PRMR 2024-2025 Recommendations Spreadsheet

Dear Partnership for Quality Measurement (PQM) Pre-Rulemaking Measure Review Committee (PRMR) and Dr. Schreiber: 

On behalf of the American Podiatric Medical Association (APMA), the premier professional organization representing the vast majority of the nation’s doctors of podiatric medicine, also known as podiatrists or podiatric physicians and surgeons, please find attached APMA’s feedback on the 2024-2025 PRMR Measures Under Consideration (MUC) List Recommendations. .

If you require additional information, please contact APMA Vice President of Clinical Affairs and Medical Director Dyane Tower, DPM, MPH, MS, CAE at dtower@apma.org or 301-581-9250. Thank you for your time and consideration.

AHIP appreciates the Clinician Workgroup recognizing the feasibility issues with this measure. As we have raised in previous comments, there are significant challenges in collecting accurate, complete data for these measures. These issues include limited interoperability plan and provider systems, provider reluctance to share electronic health record (EHR) data with plans, and a lack of EHR adoption by some providers, especially safety net providers with limited resources or those left out of the CMS Meaningful Use program. We also understand that plans are having trouble accessing Logical Observation Identifiers Names and Codes (LOINC) necessary to calculate this measure because providers may not be using them or these codes are not readily available in the provider’s EHR. We also appreciate the Committee recognizing that performance on the SNE-E measure can be affected by regional variation in the availability of social support services. AHIP recommends that CMS work with NCQA, the developer for this measure, to address and resolve data collection challenges and other concerns raised by AHIP and our members before considering adoption of this measure for Star Ratings.

As CMS considers PRMR’s recommendations, we also wish to highlight the need to ensure more balanced stakeholder representation. Health plan representation on the Clinician workgroup is limited, despite the inclusion of the MA Stars program in its scope of work.  We are also concerned that Committee members may not have a robust understanding of the MA Stars program and the impact of ratings on health plans and the stakes of including measures in this program.  We recommend that as Battelle and CMS work to improve the PRMR process that committee meetings include an overview of the programs under the group’s purview and the impact of inclusion of a measure into that program. 

AHIP recognizes the importance of compliance with all Advisory Committee on Immunization Practices (ACIP) recommendations and improving the number of individuals up to date on recommended vaccinations.  However, we do not agree with PRMR’s recommendation to add this program to the MA Star Ratings Program. Data collection is challenging for this measure, and plans have noted challenges accessing the data required for this measure. There are a vast number of locations and opportunities beneficiaries have to receive immunizations and obtaining pre-enrollment vaccine history for beneficiaries is challenging because plans do not have universal access to state immunization registries. Additionally, the use of a single rate assessing compliance for all indicators could create unfair penalties for health insurance providers and miss important regional and/or cultural variation in vaccine acceptance.  AHIP recommends that CMS work with NCQA, the developer for this measure, to address and resolve data collection challenges and other concerns raised by AHIP and our members before considering adoption of this measure for Star Ratings.

As CMS considers PRMR’s recommendations, we also wish to highlight the need to ensure more balanced stakeholder representation. Health plan representation on the Clinician workgroup is limited, despite the inclusion of the MA Stars program in its scope of work.  We are also concerned that Committee members may not have a robust understanding of the MA Stars program and the impact of ratings on health plans and the stakes of including measures in this program.  We recommend that as Battelle and CMS work to improve the PRMR process that committee meetings include an overview of the programs under the group’s purview and the impact of inclusion of a measure into that program. 

We appreciate the Committee recognizing the potential challenges with implementing this measure. As we have raised in previous comments, there are significant challenges in collecting accurate, complete data for these measures. These issues include limited interoperability plan and provider systems, provider reluctance to share electronic health record (EHR) data with plans, and a lack of EHR adoption by some providers, especially safety net providers with limited resources or those left out of the CMS Meaningful Use program. We also understand that plans are having trouble accessing Logical Observation Identifiers Names and Codes (LOINC) necessary to calculate this measure because providers may not be using them or these codes are not readily available in the provider’s EHR. State laws and regulations that limit the sharing of mental health information with primary care providers without patient consent can adversely affect follow-up care. AHIP recommends that CMS work with NCQA, the developer for this measure, to address and resolve data collection challenges and other concerns raised by AHIP and our members before considering adoption of this measure for Star Ratings.

We also recommend that CMS use processes such as the measure endorsement process and the Core Quality Measures Collaborative to explore ways to promote measure alignment. 

As CMS considers PRMR’s recommendations, we also wish to highlight the need to ensure more balanced stakeholder representation. Health plan representation on the Clinician workgroup is limited, despite the inclusion of the MA Stars program in its scope of work.  We are also concerned that Committee members may not have a robust understanding of the MA Stars program and the impact of ratings on health plans and the stakes of including measures in this program.  We recommend that as Battelle and CMS work to improve the PRMR process that committee meetings include an overview of the programs under the group’s purview and the impact of inclusion of a measure into that program. 

Please see the attached comment letter from the American College of Surgeons (ACS) that includes feedback on MUC 2024-026 - Person-Centered Outcome Measures: Goal-Identification, Follow-Up, and Goal Achievement and MUC 2024-069 Addressing Social Needs Assessment & Intervention.