and support high quality care for patients with these conditions in order to
prevent unnecessary admissions. Novo Nordisk appreciates MAP’s concerns
regarding the need for risk adjustment for this measure and would support an
updated measure with appropriate risk adjustment incorporated. (Submitted by:
Novo Nordisk)
- If the PQI composites are added to MSSP, the existing unplanned admission
measures (diabetes, heart failure, multiple chronic conditions) should be
removed. The PQI composites are preferrable since they are used in the
value-modifier and all physicians who participate in an MSSP ACO are also
subject to the value modifier. Having one set of measures related to
admissions for ambulatory sensitive conditions will reduce measurement burden
for ACO participants. (Submitted by: Premier)
- The MAP’s recommendations for MUC15-576 are to encourage continued
development for use in the MSSP program. The AMA does not support this
recommendation for several reasons. First, these measures were developed to
be reported at the metropolitan area or county level (per 100,000) and still
have not been sufficiently developed and tested for use at the accountable
care organization (ACO) level. Currently, CMS modified the measure to enable
reporting at the ACO level but these changes and associated impact on the
reliability and validity of the measure have never been submitted to NQF for
review. Depending on the composition and size of the ACO, this measure may or
may not be feasible to implement in the MSSP and we are not confident that
ACOs could yield performance results that would be considered reliable and
valid. This concern regarding the reliability and validity of the measure is
further increased if these composites are applied to the individual physician
in the MIPS program. We also remain concerned that these measures may
encourage inappropriate use of resources by the ACO. If you are an ACO and
you are accountable for costs, then using measures of admissions and
readmissions is inappropriate. The ACO has a natural incentive to reduce
avoidable admissions and readmissions. In some cases, the ACO may decide the
patient should be hospitalized or readmitted because it is more efficient than
forcing them to pursue office visits or to provide home care, but the ACO
doesn't have the flexibility to do that because of a measure that declares
hospitalizations and readmissions to be bad in all cases. In addition, the
MAP rationale notes that the risk model is under development and the AMA
strongly urges CMS to address the potential sociodemographic (SDS) factors
that may play an important role in impacting an ACO’s ability to limit
admissions or readmissions. To date, the results that developers have
provided during the NQF’s SDS trial period are limited to factors such as dual
eligible status and race. CMS and its developers must look beyond the
traditional SDS factors and begin to address variables including, but not
limited to, income and education levels, employment status, and geographic
regions. Until the potential impact that these variables have on a hospital’s
performance are analyzed and used, there is risk that the measures will
inappropriately attribute poor care to ACOs and misconstrue where true
improvements are needed. Information on how the measures perform at the ACO
level, the composite constructs, attribution, weighting and other issues have
not been vetted by experts outside of AHRQ, data has not been provided for
these measures currently reported in the Medicare Shared Saving Program or
Value-based Payment Modifier nor have the measures been submitted to NQF for
review. We urge the MAP to change the recommendation to “do not support” for
these measures until testing has been completed and the measures with these
results are submitted to NQF for review. (Submitted by: American Medical
Association)
- The American Academy of Ophthalmology opposes MAP’s recommendation for
this measure. We further would oppose the inclusion of this measure in federal
programs. We lack clarity around the intended use for this measure. While the
MUC listing references MIPS as the intended program, it seems that this
measure may be used as a claims-based quality measure that all MIPS
participants would be evaluated against. Such a measure would be flawed, as it
would hold EPs accountable for inpatient admissions related to conditions they
do not treat. This would also unfairly penalize EPs that treat high risk
patients with multiple chronic conditions, especially given that there appears
to be no risk adjustment outlined. (Submitted by: American Academy of
Ophthalmology)
- (Early public comment)If the PQI composites are added to MSSP, the
existing unplanned admission measures (diabetes, heart failure, multiple
chronic conditions) should be removed. The PQI composites are preferrable
since they are used in the value-modifier and all physicians who participate
in an MSSP ACO are also subject to the value modifier. Having one set of
measures related to admissions for ambulatory sensitive conditions will reduce
measurement burden for ACO participants. (Submitted by: Premier)
- (Early public comment)All of the measures that comprise the
composite are intended to be measured at the metropolitan area of county
level, per 100,000. Depending on the composition and size of the ACO, this
measure may not be feasible to implement in the MSSP and physician practices
would most certainly never meet the minimum threshold required for the
measure. If you are an ACO and you are accountable for costs, then using
measures of admissions and readmissions is inappropriate. The ACO has a
natural incentive to reduce avoidable admissions and readmissions. In some
cases, the ACO may decide the patient should be hospitalized or readmitted
because that's more efficient than forcing them to pursue office visits or to
provide home care, but the ACO doesn't have the flexibility to do that because
of a measure that declares hospitalizations and readmissions to be bad in all
cases. In addition, information on how the measure performs at the ACO level
has not been provided for existing measures in the Medicare Shared Saving
Program or Value-based Payment Modifier nor have they been submitted to NQF
for review. We recommend that the MAP does not support these measures The AMA
would also like to highlight the following additional areas of concern with
CMS’ modified use of the measure within the MSSP. Only six of the nine
indicators from PQI 92 are included in the Chronic Ambulatory Sensitive
Condition Composite. Only PQI 8 (Heart failure) is intended to be used at the
health plan or integrated delivery system level. The rest of the measures are
intended for us at the county or city level of analysis. In addition, the full
composite is not endorsed by NQF so information on how these measures perform
at the ACO level are unknown. Currently, within MSSP, only two AHRQ PQI
measures are included in the program, which is PQI 5 (COPD and Asthma) and PQI
8 (heart failure). Currently, CMS modified the measures as follows: For the
purposes of the CMS ACO initiatives, the following modifications were made to
the original AHRQ Prevention Quality Indicator (PQI) version 4.4 technical
specifications: 1) denominator changed from general population in a geographic
area to beneficiaries assigned or aligned to a Medicare ACO including
part-year beneficiaries; 2) denominator changed from patients of any disease
status to beneficiaries with a diagnosis of COPD or Asthma; and 3) added a
denominator exclusion for beneficiaries with ESRD. To verify that these
modifications were valid, the following analyses were completed: 1) dry run
testing, 2) validity testing, 3) reliability testing, 4) variability testing
and 5) exclusion testing. However, results from the analyses could not be
found. The AMA did look at testing related to PQI 5 and 8 that was submitted
for NQF maintenance, which is part of PQI 92. The testing form for PQI 5 is
currently blank. It appears for PQI 8, no new testing was submitted; rather
the testing from the previous endorsement maintenance review in 2010 is
provided. This is consistent with the update NQF maintenance process where
developers do not need to provide updated info if the measure has not changed.
However, there still are a few issues with the testing provided. 1st, the info
is not sufficiently detailed to indicate whether the testing was performed at
an ACO level or whether it was completed at the county/city level. Second, the
c-statistic for the risk-adjustment is not reported. Also the performance
scores provided in the submissions are reported at the regional level. Thus,
no info on how the measure performs at the health plan, integrated delivery
system or ACO are provided. (Submitted by: American Medical
Association)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program: Merit-Based Incentive Payment
System (MIPS); MUC ID: MUC15-577) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- This measure includes admissions with a principal diagnosis of one of the
following conditions: dehydration, bacterial pneumonia, or urinary tract
infection. It encourages appropriate care of acute conditions in the
ambulatory setting to avoid hospitalization which is highly desirable for
patients and families. This measure has been well vetted and is already used
in the Physician Value Based Payment Modifier and we believe it is appropriate
for use in other programs at this time. (Submitted by:
Medtronic)
- PQI 91: Prevention Quality Acute Composite and PQI 92: Prevention Quality
Chronic Composite The MAP draft report references two composite measures under
consideration, MUC 15-577 and MUC 15-576 (PQI 91: Prevention Quality Acute
Composite and PQI 92: Prevention Quality Chronic Composite, respectively) that
were discussed extensively. The AAMC has significant concerns with the use of
these measures in the MIPS program and the shared savings ACO program. The
Association was pleased to see that the MAP discussed the limitations and
potential unintended consequences of these measures, noting the impact that
socio-demographic factors may have on the outcomes addressed by these
measures, and the fact that these measures were designed for use at the
“population level,” not the “clinician level.” The PQIs were originally
designed to measure ambulatory sensitive conditions at a community level and
the rate calculated per 100,000 population. Such a large sample size allows
communities to evaluate their primary care system at a macro level. These
measures were not tested or endorsed by NQF for use at the clinician level,
where the population is much smaller. If implemented in the MIPS program, it
is possible that physician practices with only 20 attributed patients could be
held accountable for performance under this measure. We have major concerns
with applying measures that are intended to address overall admission rates at
a population level to individual physicians in the MIPS program and to ACOs
that have much smaller populations than 100,000. These measures would also
penalize physicians that treat complex patients with multiple chronic
conditions given that there is no appropriate clinical risk adjustment. The
characteristics of the attributed Medicare beneficiaries can vary widely by
physician group practice. Not accounting for the clinical variation in the
underlying population is extremely misleading and disproportionately affects
the physicians who care for the most complex patients. These measures should
have appropriate clinical risk adjustment prior to implementation in any
program. In addition, as admissions and readmissions are often connected to
the broader community, CMS should consider adding an adjustment or
stratification to account for socio-demographic factors. Despite these
challenges with the measure, CMS is currently using these PSI measures under
the physician value-based modifier program. In the 2015 Value Modifier
Experience Report, groups in the low-quality and/or high-cost categories had
worse performance on these measures. These cohorts tended to have patients
with a higher risk score, and therefore this group is unfairly penalized under
the current value-based modifier program. The use of this measure at the ACO
level also would have similar challenges with population size and risk
adjustment. An ACO patient population is typically much smaller than 100,000.
In addition, an ACO is already accountable for costs and has an incentive to
reduce admissions and readmissions. Therefore, use of an additional measure
involving admissions and readmissions would be duplicative and inappropriate.
We recommend that the issues related to risk adjustment, sociodemographic
factors, and attribution be addressed and that these measures be endorsed by
NQF prior to implementation in the MIPS program or the shared savings ACO
program. (Submitted by: Association of American Medical Colleges)
- The MAP’s recommendations for MUC15-577 are to encourage continued
development for use in the MIPS program. The AMA does not support this
recommendation for several reasons. First, these measures were developed to
be reported at the metropolitan area or county level (per 100,000) and still
have not been sufficiently developed and tested for use at the individual
physician level. Currently, CMS modified the measure to enable reporting at
the ACO level but these changes and associated impact on the reliability and
validity of the measure have never been submitted to NQF for review.
Depending on the composition and size of the physician’s practice, this
measure will very likely be found to be infeasible to implement in the MIPS
and we are not confident that data at the individual physician level could
yield performance results that would be considered reliable and valid due to
small sample sizes and the lack of applicability to a broad number of
specialties. We also are concerned that these measures may encourage
inappropriate uses of resources by the physician. In addition, and perhaps
more importantly, it assumes that the physician is the final arbiter and
decision-maker for a patient’s admission or readmission. There are many
individuals and entities involved in a patient’s care and it would seem
imprudent to attribute sole responsibility to an individual physician. In
addition, the MAP rationale notes that the risk model is under development and
the AMA strongly urges CMS to address the potential sociodemographic (SDS)
factors that may play an important role in impacting an ACO’s ability to limit
admissions or readmissions. To date, the results that developers have
provided during the NQF’s SDS trial period are limited to factors such as dual
eligible status and race. CMS and its developers must look beyond the
traditional SDS factors and begin to address variables including, but not
limited to, employment status, and geographic regions. Until the potential
impact that these variables have on performance are analyzed and used, there
is risk that the measures will inappropriately attribute poor care to
physicians and misconstrue where true improvements are needed. Information
on how the measures perform at the ACO level, the composite constructs,
attribution, weighting and other issues have not been vetted by experts
outside of AHRQ, data has not been provided for these measures currently
reported in the Medicare Shared Saving Program or Value-based Payment Modifier
nor have the measures been submitted to NQF for review. We urge the MAP to
change the recommendation to “do not support” for these measures until testing
has been completed and the measures with these results are submitted to NQF
for review. (Submitted by: American Medical Association)
- The American Academy of Ophthalmology opposes MAP’s recommendation for
this measure. We further would oppose the inclusion of this measure in federal
programs. We lack clarity around the intended use for this measure. While the
MUC listing references MIPS as the intended program, it seems that this
measure may be used as a claims-based quality measure that all MIPS
participants would be evaluated against. Such a measure would be flawed, as it
would hold EPs accountable for inpatient admissions related to conditions they
do not treat. This would also unfairly penalize EPs that treat high risk
patients with multiple chronic conditions, especially given that there appears
to be no risk adjustment outlined. (Submitted by: American Academy of
Ophthalmology)
- (Early public comment)These measures are intended to be implemented
and reported at the metropolitan area or county level (per 100,000) and have
been endorsed as such by the National Quality Forum (NQF) with the exception
of PQI 8 (Heart Failure), which is at the health plan/integrated delivery
system level. Applying measures that are intended to assess overall admission
rates at a population level to individual physicians in the MIPS program seems
imprudent; particularly, as there may be significant concerns with small
sample sizes and applicability to the various physician specialties. In
addition, PQI 91 and 92 have not been endorsed by the NQF and therefore the
composite constructs, attribution, weighting and other issues have not been
vetted by experts outside of AHRQ. We recommend that MAP does not support
these measures until additional information on how these measures would be
implemented in MIPS are provided and the measure with this information
submitted to NQF for review.
While the MUC listing lists MIPS as the intended program, it seems that this
measure may be used as a claims-based quality measure that all MIPS
participants would be evaluated against. Such a measure would be flawed, as it
would hold EPs accountable for inpatient admissions related to conditions they
do not treat. This would also unfairly penalize EPs that treat high risk
patients with multiple chronic conditions, especially given that there appears
to be no risk adjustment outlined. (Submitted by: American Medical
Association)
- (Early public comment)These measures are intended to be implemented
and reported at the metropolitan area or county level (per 100,000) and have
been endorsed as such by the National Quality Forum (NQF) with the exception
of PQI 8 (Heart Failure), which is at the health plan/integrated delivery
system level. Applying measures that are intended to assess overall admission
rates at a population level to individual physicians in the MIPS program seems
imprudent; particularly, as there may be significant concerns with small
sample sizes and applicability to the various physician specialties. In
addition, PQI 91 and 92 have not been endorsed by the NQF and therefore the
composite constructs, attribution, weighting and other issues have not been
vetted by experts outside of AHRQ. We recommend that MAP does not support
these measures until additional information on how these measures would be
implemented in MIPS are provided. While the MUC listing lists MIPS as the
intended program, it seems that this measure may be used as a claims-based
quality measure that all MIPS participants would be evaluated against. Such a
measure would be flawed, as it would hold EPs accountable for inpatient
admissions related to conditions they do not treat. This would also unfairly
penalize EPs that treat high risk patients with multiple chronic conditions,
especially given that there appears to be no risk adjustment outlined.
(Submitted by: American Medical Association)
- (Early public comment)The American Academy of Ophthalmology
encourages MAP to oppose the inclusion of this measure in federal programs. We
lack clarity around the intended use for this measure. While the MUC listing
references MIPS as the intended program, it seems that this measure may be
used as a claims-based quality measure that all MIPS participants would be
evaluated against. Such a measure would be flawed, as it would hold EPs
accountable for inpatient admissions related to conditions they do not treat.
This would also unfairly penalize EPs that treat high risk patients with
multiple chronic conditions, especially given that there appears to be no risk
adjustment outlined. (Submitted by: American Academy of
Ophthalmology)
(Program: Medicare Shared Savings Program;
MUC ID: MUC15-577) |
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Johns Hopkins
Armstrong Institute for Patient Safety and Quality)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- If the PQI composites are added to MSSP, the existing unplanned admission
measures (diabetes, heart failure, multiple chronic conditions) should be
removed. The PQI composites are preferrable since they are used in the
value-modifier and all physicians who participate in an MSSP ACO are also
subject to the value modifier. Having one set of measures related to
admissions for ambulatory sensitive conditions will reduce measurement burden
for ACO participants. (Submitted by: Premier)
- The MAP’s recommendations for MUC15-577 are to encourage continued
development for use in the MSSP program. The AMA does not support this
recommendation for several reasons. First, these measures were developed to
be reported at the metropolitan area or county level (per 100,000) and still
have not been sufficiently developed and tested for use at the accountable
care organization (ACO) level. Currently, CMS modified the measure to enable
reporting at the ACO level but these changes and associated impact on the
reliability and validity of the measure have never been submitted to NQF for
review. Depending on the composition and size of the ACO, this measure may or
may not be feasible to implement in the MSSP and we are not confident that
ACOs could yield performance results that would be considered reliable and
valid. This concern regarding the reliability and validity of the measure is
further increased if these composites are applied to the individual physician
in the MIPS program. We also remain concerned that these measures may
encourage inappropriate use of resources by the ACO. If you are an ACO and
you are accountable for costs, then using measures of admissions and
readmissions is inappropriate. The ACO has a natural incentive to reduce
avoidable admissions and readmissions. In some cases, the ACO may decide the
patient should be hospitalized or readmitted because it is more efficient than
forcing them to pursue office visits or to provide home care, but the ACO
doesn't have the flexibility to do that because of a measure that declares
hospitalizations and readmissions to be bad in all cases. In addition, the
MAP rationale notes that the risk model is under development and the AMA
strongly urges CMS to address the potential sociodemographic (SDS) factors
that may play an important role in impacting an ACO’s ability to limit
admissions or readmissions. To date, the results that developers have
provided during the NQF’s SDS trial period are limited to factors such as dual
eligible status and race. CMS and its developers must look beyond the
traditional SDS factors and begin to address variables including, but not
limited to, income and education levels, employment status, and geographic
regions. Until the potential impact that these variables have on a hospital’s
performance are analyzed and used, there is risk that the measures will
inappropriately attribute poor care to ACOs and misconstrue where true
improvements are needed. Information on how the measures perform at the ACO
level, the composite constructs, attribution, weighting and other issues have
not been vetted by experts outside of AHRQ, data has not been provided for
these measures currently reported in the Medicare Shared Saving Program or
Value-based Payment Modifier nor have the measures been submitted to NQF for
review. We urge the MAP to change the recommendation to “do not support” for
these measures until testing has been completed and the measures with these
results are submitted to NQF for review. (Submitted by: American Medical
Association)
- (Early public comment)If the PQI composites are added to MSSP, the
existing unplanned admission measures (diabetes, heart failure, multiple
chronic conditions) should be removed. The PQI composites are preferrable
since they are used in the value-modifier and all physicians who participate
in an MSSP ACO are also subject to the value modifier. Having one set of
measures related to admissions for ambulatory sensitive conditions will reduce
measurement burden for ACO participants. (Submitted by: Premier)
- (Early public comment)All of the measures that comprise the
composite are intended to be measured at the metropolitan area of county
level, per 100,000. Depending on the composition and size of the ACO, this
measure may not be feasible to implement in the MSSP and physician practices
would most certainly never meet the minimum threshold required for the
measure. If you are an ACO and you are accountable for costs, then using
measures of admissions and readmissions is inappropriate. The ACO has a
natural incentive to reduce avoidable admissions and readmissions. In some
cases, the ACO may decide the patient should be hospitalized or readmitted
because that's more efficient than forcing them to pursue office visits or to
provide home care, but the ACO doesn't have the flexibility to do that because
of a measure that declares hospitalizations and readmissions to be bad in all
cases. In addition, information on how the measure performs at the ACO level
has not been provided for existing measures in the Medicare Shared Saving
Program or Value-based Payment Modifier nor have they been submitted to NQF
for review. We recommend that the MAP does not support these measures The AMA
would also like to highlight the following additional areas of concern with
CMS’ modified use of the measure within the MSSP. All of the indicators
included in PQI 91 (Acute) are endorsed by NQF at the county or city level of
analysis. Two of the indicators are not endorsed by NQF. Of the seven that are
endorsed, all but one is intended to be reported at the county or city level
of analysis. In addition, the full composite is not endorsed by NQF so
information on how these measures perform at an ACO level is unknown.
Currently, within MSSP, only two AHRQ PQI measures are included in the
program, which is PQI 5 (COPD and Asthma) and PQI 8 (heart failure).
Currently, CMS modified the measures as follows: For the purposes of the CMS
ACO initiatives, the following modifications were made to the original AHRQ
Prevention Quality Indicator (PQI) version 4.4 technical specifications: 1)
denominator changed from general population in a geographic area to
beneficiaries assigned or aligned to a Medicare ACO including part-year
beneficiaries; 2) denominator changed from patients of any disease status to
beneficiaries with a diagnosis of COPD or Asthma; and 3) added a denominator
exclusion for beneficiaries with ESRD. To verify that these modifications
were valid, the following analyses were completed: 1) dry run testing, 2)
validity testing, 3) reliability testing, 4) variability testing and 5)
exclusion testing. However, results from the analyses could not be found. The
AMA did look at testing related to PQI 5 and 8 that was submitted for NQF
maintenance, which is part of PQI 92. The testing form for PQI 5 is currently
blank. It appears for PQI 8, no new testing was submitted; rather the testing
from the previous endorsement maintenance review in 2010 is provided. This is
consistent with the update NQF maintenance process where developers do not
need to provide updated info if the measure has not changed. However, there
still are a few issues with the testing provided. 1st, the info is not
sufficiently detailed to indicate whether the testing was performed at an ACO
level or whether it was completed at the county/city level. Second, the
c-statistic for the risk-adjustment is not reported. Also the performance
scores provided in the submissions are reported at the regional level. Thus,
no info on how the measure performs at the health plan, integrated delivery
system or ACO are provided. (Submitted by: American Medical
Association)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program: Medicare Shared Savings Program; MUC ID: MUC15-578)
|
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Johns Hopkins
Armstrong Institute for Patient Safety and Quality)
- CAPC supports the MAP’s recommendation “Support” for the inclusion of
MUC15-578 in the Medicare Shared Savings Program (MSSP). This measure is
currently in use in the Physician Quality Reporting System (and eventually
likely the Merit-based Incentive Payment System) and inclusion in the MSSP
will allow for greater harmonization in measuring this quality gap area across
programs. While we acknowledge there are significant limitations to MUC15-578,
not the least of which being that this checkbox measure does not necessarily
indicate that providers have had a meaningful goals of care conversation with
patients and their families/caregivers, this is nonetheless an important
starting point while the field continues to develop new measures.
Additionally, with the introduction of a new payment structure for the MSSP,
this is an excellent time to research the completion of advance care plans and
examine how they are incorporated into the overall care of the patient.
(Submitted by: Center to Advance Palliative Care)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The Carolinas Center agrees with MAP on the support of this measure. We
encourage the expansion of this measure in two ways. One, this measure should
be for any Medicare beneficiary with an advanced illness regardless of age.
Two, we suggest expanding this measure to other provider types across the
continuum of care. Now that Advance Care Planning codes have been added to the
Physician Fee Schedule there should be an increase in the documentation of
these discussions. (Submitted by: The Carolinas Center)
- Adds value to the program and addresses an important topic. Additionally,
with payment for the CPT codes for advance care planning going into effect in
2016 this measure may become less burdensome with decreased need for medical
record review as CPT code use increases. (Submitted by: Premier)
- NPHI supports this measure as an appropriate method to stimulate providers
to expand and improve advance care planning. Given the limited scope of
patients treated by MSSP providers who would most benefit from an advance care
plan, the effect of this measure may be limited. NPHI encourages broader
application of this measure beyond MSSP to address the need for advance care
planning more broadly throughout patient’s care to promote greater awareness,
continuity, and coordination throughout the continuum of care. (Submitted by:
National Parternship for Hospice Innovation (NPHI))
- While documentation of ACP discussion with patients or surrogates is a
necessary process measure, this measure, by itself, does not address the more
patient-centric outcome of being able to evaluate whether or not the providers
understood the patient's health care values or how well was the adherence to
the patient's wishes. (The image comes to mind of a physician typing into the
EHR system while never looking or directly addressing the patient.) (Submitted
by: American Medical Group Association - KF)
- AAPM&R commends NQF for evolving its work to understand how measures
are being developed and implemented across settings and how they impact
payment reform. This is a huge endeavor that AAPM&R stands behind in
concept. However, AAPM&R cautions NQF to ensure their processes and
review of measures are adequately reported back to CMS and other rule-making
entities to ensure the NQF’s measurement expertise is realized in rule making.
AAPM&R agrees with this measure. However, AAPM&R would suggest the
age limit to be removed from the denominator to expand the measure to reach a
broader population. Keeping the denominator as is makes this a Medicare only
population measure, which is highly restrictive in terms of measuring
outcomes. (Submitted by: American Academy of Physical Medicine and
Rehabilitation )
- As submitted in previous comments, we believe this measure is a good
starting point to promoting advance care planning, a necessary component to
quality care. We recommend that this measure be added to the quality programs
of other provider types and, eventually, be expanded to include measures
assessing provider compliance with patient’s advance directive. Consideration
should also be given in the future to including in the measure assessment of
whether providers inform patients of the availability of advance care planning
discussions, and provide referral in cases where the patient indicates an
interest, if not directly having the discussion. This would be an especially
appropriate measure for all physicians considering the fact that two new
physician billing codes for advance care planning were added to the Physician
Fee Schedule in 2016 (Submitted by: National Association for Home &
Hospice Care)
- As submitted in previous comments, this measure for MSSP is a good
starting point to promoting advance care planning, a necessary component to
quality care. We recommend that this measure be added to the quality programs
of other provider types and, eventually, be expanded to include measures
assessing provider compliance with patient’s advance directive. (Submitted by:
The Home Care & Hospice Association of New Jersey)
- As submitted in previous comments, this measure for MSSP is a good
starting point to promoting advance care planning, a necessary component to
quality care. We recommend that this measure be added to the quality programs
of other provider types and, eventually, be expanded to include measures
assessing provider compliance with patient’s advance directive. (Submitted by:
Ohio Council for HOme Care & Hospice)
- We support adding this measure to the Medicare Shared Savings Program, but
would recommend taking the age limit off the denominator so that it includes
all adults/18 years or older (rather than all patients aged 65 years and
older). This measure is currently in use in the Physician Quality Reporting
System (and eventually likely the Merit-based Incentive Payment System) and
inclusion in the MSSP will allow for greater harmonization in measuring this
quality gap area across programs. (Submitted by: American Academy of Hospice
and Palliative Medicine)
- (Early public comment)The measure is appropriate and it will
stimulate the targeted providers (those influenced by MIPS and MSSP) to expand
and improve their advance care planning efforts. However, only some 400
organizations are part of the MSSP; broader application of this measure to
essentially all hospitals would address a great national need that extends far
beyond MSSP participant organizations. (Submitted by: The Coalition to
Transform Advanced Illness)
- (Early public comment)Adds value to the program and addresses an
important topic. Additionally, with payment for the CPT codes for advance care
planning going into effect in 2016 this measure may become less burdensome
with decreased need for medical record review as CPT code use increases.
(Submitted by: Premier)
- (Early public comment)This measure for MSSP is a good starting
point to promoting advance care planning, a necessary component to quality
care. We recommend that this measure be added to the quality programs of
other provider types and, eventually, be expanded to include measures
assessing provider compliance with patient’s advance directive. Consideration
should also be given in the future to including in the measure assessment of
whether providers inform patients of the availability of advance care planning
discussions, and provide referral in cases where the patient indicates an
interest, if not directly having the discussion. This would be an especially
appropriate measure for all physicians considering the fact that two new
physician billing codes for advance care planning were added to the Physician
Fee Schedule in 2016. (Submitted by: National Association for Home Care &
Hospice (NAHC))
- (Early public comment)This measure for MSSP is a good starting
point to promoting advance care planning, a necessary component to quality
care. We recommend that this measure be added to the quality programs of
other provider types and, eventually, be expanded to include measures
assessing provider compliance with patient’s advance directive. (Submitted by:
The Home Care & Hospice Association of New Jersey)
- (Early public comment)This measure for MSSP is a good starting
point to promoting advance care planning, a necessary component to quality
care. We recommend that this measure be added to the quality programs of
other provider types and, eventually, be expanded to include measures
assessing provider compliance with patient’s advance directive. (Submitted by:
Ohio Council for Home Care & Hospice)
(Program: Medicare Shared Savings Program; MUC ID: MUC15-579)
|
- We support the rationale for this measure, but have concerns that the data
collection and medical record review could be a barrier to timely and accurate
reporting. (Submitted by: Johns Hopkins Armstrong Institute for Patient
Safety and Quality)
- CAPC supports the MAP’s recommendation “Support” for the inclusion of
MUC15-579 in the Medicare Shared Savings Program (MSSP). This measure is
currently in use in the Physician Quality Reporting System (and eventually
likely the Merit-based Incentive Payment System) and the Meaningful Use
program, and inclusion in the MSSP will allow for greater harmonization in
measuring this quality gap area across programs. Falls and fall risk are
important indicators of the need for palliative care in older adults, as they
often signal an increase in functional decline; yet patients over the age of
65 are not universally screened for either. In addition to incorporating this
measure into the standard MSSP settings, we encourage CMS and NQF to explore
how this measure might be expanded for use in home-based programs. (Submitted
by: Center to Advance Palliative Care)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The measure's first two rates are reasonable. The third "Plan of Care for
Falls" is problematic. Rather than leading to improved interventions to
reduce falls, the third rate will increase the length and complexity of our
currently used "care plans" or "after-visit summaries." Most care plans today
are still mired in the paper chase world of static documents that lack patient
centricity or the flexibility to adapt to varied patient, family and care team
capacities. The third rate should be deferred for further consideration and
re-proposal (Submitted by: American Medical Group Association -
KF)
- Falls are the leading cause of injury-related morbidity and mortality
among older adults. Falls result in physical injury, including high rates of
orthopedic and ocular injury, directly cause costly disability, and often
increase hospital readmissions. In addition, important psychological
consequences occur as a result of a fall, including depression, anxiety,
activity restriction, and fear of falling. There is a plethora of evidence
indicating that impaired vision is highly associated with and is an important
risk factor of falls. Importantly, reduced visual acuity, as currently
screened for, is not adequate to establish a falls risk associated with vision
problems. A comprehensive eye exam is needed to fully assess known
contributing factors to falls, including but not limited to, reduced contrast
sensitivity, poor stereopsis and visual field loss (e.g. especially in the
lower visual field) cataract, ptosis, and color vision deficiencies.
Comprehensive eye examination can also identify other changes in the eye that
can hinder daily function. As an example, a measured increase in sensitivity
to glare and sunlight known to decrease binocularity and can be measured and
subsequently compensated through optical correction (Submitted by: American
Optometric Association)
- (Early public comment)If added to MSSP this measure should replace
the existing falls risk measure. This measure is preferrable as it goes beyond
screening and requires a plan of care for beneficiaries at risk for falls.
(Submitted by: Premier)
- (Early public comment)Falls are the leading cause of injury-related
morbidity and mortality among older adults. Falls result in physical injury,
including high rates of orthopedic and ocular injury, directly cause costly
disability, and often increase hospital readmissions. In addition, important
psychological consequences occur as a result of a fall, including depression,
anxiety, activity restriction, and fear of falling. There is a plethora of
evidence indicating that impaired vision is highly associated with and is an
important risk factor of falls. Importantly, reduced visual acuity, as
currently screened for, is not adequate to establish a falls risk associated
with vision problems. A comprehensive eye exam is needed to fully assess known
contributing factors to falls, including but not limited to, reduced contrast
sensitivity, poor stereopsis and visual field loss (e.g. especially in the
lower visual field) cataract, ptosis, and color vision deficiencies.
Comprehensive eye examination can also identify other changes in the eye that
can hinder daily function. As an example, a measured increase in sensitivity
to glare and sunlight known to decrease binocularity and can be measured and
subsequently compensated through optical correction. (Submitted by: America
Optometric Association)
(Program: Hospital Acquired Condition
Reduction Program; MUC ID: MUC15-604) |
- We support the changes in version 6.0 which was recently endorsed by NQF.
The measure should replace the current measure in IQR. (Submitted by:
Premier)
- Thank you for opportunity to comment upon the changes proposed to PSI 90
(NQF #0531). We continue to be concerned about the use of claims data to
determine patient safety events. The claims-based components that make up the
PSI 90 measure use administrative data rather than clinical indicators. The
Centers for Medicare and Medicaid Services (CMS) has recognized this point by
decreasing the weight of the PSI 90 measure within the Hospital Acquired
Condition Reduction Program (HACRP) and the HVBP Program. For this reason, we
believe there is a substantial need for better measures of patient harm that
directly reflect clinical data. We are particularly interested in the
development of automated clinical indicators of patient harm drawn directly
from Health Information Technology (Health IT) data. However, until such
measures can be implemented on a nationwide scale, we believe that CMS should
use this updated and NQF-endorsed version of the PSI 90 measure in favor of
the previous version. As a point of consideration, we think that the NQF
should continue its work to ensure patient safety indicators are always
reflective of actual patient safety events that resulted in preventable
patient harm. The NQF should also continue to prioritize the most precise
measures such as the related National Healthcare Safety Network (NHSN) measure
of central line related blood stream infections. In addition, the NQF must
strive for greater simplicity in measure development. Composite measures,
such as PSI 90, require considerable statistical manipulation to come to an
index from which comparisons can be made. There is not much explanation of
what is gained or lost in such manipulations. According to the Agency for
Healthcare Research and Quality’s (AHRQ) PSI Composite Measure Workgroup
Report published in March 2008, there are several drawbacks to composite
measures: 1) they “can mask important differences and relations among
components,” 2) they “may not be actionable,” 3) composites can make it
“difficult to know which parts of the health care system contribute most to
quality,” 4) they “might not reflect the evidence base of the component
indicators.” We believe that the decision to remove PSI 07 because a related
NHSN measure was determined to be more valuable supports these concerns. It is
much more meaningful for consumers, when choosing providers, if safety metrics
are clear and actionable. The same is true for providers seeking to improve
the quality of care. Patient safety metrics should elucidate exactly what
interventions are connected and important. We think that grouping individual
measures demands even greater scrutiny of the statistical science behind the
weightings and risk-adjustment to ensure credibility, validity and
reliability. (Submitted by: Adventist Health System)
- We support the changes in version 6.0 which was recently endorsed by NQF.
The measure should replace the current measure in IQR. After gaining
experience in IQR the measure should then be added to the other payment
programs (HACRP, HVBP). (Submitted by: Premier)
- Patient Safety and Adverse Events Composite (PSI-90) The Hospital MAP
Workgroup supported a revised patient safety and adverse events composite
measure (PSI-90) for future inclusion in the IQR and HACRP programs. As of
December 2015, the revised composite measure had not been formally reviewed by
the NQF Board of Directors. While the AAMC appreciates that the PSI-90 measure
has undergone initial improvements, we continue to have serious concerns with
the underlying structure of this composite measure. As noted by Hospital MAP
Workgroup members, the Medicare Payment Advisory Commission (MedPAC) , and
other academic researchers , the measure components contain serious
deficiencies. The measures as currently specified may not be preventable
through evidence based practices, lack the statistical reliability of the
Centers for Disease Control (CDC) National Healthcare Safety Network (NHSN)
measures, are susceptible to surveillance bias, and are based on
administrative claims data and therefore cannot capture the full scope of
patient-level risk factors. In addition, teaching hospitals are more likely to
be penalized by this measure because they treat a more complex and vulnerable
patient population. Since PSI-90 components focus on surgical issues, teaching
hospitals are more likely to be disproportionately impacted by this measure
because they tend to have a larger volume of surgeries. For all of the
reasons noted above, the AAMC strongly supports the removal of the PSI-90
composite from both the HACRP and VBP programs. The Association remains
unconvinced that the updates to the PSI components and weights are sufficient
to address these considerable measure deficiencies. Until a revised PSI
measure has been shown to meet an acceptable level of validity, is actionable,
and has been sufficiently publicly reported, it should not be considered for
inclusion in a Medicare performance program. (Submitted by: Association of
American Medical Colleges )
- While the AHA believes this new version of PSI-90 is an improvement over
the existing measure, it continues to fall well short of the standard needed
for use in public accountability applications. We urge CMS to phase PSI-90 out
of its programs altogether. We have long been concerned by the significant
limitations of PSI 90 as a quality measure. PSIs use hospital claims data to
identify patients that have potentially experienced a safety event. However,
claims data cannot and do not fully reflect the details of a patient’s
history, course of care and clinical risk factors. As a result, as shown in a
CMS-commissioned analysis from 2012, the rates derived from the component
measures are highly inexact. PSI data may assist hospitals in identifying
patients whose particular cases merit deeper investigation with the benefit of
the full medical record. But, the measures are poorly suited to drawing
meaningful conclusions about hospital performance on safety issues. In other
words, PSI 90 may help hospitals determine what “haystack” to look in for
potential safety issues. But the ability of the measure to consistently and
accurately identify the “needle” (i.e., the safety event) is far too suspect
to deem it worthy of NQF endorsement, let alone use in public reporting and
pay-for-performance applications. (Submitted by: American Hospital Association
(AHA))
- Patient safety and adverse events are critical areas to measure and drive
improvement. However, little is known about how the measure’s changes and
refinements will alter hospital performance. We request that absolute and
relative performance changes be reviewed and understood prior to using this
measure in replacement of its predecessor. (Submitted by: Children's
Hospital Association)
- FAH opposes the inclusion of this measure. Given the changes made to the
composite, we do not yet know how a hospital's performance will shift when
used in this program nor do we believe that these population-based measures
are appropriate for hospital accountability. The potential differences in
performance and ranking should be explored and education should be provided
before it is implemented in the program. (Submitted by: Federation of
American Hospitals)
- The ACS does not support the Patient Safety and Adverse Events Composite
for inclusion in HACRP or HVBP. ACS has concerns with PSI-15, a measure
included in the patient safety and adverse events composite (AHRQ PSI-90). We
continue to receive questions from ACS members expressing confusion regarding
coding for PSI-15, which is a highly weighted component of the AHRQ PSI-90
composite. In the past when we have expressed this concern, CMS has reference
to the American Hospital Association Coding Clinic guidance on PSI-15, but we
believe that coding for accidental puncture is still non-uniform due to lack
of clarity as to what constitutes an “accident.” Often punctures or
lacerations are incorrectly coded as “accidental” when the puncture or
laceration was part of the surgery. Measures that have questionable
reliability and validity should not be weighted so heavily. We request that
CMS provide more precise guidance regarding the correct coding of PSI-15.
(Submitted by: American College of Surgeons)
- (Early public comment)We support the changes in version 6.0 which
was recently endorsed by NQF. The measure should replace the current measure
in IQR. After gaining experience in IQR the measure should then be added to
the other payment programs (HACRP, HVBP). (Submitted by: Premier)
- (Early public comment)We support inclusion of this NQF-endorsed
measure for consideration under the full range of CMS quality programs,
including HVBP, HIQR, and HACRP. As noted in CMS’ Measure Rationale, each
measure in PSI 90 is an outcome measure that has been shown to be largely
preventable through improved structures and processes of care: each measure
has an evidence review form as part of the NQF endorsement process; and the
literature to support each measure is updated on a schedule basis. Last year,
CMS indicated they were reassessing inclusion of PSI 90 as a quality measure
and would be basing their recommendation after re-review by AHRQ. This
measure was reassessed by AHRQ this year and received continued endorsement,
and was the recipient of multiple public comments. The public and AHRQ
endorsement of this composite measure, which is composed of individual quality
measures that are widely preventable with appropriate clinical safety and
surveillance measures, supports the value of this measure and its utility in a
range of CMS hospital quality reporting and pay-for-performance programs.
(Submitted by: AdvaMed)
- (Early public comment)The American College of Obstetricians and
Gynecologists supports this measure. (Submitted by: American College of
Obstetricians and Gynecologists)
(Program: Hospital Inpatient Quality
Reporting and EHR Incentive Program; MUC ID: MUC15-604) |
- We agree with MAP's support of this measure. (Submitted by:
Medtronic)
- Patient safety and adverse events are critical areas to measure and drive
improvement. However, little is known about how the measure’s changes and
refinements will alter hospital performance. We request that absolute and
relative performance changes be reviewed and understood prior to using this
measure in replacement of its predecessor. However, we believe implementing
it first in HIQR is a starting point. (Submitted by: Children's Hospital
Association)
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Society of
Hospital Medicine)
- Thank you for opportunity to comment upon the changes proposed to PSI 90
(NQF #0531). We continue to be concerned about the use of claims data to
determine patient safety events. The claims-based components that make up the
PSI 90 measure use administrative data rather than clinical indicators. The
Centers for Medicare and Medicaid Services (CMS) has recognized this point by
decreasing the weight of the PSI 90 measure within the Hospital Acquired
Condition Reduction Program (HACRP) and the HVBP Program. For this reason, we
believe there is a substantial need for better measures of patient harm that
directly reflect clinical data. We are particularly interested in the
development of automated clinical indicators of patient harm drawn directly
from Health Information Technology (Health IT) data. However, until such
measures can be implemented on a nationwide scale, we believe that CMS should
use this updated and NQF-endorsed version of the PSI 90 measure in favor of
the previous version. As a point of consideration, we think that the NQF
should continue its work to ensure patient safety indicators are always
reflective of actual patient safety events that resulted in preventable
patient harm. The NQF should also continue to prioritize the most precise
measures such as the related National Healthcare Safety Network (NHSN) measure
of central line related blood stream infections. In addition, the NQF must
strive for greater simplicity in measure development. Composite measures,
such as PSI 90, require considerable statistical manipulation to come to an
index from which comparisons can be made. There is not much explanation of
what is gained or lost in such manipulations. According to the Agency for
Healthcare Research and Quality’s (AHRQ) PSI Composite Measure Workgroup
Report published in March 2008, there are several drawbacks to composite
measures: 1) they “can mask important differences and relations among
components,” 2) they “may not be actionable,” 3) composites can make it
“difficult to know which parts of the health care system contribute most to
quality,” 4) they “might not reflect the evidence base of the component
indicators.” We believe that the decision to remove PSI 07 because a related
NHSN measure was determined to be more valuable supports these concerns. It is
much more meaningful for consumers, when choosing providers, if safety metrics
are clear and actionable. The same is true for providers seeking to improve
the quality of care. Patient safety metrics should elucidate exactly what
interventions are connected and important. We think that grouping individual
measures demands even greater scrutiny of the statistical science behind the
weightings and risk-adjustment to ensure credibility, validity and
reliability. (Submitted by: Adventist Health System)
- While the AHA believes this new version of PSI-90 is an improvement over
the existing measure, it continues to fall well short of the standard needed
for use in public accountability applications. We urge CMS to phase PSI-90 out
of its programs altogether. We have long been concerned by the significant
limitations of PSI 90 as a quality measure. PSIs use hospital claims data to
identify patients that have potentially experienced a safety event. However,
claims data cannot and do not fully reflect the details of a patient’s
history, course of care and clinical risk factors. As a result, as shown in a
CMS-commissioned analysis from 2012, the rates derived from the component
measures are highly inexact. PSI data may assist hospitals in identifying
patients whose particular cases merit deeper investigation with the benefit of
the full medical record. But, the measures are poorly suited to drawing
meaningful conclusions about hospital performance on safety issues. In other
words, PSI 90 may help hospitals determine what “haystack” to look in for
potential safety issues. But the ability of the measure to consistently and
accurately identify the “needle” (i.e., the safety event) is far too suspect
to deem it worthy of NQF endorsement, let alone use in public reporting and
pay-for-performance applications. (Submitted by: American Hospital Association
(AHA))
- The ACS conditionally supports the patient safety and adverse events
composite. However, ACS has concerns with PSI-15, a measure included in the
patient safety and adverse events composite (AHRQ PSI-90). We continue to
receive questions from ACS members expressing confusion regarding coding for
PSI-15, which is a highly weighted component of the AHRQ PSI-90 composite.
In the past when we have expressed this concern, CMS has reference to the
American Hospital Association Coding Clinic guidance on PSI-15, but we
believe that coding for accidental puncture is still non-uniform due to lack
of clarity as to what constitutes an “accident.” Often punctures or
lacerations are incorrectly coded as “accidental” when the puncture or
laceration was part of the surgery. Measures that have questionable
reliability and validity should not be weighted so heavily. We request that
CMS provide more precise guidance regarding the correct coding of PSI-15.
(Submitted by: American College of Surgeons)
- (Early public comment)ASPS is pleased to see meaningful and
relevant measures for plastic surgeons in the MIPS program. Going forward,
ASPS wishes to continue to see more relevant measures for specialties and
surgical specialties. (Submitted by: American Society of Plastic
Surgeons)
- (Early public comment)We support the changes in version 6.0 which
was recently endorsed by NQF. The measure should replace the current measure
in IQR. After gaining experience in IQR the measure should then be added to
the other payment programs (HACRP, HVBP). (Submitted by: Premier)
- (Early public comment)We support inclusion of this NQF-endorsed
measure for consideration under the full range of CMS quality programs,
including HVBP, HIQR, and HACRP. As noted in CMS’ Measure Rationale, each
measure in PSI 90 is an outcome measure that has been shown to be largely
preventable through improved structures and processes of care: each measure
has an evidence review form as part of the NQF endorsement process; and the
literature to support each measure is updated on a schedule basis. Last year,
CMS indicated they were reassessing inclusion of PSI 90 as a quality measure
and would be basing their recommendation after re-review by AHRQ. This
measure was reassessed by AHRQ this year and received continued endorsement,
and was the recipient of multiple public comments. The public and AHRQ
endorsement of this composite measure, which is composed of individual quality
measures that are widely preventable with appropriate clinical safety and
surveillance measures, supports the value of this measure and its utility in a
range of CMS hospital quality reporting and pay-for-performance programs.
(Submitted by: AdvaMed)
- (Early public comment)We support inclusion of this measure for
consideration under the full range of CMS quality programs, including HVBP,
HIQR, and HACRP. As noted in CMS’ Measure Rationale, each measure in PSI 90
is an outcome measure that has been shown to be largely preventable through
improved structures and processes of care: each measure has an evidence review
form as part of the NQF endorsement process; and the literature to support
each measure is updated on a schedule basis. Last year, CMS indicated they
were reassessing inclusion of PSI 90 as a quality measure and would be basing
their recommendation after re-review by AHRQ. This measure was reassessed by
AHRQ this year and received continued endorsement, and was the recipient of
multiple public comments. The public and AHRQ endorsement of this composite
measure, which is composed of individual quality measures that are widely
preventable with appropriate clinical safety and surveillance measures,
confirms the value of this measure and its utility in a range of CMS hospital
quality reporting and pay-for-performance programs. (Submitted by:
Medtronic)
(Program: Hospital Value-Based Purchasing
Program; MUC ID: MUC15-604) |
- We agree with MAP's support of this measure. (Submitted by:
Medtronic)
- Thank you for opportunity to comment upon the changes proposed to PSI 90
(NQF #0531). While we are in agreement with the removal of PSI 07, we question
the inclusion of PSI 09, PSI 10 and PSI 11. To the best of our knowledge,
these measures have not been previously included in the Hospital Inpatient
Quality Reporting (HIQR) Program. In addition, these three component
indicators are not currently reported on Hospital Compare. Given this, we are
unsure how they may be statutorily eligible to be included in the Hospital
Value-Based Purchasing (HVBP) program at this point, even if included as part
of a previously reported composite measure. We continue to be concerned about
the use of claims data to determine patient safety events. The claims-based
components that make up the PSI 90 measure use administrative data rather than
clinical indicators. The Centers for Medicare and Medicaid Services (CMS) has
recognized this point by decreasing the weight of the PSI 90 measure within
the Hospital Acquired Condition Reduction Program (HACRP) and the HVBP
Program. For this reason, we believe there is a substantial need for better
measures of patient harm that directly reflect clinical data. We are
particularly interested in the development of automated clinical indicators of
patient harm drawn directly from Health Information Technology (Health IT)
data. However, until such measures can be implemented on a nationwide scale,
we believe that CMS should use this updated and NQF-endorsed version of the
PSI 90 measure in favor of the previous version. As a point of consideration,
we think that the NQF should continue its work to ensure patient safety
indicators are always reflective of actual patient safety events that resulted
in preventable patient harm. The NQF should also continue to prioritize the
most precise measures such as the related National Healthcare Safety Network
(NHSN) measure of central line related blood stream infections. In addition,
the NQF must strive for greater simplicity in measure development. Composite
measures, such as PSI 90, require considerable statistical manipulation to
come to an index from which comparisons can be made. There is not much
explanation of what is gained or lost in such manipulations. According to the
Agency for Healthcare Research and Quality’s (AHRQ) PSI Composite Measure
Workgroup Report published in March 2008, there are several drawbacks to
composite measures: 1) they “can mask important differences and relations
among components,” 2) they “may not be actionable,” 3) composites can make it
“difficult to know which parts of the health care system contribute most to
quality,” 4) they “might not reflect the evidence base of the component
indicators.” We believe that the decision to remove PSI 07 because a related
NHSN measure was determined to be more valuable supports these concerns. It is
much more meaningful for consumers, when choosing providers, if safety metrics
are clear and actionable. The same is true for providers seeking to improve
the quality of care. Patient safety metrics should elucidate exactly what
interventions are connected and important. We think that grouping individual
measures demands even greater scrutiny of the statistical science behind the
weightings and risk-adjustment to ensure credibility, validity and
reliability. (Submitted by: Adventist Health System)
- We support the changes in version 6.0 which was recently endorsed by NQF.
The measure should replace the current measure in IQR. After gaining
experience in IQR the measure should then be added to the other payment
programs (HACRP, HVBP). (Submitted by: Premier)
- While the AHA believes this new version of PSI-90 is an improvement over
the existing measure, it continues to fall well short of the standard needed
for use in public accountability applications. We urge CMS to phase PSI-90 out
of its programs altogether. We have long been concerned by the significant
limitations of PSI 90 as a quality measure. PSIs use hospital claims data to
identify patients that have potentially experienced a safety event. However,
claims data cannot and do not fully reflect the details of a patient’s
history, course of care and clinical risk factors. As a result, as shown in a
CMS-commissioned analysis from 2012, the rates derived from the component
measures are highly inexact. PSI data may assist hospitals in identifying
patients whose particular cases merit deeper investigation with the benefit of
the full medical record. But, the measures are poorly suited to drawing
meaningful conclusions about hospital performance on safety issues. In other
words, PSI 90 may help hospitals determine what “haystack” to look in for
potential safety issues. But the ability of the measure to consistently and
accurately identify the “needle” (i.e., the safety event) is far too suspect
to deem it worthy of NQF endorsement, let alone use in public reporting and
pay-for-performance applications. (Submitted by: American Hospital Association
(AHA))
- Patient safety and adverse events are critical areas to measure and drive
improvement. However, little is known about how the measure’s changes and
refinements will alter hospital performance. We request that absolute and
relative performance changes be reviewed and understood prior to using this
measure in replacement of its predecessor. Further, the use of measures of
relative performance in VBP requires discussion. (Submitted by: Children's
Hospital Association)
- The ACS does not support the Patient Safety and Adverse Events Composite
for inclusion in HACRP or HVBP. ACS has concerns with PSI-15, a measure
included in the patient safety and adverse events composite (AHRQ PSI-90). We
continue to receive questions from ACS members expressing confusion regarding
coding for PSI-15, which is a highly weighted component of the AHRQ PSI-90
composite. In the past when we have expressed this concern, CMS has reference
to the American Hospital Association Coding Clinic guidance on PSI-15, but we
believe that coding for accidental puncture is still non-uniform due to lack
of clarity as to what constitutes an “accident.” Often punctures or
lacerations are incorrectly coded as “accidental” when the puncture or
laceration was part of the surgery. Measures that have questionable
reliability and validity should not be weighted so heavily. We request that
CMS provide more precise guidance regarding the correct coding of PSI-15.
(Submitted by: American College of Surgeons)
- (Early public comment)ASPS is pleased to see meaningful and
relevant measures for plastic surgeons in the MIPS program. Going forward,
ASPS wishes to continue to see more relevant measures for specialties and
surgical specialties. (Submitted by: American Society of Plastic
Surgeons)
- (Early public comment)We support the changes in version 6.0 which
was recently endorsed by NQF. The measure should replace the current measure
in IQR. After gaining experience in IQR the measure should then be added to
the other payment programs (HACRP, HVBP). (Submitted by: Premier)
- (Early public comment)We support inclusion of this NQF-endorsed
measure for consideration under the full range of CMS quality programs,
including HVBP, HIQR, and HACRP. As noted in CMS’ Measure Rationale, each
measure in PSI 90 is an outcome measure that has been shown to be largely
preventable through improved structures and processes of care: each measure
has an evidence review form as part of the NQF endorsement process; and the
literature to support each measure is updated on a schedule basis. Last year,
CMS indicated they were reassessing inclusion of PSI 90 as a quality measure
and would be basing their recommendation after re-review by AHRQ. This
measure was reassessed by AHRQ this year and received continued endorsement,
and was the recipient of multiple public comments. The public and AHRQ
endorsement of this composite measure, which is composed of individual quality
measures that are widely preventable with appropriate clinical safety and
surveillance measures, supports the value of this measure and its utility in a
range of CMS hospital quality reporting and pay-for-performance programs.
(Submitted by: AdvaMed)
- (Early public comment)We support inclusion of this measure for
consideration under the full range of CMS quality programs, including HVBP,
HIQR, and HACRP. As noted in CMS’ Measure Rationale, each measure in PSI 90
is an outcome measure that has been shown to be largely preventable through
improved structures and processes of care: each measure has an evidence review
form as part of the NQF endorsement process; and the literature to support
each measure is updated on a schedule basis. Last year, CMS indicated they
were reassessing inclusion of PSI 90 as a quality measure and would be basing
their recommendation after re-review by AHRQ. This measure was reassessed by
AHRQ this year and received continued endorsement, and was the recipient of
multiple public comments. The public and AHRQ endorsement of this composite
measure, which is composed of individual quality measures that are widely
preventable with appropriate clinical safety and surveillance measures,
confirms the value of this measure and its utility in a range of CMS hospital
quality reporting and pay-for-performance programs. (Submitted by:
Medtronic)
(Program: End-Stage Renal Disease
Quality Incentive Program; MUC ID: MUC15-693) |
- We believe this measure would be best used by pairing with the mortality
measure (MUC15-575). That way one balances the competing risks of death and
hospitalization. (Submitted by: Johns Hopkins Armstrong Institute for Patient
Safety and Quality)
- The National Kidney Foundation supports this measure and agrees with the
MAP recommendations. However, as we state in our comments on the Standardized
Readmissions Ratio, we believe this measure should be stratified by cause of
admission to include those that are actionable by the dialysis care team. The
admissions that may be most actionable include congestive heart failure,
volume overload and vascular access blood stream infections. Stratification
would give clinicians information for quality improvement focus and help
patients better assess the quality of care they can expect to receive in the
dialysis unit. An alternative approach to stratification by cause of admission
would be to exclude admissions that are not likely to be actionable by
dialysis care. (Submitted by: National Kidney Foundation)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- Standardized Hospitalization Ratio (SHR) – Modified Standardized
Mortality Ratio (SMR) – Modified ASN supports both the SMR and SHR measure in
concept; however ASN has several concerns with the current version. One major
area of concern is related to CMS’ Five Star program. In this context, it is
important to view metrics in the manner in which they are currently being
applied rather than as theoretical constructs. As of now, the SMR is used as
a rigid point estimate without any accounting for potential variance. When a
metric is used before endorsement, we have an interesting opportunity to
comment on whether the current use is appropriate; in this case, endorsement
of this metric would de facto endorse the current improper use of this
particular measure as a rigid ordinal ranking system, which is counter to its
design and its statistical qualities. Secondly, ASN would like to see some
refinement of the denominator (expected) adjustments. Currently, the 1st
stage model is adjusted for age, race, ethnicity, sex, diabetes, duration of
ESRD, nursing home status, patient comorbidities at incidence, calendar year
and body mass index (BMI) at incidence. This should be updated to look at
claims with a lag as is likely being done with more recently developed
measures. This would also have the benefit of encouraging parsimony in
measure methodology. Until these changes are made, ASN continues to have
concerns with the measures as proposed. If these measures are endorsed, ASN
urges NQF to comment on the appropriate use of these measures and the
inappropriate use of ordinal ranking without accounting for statistical
variance. (Submitted by: American Society of Nephrology (ASN))
- MUC 15-693—Standardized Hospitalization Ratio-Modified. KCP does not
concur with the MAP recommendation of “Conditional support.” The information
provided to date lacks the specificity required to fully evaluate the measure.
It is essential that the full details of the risk model be made transparent
and available for comment during the MAP process. Absent this information,
KCP cannot support the measure, even conditionally, because we cannot evaluate
it. KCP also strongly recommends that ratio measures be avoided and that
year-over-year normalized rates be used. (Submitted by: Kidney Care
Partners)
- Comments on Draft Report of Hospital Workgroup In the section that
addresses the ESRD Quality Incentive Program (page 12), KCP has two comments.
1. The draft report notes: MAP also supported updates to two additional
measures with the condition that NQF review the measure updates and examine
SDS factors as part of the review. KCP recommends this sentence be clarified
to indicate the specific measures, and that not only must review occur, but
endorsement also must occur: MAP also supported updates to two additional
measures— Standardized Readmission Ratio for Dialysis Facilities (MUC 15-1167)
and Standardized Hospitalization Ratio (MUC 15-693)— with the condition that
the measures maintain endorsement following NQF review of the measure updates
and examination of SDS factors as part of the review. (Submitted by: Kidney
Care Partners)
- (Early public comment)MUC 15-693—Standardized Hospitalization
Ratio-Modified. KCP notes that NQF 1463 is the existing NQF-endorsed SHR.
For the MUC list, however, CMS makes no reference to NQF 1463 (although
elsewhere it does include NQF numbers), so we must assume MUC 15-693 modifies
NQF 1463 because the information provided by CMS in the MUC list lack the
specificity required to fully evaluate it. It is essential that the full
details of the risk model be made transparent and available for comment during
the MAP process through the CMS list or an external link. Absent this
information, KCP cannot support the measure at this time because we cannot
evaluate it. KCP also strongly recommends that ratio measures be avoided and
that year-over-year normalized rates be used. (Submitted by: Kidney Care
Partners)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program: End-Stage Renal Disease Quality Incentive Program; MUC ID:
MUC15-758) |
- MUC 15-758—Avoidance of Utilization of High Ultrafiltration Rate (=13
ml/kg/hour). KCP concurs with the MAP recommendation to support MUC 15-758.
We believe fluid management is an important domain for inclusion in the QIP,
but KCP strongly objects to the characterization of MUC 15-758 as a “CMS;
Kidney Care Quality Alliance (KCQA)” measure. Although not noted in the
original MUC list, subsequent MAP materials indicated MUC 15-278 to be NQF
2701, for which the sole developer/steward is KCQA and which KCP supports, as
endorsed. We also note an eighth exclusion for #2701 is missing from MUC
15-758—facilities treating <=25 adult in-center hemodialysis patients
during the reporting month. Dr. Pierre Yong of CMS acknowledged this was an
error during the Hospital Workgroup meeting, as was CMS claiming
co-stewardship. The Workgroup ultimately voted on and supported #2701, as
endorsed. KCP recommends the draft report specifically reference #2701, and
requests the omission of the exclusion and designation of KCQA as the sole
steward be corrected in the spreadsheet. (Submitted by: Kidney Care
Partners)
- MUC 15-758—Avoidance of Utilization of High Ultrafiltration Rate (= 13
ml/kg/hour) 1. National Quality Forum, Measure Applications Partnership,
Hospital Workgroup Meeting Transcript. December 17, 2015. Page 63, lines
1-18. Available at:
http://www.qualityforum.org/ProjectMaterials.aspx?projectID=75369. Accessed
January 1, 2016. (Submitted by: Kidney Care Partners)
- NKF supports the use NQF# 2701: Avoidance of Utilization of High
Ultrafiltration Rate (>/= 13 ml/kg/hour), in the QIP. There is broad
consensus that optimizing ultrafiltration and fluid management in hemodialysis
is an important and actionable aspect of care to improve hypertension control
and minimize heart failure and volume overload. However, medical experts have
mixed opinions regarding whether or not this measure is a significant quality
improvement advancement. There was concern on the part of some that the
measure could actually promote less adequate achievement of ideal dialysis dry
weight, since the focus is on limiting ultrafiltration rather than optimal
achievement of target weight. However, NKF is supporting the measure as a
first step in the direction to address this key domain of dialysis care. The
NKF updated KDOQI hemodialysis adequacy draft guidelines do not include a
target for UFR and instead recommend minimizing UFR as best possible in order
to maximize hemodynamic stability and tolerability of the hemodialysis
procedure. This is because the supporting evidence for a specific target is
limited. One study, suggests an increased risk for individuals with heart
failure with a UFR between 10-14 ml/h/kg, but improvements in outcomes for
individuals without heart failure with a UFR in that range. However, NKF
believes the >/=13 ml/kg target for a quality measure of UFR has reasonable
consensus among experts. This measure applies only to those patients treated
<240 minutes. Successful implementation of the measure will require patient
participation and shared decision making on proper dialysis prescription and
fluid intake. (Submitted by: National Kidney Foundation)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- Avoidance of Utilization of High Ultrafiltration Rate (= 13 ml/kg/hour)
ASN strongly supports this concept, but would recommend that NQF support the
KCQA measures over the current CMS measure. While there are limitations with
both of these measures, ASN feels that it is an important start to addressing
one of the most important elements of dialysis care, volume management. As
discussed by CMS in the 2015 ESRD Final Rule, we agree that gathering these
data and understanding this measure are important prior to its inclusion as a
performance measure attached to the QIP. (Submitted by: American Society of
Nephrology (ASN))
- We are concerned about the quality of the studies that informed this
measure. High ultrafiltration rates may be associated with worse outcomes due
to the confounding factors that contribute to higher interdialytic weight
gain. There is NO RCT data to support this. (Submitted by: Johns Hopkins
Armstrong Institute for Patient Safety and Quality)
- (Early public comment)MUC 15-758—Avoidance of Utilization of High
Ultrafiltration Rate (= 13 ml/kg/hour). KCP believes fluid management is an
important domain for inclusion in the QIP, but objects to the characterization
of MUC 15-758 as a “CMS; Kidney Care Quality Alliance (KCQA)” measure. The
measure specifications appear to be those of NQF 2701, although we note that
an eighth exclusion is missing, whether inadvertently or intentionally cannot
be determined. The exclusion in the NQF-endorsed measure is “8. Facilities
treating
(Program: End-Stage Renal
Disease Quality Incentive Program; MUC ID: MUC15-761) |
- MUC 15-761—ESRD Vaccination: Full-Season Influenza Vaccination. KCP
concurs with the MAP recommendation of “Do not support.” KCP supports the
NQF-endorsed dialysis facility-level measure, NQF #0226 Influenza Immunization
in the ESRD Population, which is referred to in the spreadsheet and draft
report. (Submitted by: Kidney Care Partners)
- 1. The draft report notes: MAP did not support the inclusion of ESRD
Vaccination: Full-Season Influenza Vaccination (MUC15-761) because there is
already an NQF endorsed influenza vaccination claims-based measure available.
KCP recommends this sentence be edited to provide the number of the
NQF-endorsed measure (NQF #0226). The words “claims-based” should be struck,
as they incorrectly characterize this measure. The measure is not strictly
claims-based. While it may be claims-based, it also was specified and tested
by KCQA from the medical record, with the intent that appropriate data
elements be transmitted through CROWNWeb. The new sentence would be: MAP did
not support the inclusion of ESRD Vaccination: Full-Season Influenza
Vaccination (MUC15-761) because there is already an NQF endorsed influenza
vaccination measure available (NQF #0226). (Submitted by: Kidney Care
Partners)
- ESRD Vaccination: Full-Season Influenza Vaccination ASN supports this
measure and thanks NQF for including it in this year’s MAP. (Submitted by:
American Society of Nephrology (ASN))
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- NKF supports the evidenced-based Full-Season Influenza Vaccine measure in
the QIP. We suggest CMS use the alternative NQF-endorsed #0226 Influenza
Immunization in the ESRD population rather than introduce an entirely new
measure. In addition, we are concerned about the “offered but declined”
portion of both measures that could be inappropriately used without adequate
patient education. Accordingly, NKF suggests CMS monitor the proportion of
patients with this exclusion in dialysis facilities to identify outliers.
(Submitted by: National Kidney Foundation)
- (Early public comment)Inclusion of these measures will build on
existing immunization-related measures currently used in the Physician Quality
Reporting System to help ensure that Medicare beneficiaries benefit from these
important vaccinations. (Submitted by: Trust for America's
Health)
- (Early public comment)This measure addresses an important
preventive health intervention and provides for appropriate allowance for
patients who refuse the vaccine or who have contraindications to the vaccine.
(Submitted by: The Society for Healthcare Epidemiology of
America)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
- (Early public comment)MUC 15-761—ESRD Vaccination: Full-Season
Influenza Vaccination. KCP recognizes the high importance of influenza
vaccination, but strongly opposes MUC-15-761 because it is not aligned with
the NQF-endorsed standardized specifications for influenza immunization
measures. More importantly, an NQF-endorsed dialysis facility-level measure
already exists in the NQF portfolio that fully aligns with the NQF-endorsed
standardized specifications: #0226 Influenza Immunization in the ESRD
Population. We recognize measurement specifications, like evidence, evolve.
However, we believe CMS and the kidney care community are best and most
efficiently served if CMS conforms to existing NQF processes to address
full-season influenza vaccination performance measurement. Specifically, if
CMS believes the evidence supports the changes its specifications encompass,
it should work with KCQA, and use the NQF endorsement maintenance process to
request that NQF #0226 deviate from the standardized specifications or that
the standard specifications themselves be updated. (Submitted by: Kidney Care
Partners)
(Program:
Hospital Inpatient Quality Reporting and EHR Incentive Program; MUC ID:
MUC15-835) |
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- ACS agrees that measuring resource use (cost) is different from
appropriateness of care; the cost of a service is not indicative of quality
care. Additionally, we seek clarity about whether the measure steward
conducted an analysis of elective versus emergent repair. If this analysis was
not done, we strongly suggest including this in the measure testing and
excluding emergent repair if there is variability. (Submitted by: American
College of Surgeons)
- We agree with MAP, this is an acute condition with a heteregenous
population and a wide degree of standards of care. (Submitted by:
Premier)
- (Early public comment)"This is an acute condition with a
heteregenous population and a wide degree of standards of care; risk
adjustment does not appear to account for this. The condition-specific payment
meaures overlap with the Medicare Spending Per Beneficiary measure that is
currently in HIQR and HVBP; adding segments of MSPB creates unecessary
duplication in the programs. While these payment measures would create
alignment with the physician value-modifier and later MIPS; MACRA requires
establishment of patient relationship categories and codes to attribute
patients and episodes to providers, this significantly change could the way
the episode groupers are implemented and lead to lack of alignment between the
hospital and physician specifications. Accordingly, the measures should not be
added to hospital programs in advance of finalizing the measures for physician
programs. Additionally, we have ongoing concerns about these measures. First,
measures of Federal spending are not real indicators of “value” for
beneficiaries as they neither capture the quality of care, nor are paired with
measures that do so. Moreover, the measures do not give beneficiaries a sense
of their financial obligation so they are not useful for public reporting and
beneficiary engagement purposes. Also, the spending measures are cross-cutting
measures that are not appropriate for evaluating care exclusively in the
inpatient setting. CMS data has previously shown that variation in total
Medicare payments for episodes are primarily due to readmission rates and
post-acute care. Post-acute care use varies due to wide ranging differences in
local market availability of these services and patterns of care, which are
not within the hospital’s control." (Submitted by: Premier)
- (Early public comment)The AMA continues to have several concerns
regarding the clinical episode-based payment measures. First, as we noted
previously, we are concerned that the 90-day look-back period to capture a
patient’s co-morbidities in order to determine the hierarchical condition
categories (HCC) score is insufficient. There is precedent for utilizing a
longer look-back period: the HCC risk adjustment model used for the current
mortality and readmission measures utilizes a one year look-back period.
Second, information on the reliability and validity of this measure is not yet
available. In general, it is difficult to evaluate whether the measure is
appropriate for adoption in light of this lack of information. Data on the
reliability of the measure specifications is needed. In addition and perhaps
more importantly, the validity of these measures must be demonstrated prior to
implementation in any pay-for-performance program. Finally, continuing to
include cost of care measures in the absence of accompanying quality measures
addressing the same clinical condition is contrary to NQF recommendations and
the intent of the value-based programs. Because the proposed measure does not
demonstrate the linkage of expenditures as a result of quality achieved, the
proposed measure will not provide actionable information that a hospital and
physician could use to identify how to make improvements. In summary,
applying this measure in any pay-for-performance program without adequate
review and testing would have significant negative unintended consequences.
(Submitted by: American Medical Association)
- (Early public comment)The AMA continues to have several concerns
regarding the clinical episode-based payment measures. Information on the
reliability and validity of this measure is not yet available. In general, it
is difficult to evaluate whether the measure is appropriate for adoption in
light of this lack of information. Data on the reliability of the measure
specifications is needed. In addition and perhaps more importantly, the
validity of these measures must be demonstrated prior to implementation in any
pay-for-performance program. Finally, continuing to include cost of care
measures in the absence of accompanying quality measures addressing the same
clinical condition is contrary to NQF recommendations and the intent of the
value-based programs. Because the proposed measure does not demonstrate the
linkage of expenditures as a result of quality achieved, the proposed measure
will not provide actionable information that a hospital and physician could
use to identify how to make improvements. In summary, applying this measure
in any pay-for-performance program without adequate review and testing would
have significant negative unintended consequences. Ultimately, the AMA is
hopeful that with some refinements, tying costs and quality to well-defined
episodes of care will provide a more fair and accurate view of physician
performance than the measures that CMS is currently using in the hospital and
physician value-based purchasing programs. We do not think that the measures
proposed in this rule have been sufficiently refined; however, we also are
opposed to layering condition-specific measures on top of the broad total cost
measures CMS is now using. The AMA has expressed frequent objections to CMS’
use of overlapping physician measures that all pick up the costs of a cohort
of chronically ill patients with significant health care costs that make
physicians who treat these patients more likely than others to face penalties
under the value-based modifier. We are concerned that the new episode measures
proposed will intensify similar problems on the hospital side and could create
barriers to care for some patients. The fact that these measures have not yet
been endorsed by NQF and that we do not know their final form adds to our
discomfort and suggests that CMS is not practicing the transparency that it
preaches. Ultimately, the AMA is hopeful that with some refinements, tying
costs and quality to well-defined episodes of care will provide a more fair
and accurate view of physician performance than the measures that CMS is
currently using in the hospital and physician value-based purchasing programs.
We do not think that the measures proposed in this rule have been sufficiently
refined; however, we also are opposed to layering condition-specific measures
on top of the broad total cost measures CMS is now using. The AMA has
expressed frequent objections to CMS’ use of overlapping physician measures
that all pick up the costs of a cohort of chronically ill patients with
significant health care costs that make physicians who treat these patients
more likely than others to face penalties under the value-based modifier. We
are concerned that the new episode measures proposed will intensify similar
problems on the hospital side and could create barriers to care for some
patients. The fact that these measures have not yet been endorsed by NQF and
that we do not know their final form adds to our discomfort. (Submitted by:
American Medical Association)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program: Hospital Inpatient Quality Reporting and EHR Incentive Program;
MUC ID: MUC15-836) |
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- We agree that measuring resource use (cost) is different from
appropriateness of care; the cost of a service is not indicative of quality
care. Additionally, it is very difficult to define the severity of illness
for cholecystectomy and common duct exploration thereby making this a poor
proxy for quality. (Submitted by: American College of Surgeons)
- We agree with MAP, this is an acute condition with a heteregenous
population and a wide degree of standards of care. (Submitted by:
Premier)
- (Early public comment)"The condition-specific payment meaures
overlap with the Medicare Spending Per Beneficiary measure that is currently
in HIQR and HVBP; adding segments of MSPB creates unecessary duplication in
the programs. While these payment measures would create alignment with the
physician value-modifier and later MIPS; MACRA requires establishment of
patient relationship categories and codes to attribute patients and episodes
to providers, this significantly change could the way the episode groupers are
implemented and lead to lack of alignment between the hospital and physician
specifications. Accordingly, the measures should not be added to hospital
programs in advance of finalizing the measures for physician programs.
Additionally, we have ongoing concerns about these measures. First, measures
of Federal spending are not real indicators of “value” for beneficiaries as
they neither capture the quality of care, nor are paired with measures that do
so. Moreover, the measures do not give beneficiaries a sense of their
financial obligation so they are not useful for public reporting and
beneficiary engagement purposes. Also, the spending measures are cross-cutting
measures that are not appropriate for evaluating care exclusively in the
inpatient setting. CMS data has previously shown that variation in total
Medicare payments for episodes are primarily due to readmission rates and
post-acute care. Post-acute care use varies due to wide ranging differences in
local market availability of these services and patterns of care, which are
not within the hospital’s control." (Submitted by: Premier)
- (Early public comment)The AMA continues to have several concerns
regarding the clinical episode-based payment measures. First, as we noted
previously, we are concerned that the 90-day look-back period to capture a
patient’s co-morbidities in order to determine the hierarchical condition
categories (HCC) score is insufficient. There is precedent for utilizing a
longer look-back period: the HCC risk adjustment model used for the current
mortality and readmission measures utilizes a one year look-back period.
Second, information on the reliability and validity of this measure is not yet
available. In general, it is difficult to evaluate whether the measure is
appropriate for adoption in light of this lack of information. Data on the
reliability of the measure specifications is needed. In addition and perhaps
more importantly, the validity of these measures must be demonstrated prior to
implementation in any pay-for-performance program. Finally, continuing to
include cost of care measures in the absence of accompanying quality measures
addressing the same clinical condition is contrary to NQF recommendations and
the intent of the value-based programs. Because the proposed measure does not
demonstrate the linkage of expenditures as a result of quality achieved, the
proposed measure will not provide actionable information that a hospital and
physician could use to identify how to make improvements. In summary,
applying this measure in any pay-for-performance program without adequate
review and testing would have significant negative unintended consequences.
(Submitted by: American Medical Association)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program: Hospital
Inpatient Quality Reporting and EHR Incentive Program; MUC ID: MUC15-837)
|
- NASS supports MAP’s preliminary decision to not support the Spinal Fusion
Clinical Episode-Based Payment Measure for use in the Hospital Inpatient
Quality Reporting Program. MAP cited that the lack of data supporting
variation in costs for this procedure influenced their preliminary vote
against the measure. We agree with MAP’s rationale against use of the measure
on the basis that “the cost of a service is not indicative of quality care.”
Furthermore, NASS would like to reiterate comments that we previously
submitted on this measure through the 2015 MAP Measure Preliminary Decision
Comment Period and the 2016 Proposed Rule for Hospital Inpatient Prospective
Systems for Acute Care Hospitals and the Long-Term Care Hospital Prospective
Payment System.1 NASS comments relative to measure specifications for the
Spinal Fusion Clinical Episode-Based Payment Measure are as follows: • Spinal
conditions are heterogeneous due to the populations affected. NASS feels that
further exclusions need to be identified in order to establish a more uniform
population. Specifically, trauma and infection spinal conditions have a
greater risk of prolonged hospital stay and morbidities due to concurrent
injuries and greater rates of neurologic dysfunction. In addition, it is
essential to differentiate by elective and emergent (i.e., surgical
intervention within 24 to 48 hours of presentation) cases. Patients requiring
emergency surgery are significantly more complicated and tend to have higher
risk of neurologic injury; thus, requiring additional support. Failure to
stratify cases by elective or emergent creates an unfair comparison for
surgeons treating a large proportion of high risk patients. • In addition to
basic risk adjustment methodologies for this measure, NASS recommends that the
measure be stratified by the number of fusion levels performed and the area
where the fusion was performed (cervical, thoracic, lumbar). If the measure is
unable to be stratified by the exact number of fusions performed, NASS
recommended that the number of fusions are stratified in groupings, such as
1-2 levels, 3-5 levels, 6-9 levels or more than 10 levels. • The indications
for, surgical timing and postoperative care required for fusions vary widely
and the associated costs are heavily influenced by a variety of factors,
including co-morbidities, number of fusion levels performed and region of the
spine. Thus, for comparison purposes, this level of granularity is necessary
and should be considered when evaluating each fusion/refusion episode of care.
References: 1- North American Spine Society. NASS Comments on Proposed Rule
for Hospital Inpatient Prospective Systems for Acute Care Hospitals and the
Long-Term Care Hospital Prospective Payment System.
https://www.spine.org/Portals/0/Documents/ResearchClinicalCare/Comments/ScientificPolicy061615.pdf
(Submitted by: North American Spine Society)
- The AANS agrees with the MAP's recommendation NOT to support the Spine
Fusion Clinical Episode Based Payment Measure. While the measure is
well-intended, it is understudied and needs considerable work. Cost variation
based on procedure type, patient diagnosis, and patient comorbidities must be
factored into any such assessment and data supporting variation in costs for
this procedure was not provided. We also agree that the cost of a service is
not necessarily indicative of quality care. Organized neurosurgery stands
ready to provide expertise and assist measure developers with further refining
this measure. (Submitted by: American Association of Neurological
Surgeons)
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- We agree with MAP, this is an acute condition with a heteregenous
population and a wide degree of standards of care. (Submitted by:
Premier)
- (Early public comment)"This is a complex surgery that will likely
have very small numbers so it will be difficult to reliably meausre. The
condition-specific payment meaures overlap with the Medicare Spending Per
Beneficiary measure that is currently in HIQR and HVBP; adding segments of
MSPB creates unecessary duplication in the programs. While these payment
measures would create alignment with the physician value-modifier and later
MIPS; MACRA requires establishment of patient relationship categories and
codes to attribute patients and episodes to providers, this significantly
change could the way the episode groupers are implemented and lead to lack of
alignment between the hospital and physician specifications. Accordingly, the
measures should not be added to hospital programs in advance of finalizing the
measures for physician programs. Additionally, we have ongoing concerns about
these measures. First, measures of Federal spending are not real indicators of
“value” for beneficiaries as they neither capture the quality of care, nor are
paired with measures that do so. Moreover, the measures do not give
beneficiaries a sense of their financial obligation so they are not useful for
public reporting and beneficiary engagement purposes. Also, the spending
measures are cross-cutting measures that are not appropriate for evaluating
care exclusively in the inpatient setting. CMS data has previously shown that
variation in total Medicare payments for episodes are primarily due to
readmission rates and post-acute care. Post-acute care use varies due to wide
ranging differences in local market availability of these services and
patterns of care, which are not within the hospital’s control." (Submitted by:
Premier)
- (Early public comment)The AMA continues to have several concerns
regarding the clinical episode-based payment measures. First, as we noted
previously, we are concerned that the 90-day look-back period to capture a
patient’s co-morbidities in order to determine the hierarchical condition
categories (HCC) score is insufficient. There is precedent for utilizing a
longer look-back period: the HCC risk adjustment model used for the current
mortality and readmission measures utilizes a one year look-back period.
Second, information on the reliability and validity of this measure is not yet
available. In general, it is difficult to evaluate whether the measure is
appropriate for adoption in light of this lack of information. Data on the
reliability of the measure specifications is needed. In addition and perhaps
more importantly, the validity of these measures must be demonstrated prior to
implementation in any pay-for-performance program. Finally, continuing to
include cost of care measures in the absence of accompanying quality measures
addressing the same clinical condition is contrary to NQF recommendations and
the intent of the value-based programs. Because the proposed measure does not
demonstrate the linkage of expenditures as a result of quality achieved, the
proposed measure will not provide actionable information that a hospital and
physician could use to identify how to make improvements. In summary,
applying this measure in any pay-for-performance program without adequate
review and testing would have significant negative unintended consequences.
(Submitted by: American Medical Association)
- (Early public comment)The AMA continues to have several concerns
regarding the clinical episode-based payment measures. Information on the
reliability and validity of this measure is not yet available. In general, it
is difficult to evaluate whether the measure is appropriate for adoption in
light of this lack of information. Data on the reliability of the measure
specifications is needed. In addition and perhaps more importantly, the
validity of these measures must be demonstrated prior to implementation in any
pay-for-performance program. Finally, continuing to include cost of care
measures in the absence of accompanying quality measures addressing the same
clinical condition is contrary to NQF recommendations and the intent of the
value-based programs. Because the proposed measure does not demonstrate the
linkage of expenditures as a result of quality achieved, the proposed measure
will not provide actionable information that a hospital and physician could
use to identify how to make improvements. In summary, applying this measure
in any pay-for-performance program without adequate review and testing would
have significant negative unintended consequences. Ultimately, the AMA is
hopeful that with some refinements, tying costs and quality to well-defined
episodes of care will provide a more fair and accurate view of physician
performance than the measures that CMS is currently using in the hospital and
physician value-based purchasing programs. We do not think that the measures
proposed in this rule have been sufficiently refined; however, we also are
opposed to layering condition-specific measures on top of the broad total cost
measures CMS is now using. The AMA has expressed frequent objections to CMS’
use of overlapping physician measures that all pick up the costs of a cohort
of chronically ill patients with significant health care costs that make
physicians who treat these patients more likely than others to face penalties
under the value-based modifier. We are concerned that the new episode measures
proposed will intensify similar problems on the hospital side and could create
barriers to care for some patients. The fact that these measures have not yet
been endorsed by NQF and that we do not know their final form adds to our
discomfort and suggests that CMS is not practicing the transparency that it
preaches. Ultimately, the AMA is hopeful that with some refinements, tying
costs and quality to well-defined episodes of care will provide a more fair
and accurate view of physician performance than the measures that CMS is
currently using in the hospital and physician value-based purchasing programs.
We do not think that the measures proposed in this rule have been sufficiently
refined; however, we also are opposed to layering condition-specific measures
on top of the broad total cost measures CMS is now using. The AMA has
expressed frequent objections to CMS’ use of overlapping physician measures
that all pick up the costs of a cohort of chronically ill patients with
significant health care costs that make physicians who treat these patients
more likely than others to face penalties under the value-based modifier. We
are concerned that the new episode measures proposed will intensify similar
problems on the hospital side and could create barriers to care for some
patients. The fact that these measures have not yet been endorsed by NQF and
that we do not know their final form adds to our discomfort. A key issue
raised on nearly all the measures is that they are not granular enough. That
is, they cover a very broad group of patients with very different expected use
of care and a wide range of justifiable costs, thereby leading to the
possibility that a hospital might do better or worse than others based on
their patient mix rather than the care they deliver. Additionally, the
specialties that provide the services covered in these measures have
identified serious clinical problems in their specifications, including
anatomical errors, such as including cervical codes in a lumbar spine episode.
In several cases, the clinicians who perform the services have also identified
other services where episode measures would be more appropriate. This suggests
the need for far greater involvement of physicians in the development and
approval of the measures since it is unrealistic to expect the necessary
clinical expertise from the MAP and the NQF. (Submitted by: American Medical
Association)
- (Early public comment)This measure is currently in the early stage
of development, has never been submitted to NQF and thus is not NQF-endorsed
(Submitted by: AdvaMed)
(Program: Hospital Inpatient Quality
Reporting and EHR Incentive Program; MUC ID: MUC15-838) |
- FAH supports the workgroup's recommendation and rationale. (Submitted
by: Federation of American Hospitals)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- We agree with MAP, this is an acute condition with a heteregenous
population and a wide degree of standards of care. (Submitted by:
Premier)
- (Early public comment)"The condition-specific payment meaures
overlap with the Medicare Spending Per Beneficiary measure that is currently
in HIQR and HVBP; adding segments of MSPB creates unecessary duplication in
the programs. While these payment measures would create alignment with the
physician value-modifier and later MIPS; MACRA requires establishment of
patient relationship categories and codes to attribute patients and episodes
to providers, this significantly change could the way the episode groupers are
implemented and lead to lack of alignment between the hospital and physician
specifications. Accordingly, the measures should not be added to hospital
programs in advance of finalizing the measures for physician programs.
Additionally, we have ongoing concerns about these measures. First, measures
of Federal spending are not real indicators of “value” for beneficiaries as
they neither capture the quality of care, nor are paired with measures that do
so. Moreover, the measures do not give beneficiaries a sense of their
financial obligation so they are not useful for public reporting and
beneficiary engagement purposes. Also, the spending measures are cross-cutting
measures that are not appropriate for evaluating care exclusively in the
inpatient setting. CMS data has previously shown that variation in total
Medicare payments for episodes are primarily due to readmission rates and
post-acute care. Post-acute care use varies due to wide ranging differences in
local market availability of these services and patterns of care, which are
not within the hospital’s control." (Submitted by: Premier)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program:
Merit-Based Incentive Payment System (MIPS); MUC ID: MUC15-928)
|
- While written comments were not provided, the commenter indicated their
support for MAP's preliminary recommendation (Submitted by: Indian Health
Service)
- There is a typo in Description Column - The PHQ score should be less than
< 5 not greater than > 5 to demonstrate remission. (Submitted by:
American Medical Group Association - KF)
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- Dear MAP Coordinating Committee Members: In follow-up to our submission on
December 7, 2015, the Network for Regional Healthcare Improvement (NRHI), a
national organization representing 40 Regional Health Improvement
Collaboratives, offers the following additional comments on the MAP Hospital
Workgroup’s preliminary recommendations on the list of Measures under
Consideration (MUC) issued December 1, 2015. NRHI and the Center for
Healthcare Transparency supports the MAP’s recommendation to conditionally
support MUC15-928, the paired measure of Depression Utilization and Remission
at six and twelve months. However, we would encourage the members to consider
lending their full support to this measure. Based on input from provider,
purchaser, consumer and health improvement collaborative users, the Depression
Remission at Six Months measure was selected as one of fifteen high value
measures that will be implemented as part of the Center for Healthcare
Transparency’s Measure Dashboard. To-date, twenty-three organizations that
together serve 48% of the U.S. population have agreed to produce all of the
measures on the dashboard, including Depression Remission, in a consistent way
by 2020. The PHQ-9 Tool has already been implemented by providers across
multiple regions, and with support and coordination through the Center for
Healthcare Transparency (CHT), beginning in 2016, several regions are slated
to demonstrate the feasibility of consistent implementation of the 6 month
Depression Remission measure in multiple states, learning from and building on
the successful reporting of the measure by Minnesota Community Measurement.
For 2014, Minnesota’s statewide PHQ-9 Utilization reached 70% of the adult
population with major depression or dysthymia and MNCM achieved a 31% rate of
PHQ-9 Follow up at Six Months, a 3% increase in patients receiving this
follow-up relative to 2013. The implementation demonstration sites coordinated
through CHT will be using multiple strategies to continue to understand and
increase response rates for different types of providers. This larger set of
data from measure implementation in multiple regions with varied
characteristics will also offer important opportunities to analyze risk
stratification options and address concerns around adverse selection, another
of the concerns identified by the MAP. In addition to our comments on
MUC15-928, NRHI wishes to reiterate its belief in the importance of measure
consolidation, measure alignment across programs, and the need for a balanced
measures set. We also encourage the MAP to consider new measures of cost,
including the Total Cost of Care measure developed by HealthPartners, endorsed
by NQF, and piloted by regional collaboratives. We refer the MAP to NRHI’s
December 7, 2015 letter for detailed comments on these issues. NRHI commends
the MAP for its work and appreciates this opportunity to comment on the
Measure Applications Partnership (MAP) 2015-2016 Preliminary Recommendations.
Respectfully submitted, The Network for Regional Healthcare Improvement
(Submitted by: Network for Regional Healthcare Improvement
(NRHI))
- We believe it is reasonable to exclude hospice (Submitted by: American
Academy of Hospice and Palliative Medicine)
- Depression Utilization of the PHQ-9 Tool; Depression Remission at Six
Months; Depression Remission at Twelve Months The MAP draft plan states that
MAP members noted that use of the PHQ-9 tool for depression screening is
promoted through measurement in private programs as well as the Adult and
Child Core Measure Sets for Medicaid and that fostering alignment across these
programs was part of MAP’s rationale for supporting a similar measure for MIPS
and MSSP. The AAMC recommends that this draft report also reflect the concern
raised by some MAP members that this measure have appropriate risk adjustment
to account for providers caring for high risk populations from both a clinical
and sociodemographic standpoint. For these high risk populations it could be
very difficult to achieve a PHQ score of greater than 5 at 6 months or 12
months (remission) as described in the measure. There may be other measures
related to depression that may be more appropriate to use in the MIPS program.
(Submitted by: Association of American Medical Colleges (AAMC))
- (Early public comment)The Core Measure Collaborative, a
multi-stakeholder group consisting of providers, health plans, consumers, and
employers, have consensus on the most important measures for depression for
primary care. They are NQF 0710 Depression Remission at 12 Months and NQF 1885
Depression Response at Twelve Months- Progress Towards Remission. The
composite that’s currently under consideration does not include NQF 1885
Depression Response at Twelve Months- Progress Towards Remission. Because of
the work of the Core Measure Collaborative, the AAFP strongly supports this
measure not be considered as a composite, but rather the measures be evaluated
individually. (Submitted by: American Academy of Family Physicians
)
- (Early public comment)NRHI strongly supports the incorporation of
proposed measure 928 (Paired measure - Depression Utilization of the PHQ-9
tool and Depression Remission at 6 months) The Center for Healthcare
Transparency (CHT), a nonprofit initiative with the goal of making credible
information on provider cost, quality and patient experience performance
available to 50% of the US by 2020, has included this measure as one of only
15 high value measures on its Measure Dashboard. Over the next five years, we
expect that each of the measures on this dashboard will be produced in a
standard and consistent way by the 35+ multi-stakeholder regional entities
that are expected to make up CHT’s national network of regional data
intermediaries. Alignment on this measure would allow providers, payers and
purchaser to use this measure for multiple quality improvement and value based
payment purposes. This measure was identified as a strong candidate for the
CHT measure dashboard through a careful process that began with CHT’s User
Council members identifying measures they were ready to use to either deliver
or pay for care differently. This measure was then vetted for inclusion in the
dashboard by both CHT’s technical advisory council of national experts and the
13 member CHT “design team” of regional entities that have extensive
experience implementing measures using aggregated data. (Submitted by: Network
for Regional Healthcare Improvement)
(Program: Prospective Payment
System-Exempt Cancer Hospital Quality Reporting Program; MUC ID:
MUC15-946) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- We agree with MAP that the measure changes should be reviewed for
endorsement and then brought back to the MAP for consideration. (Submitted by:
Premier)
- ADCC Conditionally Supports: This measure was previously adopted for the
PCHQR program during FY2014 rulemaking. The ADCC supports the adoption of the
revised measure (expanded to include patients with breast and rectal cancers)
for the PCHQR program, as long as sampling is applied (consistent with the
current sampling methodology for the PCHQR program). Of note, this measure is
largely topped out at our centers. Therefore, we acknowledge the questionable
value of expanding the measure to include additional disease sites. • The
ADCC supports adoption of revised measure, but notes that it is largely topped
out for Cancer Centers • Sampling methodology should remain unchanged
(Submitted by: Alliance of Dedicated Cancer Centers)
- (Early public comment)Position: This measure was previously adopted
for the PCHQR program during FY2014 rulemaking. The ADCC supports the
adoption of the revised measure (expanded to include patients with breast and
rectal cancers) for the PCHQR program, as long as sampling is applied
(consistent with the current sampling methodology for the PCHQR program). What
is the measure’s potential to improve patient outcomes? Adhering to normal
tissue dose limits can improve outcomes by decreasing toxicity to normal
tissues. Would use of the measure create undue data collection or reporting
burden? As long as sampling is applied (consistent with the current sampling
methodology for the PCHQR program), no undue burden is anticipated. Is there
a better measure available or does a measure already in the program set
address a particular program objective? No. (Submitted by: Alliance of
Dedicated Cancer Centers)
(Program: Hospital Outpatient Quality Reporting
Program; MUC ID: MUC15-951) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The Oncology Nursing Society (ONS) is a professional association of more
than 37,000 members committed to promotingexcellence in oncology nursing.
While we agree with and support the MAPs preliminary recommendation for this
measure, we urge NQF to support our suggestion that the measure steward place
additional focus on encouraging visits for untreated symptoms and infection,
which may be with oncology nurses. We believe patient care is improved when
effective care coordination and effective prevention and treatment are
emphasized, and the measure steward should consider the role of the oncology
nurse in this interdisciplinary measure. (Submitted by: Oncology Nursing
Society)
- We agree this measure should be reviewed for endorsement prior to
implementation in any program. This measure captures a wide range of reasons
for admission that are very different and not appropriate to combine.
(Submitted by: Premier)
- The AHA is concerned about the potential for unintended consequences in
measuring hospital admissions and ED visits of outpatient chemotherapy
patients. Given that there remain unanswered questions about measure testing
and reliability/validity, and that the measure has yet to be assessed for the
impact of sociodemographic factors, we recommend the MAP move this measure to
the “do not support” category. The measure developers and CMS must consider
carefully the impact such a measure may have on treatment decisions. Cancer
patients choose therapies that range from aggressive to palliative. Hospitals
work with patients to provide treatments that are best tailored to individual
patient needs and preferences. If not carefully implemented, the measure may
indirectly discourage more aggressive treatment plans that have clinical
benefit If CMS is intent on moving this measure forward, it must very
carefully engage with cancer hospitals, as well as patients and families, to
determine what type of patient population should be included in the measure.
Opinions on an appropriate measurement focus are likely to vary, and must be
carefully weighed. For example, the measure could include only patients on
palliative treatment regimens, where keeping patients out of the hospital
would be a desirable outcome. In addition, the AHA is concerned about the
validity of using only administrative claims data to capture the measure. In
assessing admissions and ED visits among chemotherapy patients, the measure
developers assume that such episodes are caused by how chemotherapy is
administered. However, we have heard that that it is not always clear whether
the complications (e.g., nausea, pain) included in the measure are the result
of chemotherapy rather than tumor progression. Using claims data alone may
not provide sufficient detail to make this important distinction. (Submitted
by: American Hospital Association (AHA))
- Amgen does not agree with MAP’s recommendation of “conditional support” of
MUC15-951 for inclusion in the Hospital Outpatient Quality Reporting (HOQR)
Program. Instead, we recommend that this measure not be included in the
program. While Amgen supports quality measures aimed at reducing avoidable
hospital admissions and ER visits for patients receiving outpatient
chemotherapy, we cannot support MAP’s recommendation of “conditional support”
of MUC15-951 for inclusion in the HOQR Program due to clinically relevant
issues. Because the causes for admissions and ED visits in cancer patients are
not exclusive sequelae of outpatient chemotherapy, the measure may not be a
sensitive nor specific indicator of physician practice in prevention of these
potential complications. ED visits/admits may be due to symptoms such as
nausea/pain, laboratory values (anemia), or infectious complications such as
neutropenia fever (FN). How to prevent and accurately identify the causes of
these conditions will be challenging. For example, patients do not visit an ED
for FN, but rather for fever and related symptoms. Additionally, the 30-day
time window wouldn’t specifically address FN, since this doesn’t correlate
with any normal cycle of neutropenic nadir and recovery. We reiterate our
prior comments that supported the NQF’s identification of FN as a priority
measure gap area and continue to support development of measures that would
address this gap. Unfortunately, this measure does not do that. Both internal
and external data sources, as well as published studies, have noted the
underreporting of both FN and infectious hospitalizations associated with FN,
related to incomplete coding, failure to measure absolute neutrophil count
(ANC) and/or temperature, and other logistical issues. These are good reasons
to develop an FN risk assessment measure, which would require incorporation of
both regimen and patient risk, and alignment with existing guidelines.
(Submitted by: Amgen)
- (Early public comment)This measure captures a wide range of reasons
for admission that are very different and not appropriate to combine.
Additionally, this measure should be reviewed for NQF endorsement. (Submitted
by: Premier)
- (Early public comment)This measure has never been submitted to NQF
and thus is not NQF-endorsed (Submitted by: AdvaMed)
(Program: Prospective Payment System-Exempt Cancer
Hospital Quality Reporting Program; MUC ID: MUC15-951) |
- Support MAP Preliminary Decision (Submitted by: Children's Hospital
Association)
- The Oncology Nursing Society (ONS) is a professional association of more
than 37,000 members committed to promotingexcellence in oncology nursing.
While we agree with and support the MAPs preliminary recommendation for this
measure, we urge NQF to support our suggestion that the measure steward place
additional focus on encouraging visits for untreated symptoms and infection,
which may be with oncology nurses. We believe patient care is improved when
effective care coordination and effective prevention and treatment are
emphasized, and the measure steward should consider the role of the oncology
nurse in this interdisciplinary measure. (Submitted by: Oncology Nursing
Society)
- We agree with MAP that the measure should be reviewed for endorsement and
then brought back to the MAP for consideration. (Submitted by:
Premier)
- ADCC Does not Support: Consistent with our comments submitted in 2014, the
ADCC supports the direction of this measure, but cannot support the measure—or
provide informed responses to the MAP’s questions—in the absence of detailed
measure specifications. Of note, preliminary field testing in 2013 revealed
validity and feasibility issues for this measure; there are no
publicly-available data to demonstrate improved measure properties following
additional testing. We believe that the MAP’s review of this measure should
be postponed until detailed measure specifications are available for review by
the MAP and the public. Specifically, we feel the measure is too broad and the
potential unintended consequences (e.g., underuse of appropriate care) are too
risky if it is implemented without proper testing and validation. We urge the
MAP to delay review until the measure has been through the NQF endorsement
process. • In the absence of detailed measure specifications, the ADCC does
not support adoption of the measure • 2013 field testing revealed feasibility
and validity issues • No publicly-available data to demonstrate improved
measure properties following additional testing • The MAP’s review of this
measure should be postponed until detailed measure specifications are
available for review by the MAP and the public and the measure has been
through the NQF endorsement process • Unintended consequences of
implementation without proper testing and validation may be profound • Many
of our member institutions do not operate an emergency department (Submitted
by: Alliance of Dedicated Cancer Centers)
- The AHA is concerned about the potential for unintended consequences in
measuring hospital admissions and ED visits of outpatient chemotherapy
patients. Given that there remain unanswered questions about measure testing
and reliability/validity, and that the measure has yet to be assessed for the
impact of sociodemographic factors, we recommend the MAP move this measure to
the “do not support” category. The measure developers and CMS must consider
carefully the impact such a measure may have on treatment decisions. Cancer
patients choose therapies that range from aggressive to palliative. Hospitals
work with patients to provide treatments that are best tailored to individual
patient needs and preferences. If not carefully implemented, the measure may
indirectly discourage more aggressive treatment plans that have clinical
benefit If CMS is intent on moving this measure forward, it must very
carefully engage with cancer hospitals, as well as patients and families, to
determine what type of patient population should be included in the measure.
Opinions on an appropriate measurement focus are likely to vary, and must be
carefully weighed. For example, the measure could include only patients on
palliative treatment regimens, where keeping patients out of the hospital
would be a desirable outcome. In addition, the AHA is concerned about the
validity of using only administrative claims data to capture the measure. In
assessing admissions and ED visits among chemotherapy patients, the measure
developers assume that such episodes are caused by how chemotherapy is
administered. However, we have heard that that it is not always clear whether
the complications (e.g., nausea, pain) included in the measure are the result
of chemotherapy rather than tumor progression. Using claims data alone may
not provide sufficient detail to make this important distinction. (Submitted
by: American Hospital Association)
- Amgen does not agree with MAP’s recommendation of “conditional support” of
MUC15-951 for inclusion in the PPS-Exempt Cancer Hospital Quality Reporting
(PCHQR) Program. Instead, we recommend that this measure not be included in
the program. While Amgen supports quality measures aimed at reducing avoidable
hospital admissions and ER visits for patients receiving outpatient
chemotherapy, we cannot support MAP’s recommendation of “conditional support”
of MUC15-951 for inclusion in the PCHQR Program due to clinically relevant
issues. Because the causes for admissions and ED visits in cancer patients are
not exclusive sequelae of outpatient chemotherapy, the measure may not be a
sensitive nor specific indicator of physician practice in prevention of these
potential complications. ED visits/admits may be due to symptoms such as
nausea/pain, laboratory values (anemia), or infectious complications such as
neutropenia fever (FN). How to prevent and accurately identify the causes of
these conditions will be challenging. For example, patients do not visit an ED
for FN, but rather for fever and related symptoms. Additionally, the 30-day
time window wouldn’t specifically address FN, since this doesn’t correlate
with any normal cycle of neutropenic nadir and recovery. We reiterate our
prior comments that supported the NQF’s identification of FN as a priority
measure gap area and continue to support development of measures that would
address this gap. Unfortunately, this measure does not do that. Both internal
and external data sources, as well as published studies, have noted the
underreporting of both FN and infectious hospitalizations associated with FN,
related to incomplete coding, failure to measure absolute neutrophil count
(ANC) and/or temperature, and other logistical issues. These are good reasons
to develop an FN risk assessment measure, which would require incorporation of
both regimen and patient risk, and alignment with existing guidelines.
(Submitted by: Amgen)
- (Early public comment)Evidence-based teaching about prevention,
risk assessment/early detection/reporting and early interventions of symptoms
and possible complications both during administration of chemotherapy by
nurses and other oncology staff and in follow-up calls by nursing staff are
key in addressing this measure. Synthesized evidence summaries for
interventions for symptoms that often lead to emergency department visits and
hospitalization are available from the Oncology Nursing Society (ONS) through
open access on the ONS website, along with teaching guides in publications and
courses. (Submitted by: Oncology Nursing Society)
- (Early public comment)This measure captures a wide range of reasons
for admission that are very different and not appropriate to combine.
Additionally, this measure should be reviewed for NQF endorsement. (Submitted
by: Premier)
- (Early public comment)Consistent with our comments submitted in
2014, the ADCC supports the direction of this measure, but cannot support the
measure (or provide informed responses to the MAP’s questions) in the absence
of detailed measure specifications. Of note, preliminary field testing in
2013 revealed validity and feasibility issues for this measure; there are no
publicly-available data to demonstrate improved measure properties following
additional testing. We believe that the MAP’s review of this measure should
be postponed until detailed measure specifications are available for review by
the MAP and the public. (Submitted by: Alliance of Dedicated Cancer
Centers)
(Program: Hospital Outpatient Quality Reporting Program; MUC ID:
MUC15-982) |
- This measure is endorsed for the 65 and over population only. Its use in
children would need to be assessed. (Submitted by: Children's Hospital
Association)
- FAH is concerned that the data resulting from this measure may not be
actionable for a hospital given the measurement timeframe. We request that
the measure be fully tested before it is considered for a future payment
program. FAH requests that the MAP change it's recommendation to conditional
support (Submitted by: Federation of American Hospitals)
- This measure should be reviewed to determine if SDS adjustment would be
appropriate. (Submitted by: Premier)
- (Early public comment)As written, the numerator will only be
patients with hospital admission after surgery or unplanned hospital visit
within 7 days of a hospital outpatient surgery. What, if any risk will this
measure create for plastic surgeons? (Submitted by: American Society of
Plastic Surgeons)
- (Early public comment)This meausre should be reviewed for NQF
endorsement, the review should ensure that the measure is appropriately
capturing unplanned hospital outpatient visits rather than all hospital
outpatient visits (e.g. appointments for post-op follow-up care). (Submitted
by: Premier)
- (Early public comment)Improving processes of care to prevent
avoidable readmissions is important to improve patient outcomes, patient
satisfaction, and avoid unnecessary healthcare spending. Providing objective,
standardized data to facilities may improve the ability (and interest) of
facilities to reduce avoidable readmissions. The key to this measure being
useful and appropriate for inclusion is the ability to consistently and
effectively distinguish between unplanned and planned hospital visits. Even
with this distinction, some outpatient surgery facilities may be disadvantaged
in their ability to prevent avoidable readmissions due to factors associated
with the community in which they provide care. For example, an outpatient
surgery center in an underserved, urban setting would likely face very
different challenges in preventing these “unplanned hospital visits” than one
in an affluent suburban neighborhood. Could such a measure lead to patient
selection that would serve as a barrier to care among patient populations at
higher risk of “unplanned” hospital visits? (Submitted by: The Society for
Healthcare Epidemiology of America)
- (Early public comment)This seems to be a process measure, not an
outcome measure (Submitted by: Society of Interventional
Radiology)
- (Early public comment)The American College of Obstetricians and
Gynecologists supports this measure. In hospital outpatient hysterectomy, it
optimizes care management and coordination of the discharge of the patient and
it creates an incentive for effective office post-operative visits. (Submitted
by: American College of Obstetricians and Gynecologists)
- (Early public comment)While written comments were not provided, the
commenter indicated they did not support this measure in this program.
(Submitted by: AdvaMed)
Appendix D: Instructions and Help
If you have any
problems navigating the discussion guide, please contact us at: MAPcoordinatingcommittee@qualityforum.org
Navigating the Discussion Guide
- How do I get back to the section I was just looking at?
The
easiest way is to use the back button on your browser. Other options are using
your backspace button (which works for many browsers on laptops), or using the
permanent links at the upper right hand corner of the discussion guide. But
the back button is the best choice in most situations.
- Can I print the discussion guide out?
You can, but we don't
recommend it. Besides using a lot of paper (probably a couple hundred pages at
least), you'll lose all the links that allow you to move around the document.
For instance, if you're scrolling through the agenda and want to see more
information about a particular measure, the electronic format will allow you
to click a link, read more, and then bo back. If you're on paper, there will
be a lot of flipping through paper.
- If I can't print this out, how can I read it on the plane?
We
will send you a pdf/Adobe Acrobat file a few days before the meeting, which
will hopefully be useful when you're reviewing the discussion guide as you
travel to Washington, DC.
- How do I know that I'm looking at the most recent version?
At
the top left corner of the discussion guide is a version number. At the
beginning of the in person meetings, the NQF staff will ask everyone to load
the most recent discussion guide version and will check that everyone has the
same version loaded.
- What electronic devices can I use to view the discussion guide?
We tried to make this as universal as possible, so it should work on your
laptop (PC, Mac, Linux), your tablet (iPad, Android), or your phone (iPhone,
Android). It should also work on many types of browsers (IE, Firefox, Chrome,
Safari, Opera, Dolphin,....). Please let us know if you have any problems, and
we'll troubleshoot with you (and improve the discussion guide for the next go
around).
- Why do I see weird characters in some places?
Because we're
joining data from many different sources, we do find some technical
challenges. This generally shows up as strange characters--extra question
marks, accented characters, or otherwise unusual items. We've been able to fix
many of these problems, but not all. We ask that you bear with us as we
improve this over time!
Content
- What is included in the discussion guide?
There are four
sections within this document:
- Agenda, with summaries of each measure under consideration
- Full information about each measure, including its specifications,
preliminary analysis of how this measure can advance the program's goals,
and the rationale by HHS for being included in the list
- Summaries for each federal health program being considered
- Public comments that have been received to date (Note that the
discussion guide may be released before the public comment period is
finished, in which case there will just be a placeholder for where comments
will go)
- How are the meeting discussions organized?
The meeting sessions
are organized around consent calendars, which are groups of measures being
considered for a particular program or groups of measures for a particular
condition or topic area. For each measure being discussed, this document will
show you the description, the public comments (if any), the summary of the
preliminary analysis, and the result of the preliminary analysis
algorithm.
Appendix E: Instructions for Joining the Meeting
Remotely
Remote Participation Instructions:
Streaming Audio Online
- Direct your web browser to: http://nqf.commpartners.com/se/NQFLogin/.
- Under “Enter a Meeting” type in the meeting number for Day 1: 418711 or
for Day 2: 748449
- In the “Display Name” field, type in your first and last names and click
“Enter Meeting.”
Teleconference
- Dial (888) 802-7237 for workgroup members or (877) 303-9138 for public
participants; use conference ID code: 49578518 for Day 1 and 49589247 for Day
2 to access the audio platform.