Guidebook of Policies and Procedures for PRMR and MSR

The Federation of American Hospitals (FAH) appreciates the opportunity to comment on the Partnership for Quality Measurement (PQM) Guidebook of Policies and Procedures for Pre-Rulemaking Measure Review (PRMR) and Measure Set Review (MSR). We support the PQM’s  efforts to ensure that consensus is achieved through the design of the committees and public comment as well as the revised evaluation criteria. Our following comments are intended to further improve the process. 

We are very concerned that Recommendation Groups’ discussions will be facilitated by the PQM staff and request that this process leverage the expertise of co-chairs. Facilitation of the meetings by staff has at a minimum the perception of bias since they are operating under contract with the Center for Medicare and Medicaid Services (CMS) and it does not reflect the intent of the law where the input is intended to represent key stakeholders. In addition, co-chairs are able to bring real-life perspectives on implementation and other challenges around the proposed measures, would be better able to navigate the politics, and ensure that the processes are smooth. 

The FAH believes that public input on the Recommendation Group’s final PRMR recommendations to the CMS is necessary and ask that the PQM add a brief comment period on the Recommendation Group’s deliberations prior to submitting the final recommendations to CMS. Given the revised process with the Advisory and Recommendation Groups and higher consensus threshold, conducting a comment period during which external stakeholders can provide input on the recommendations will enable the PQM to evaluate whether the Recommendation Group’s composition sufficiently reflected the viewpoints of the key stakeholder groups. It will also allow one final opportunity for groups to change their support (or lack thereof) based on any additional materials or discussions and provide additional context to the PQM and CMS on whether the process operated as expected. 

While we understand that the timeframe for the PRMR must meet statutory requirements and cannot be modified, we request that the PQM reconsider the proposed timeline for the MSR. Based on Figure 7 on page 21, it appears that the measures that are proposed to be removed will be released for comment at the same time as when the Inpatient Prospective Payment System (IPPS) and other proposed rules are typically posted. While the public has a second opportunity to comment, that period is scheduled for July and August – the same time as when the Physician Fee Schedule and other proposed rules are made available. The timelines released for the Fall and Spring cycles for the revised endorsement process also overlap with these months, leading to a significant burden for external stakeholders. We are extremely concerned that these overlapping comment periods will lead to reduced public input on one or more of these activities and urge the PQM to change the timing of the MSR and endorsement comment periods to avoid the months when proposed rules are also released.  

Lastly, while it is our hope that this revised process is successful, as with any redesigned process there will be the need to evaluate and refine the structure, criteria, and/or steps over time. We request that the PQM commit to an initial evaluation after the first or second year of implementation and ongoing re-evaluations of the process. These evaluations should be comprehensive including whether the Novel Hybrid Delphi and Nominal Group (NHDNG) technique and structure of the Advisory Group and/or Recommendation Group successfully achieve the desired goal of consensus-driven recommendations. Examples of what could be examined are whether the composition of the Recommendation Group for PRMR and MSR are representative of the key stakeholders to which the measures are most relevant and did the final recommendations reflect the collective input from public comments in addition to the committees. Some of these questions may be more relevant to track over time since membership of the Recommendation Group will change every year and consistency in the recommendations will be critical to ensure buy-in in the process. In addition, these evaluations should include opportunities for the public to provide reactions and recommendations on changes.

Thank you for the opportunity to comment. 

The Federation of American Hospitals (FAH) appreciates the opportunity to comment on the Partnership for Quality Measurement (PQM) Guidebook of Policies and Procedures for Pre-Rulemaking Measure Review (PRMR) and Measure Set Review (MSR). We support the PQM’s  efforts to ensure that consensus is achieved through the design of the committees and public comment as well as the revised evaluation criteria. Our following comments are intended to further improve the process. 
We are very concerned that Recommendation Groups’ discussions will be facilitated by the PQM staff and request that this process leverage the expertise of co-chairs. Facilitation of the meetings by staff has at a minimum the perception of bias since they are operating under contract with the Center for Medicare and Medicaid Services (CMS) and it does not reflect the intent of the law where the input is intended to represent key stakeholders. In addition, co-chairs are able to bring real-life perspectives on implementation and other challenges around the proposed measures, would be better able to navigate the politics, and ensure that the processes are smooth. 
The FAH believes that public input on the Recommendation Group’s final PRMR recommendations to the CMS is necessary and ask that the PQM add a brief comment period on the Recommendation Group’s deliberations prior to submitting the final recommendations to CMS. Given the revised process with the Advisory and Recommendation Groups and higher consensus threshold, conducting a comment period during which external stakeholders can provide input on the recommendations will enable the PQM to evaluate whether the Recommendation Group’s composition sufficiently reflected the viewpoints of the key stakeholder groups. It will also allow one final opportunity for groups to change their support (or lack thereof) based on any additional materials or discussions and provide additional context to the PQM and CMS on whether the process operated as expected. 
While we understand that the timeframe for the PRMR must meet statutory requirements and cannot be modified, we request that the PQM reconsider the proposed timeline for the MSR. Based on Figure 7 on page 21, it appears that the measures that are proposed to be removed will be released for comment at the same time as when the Inpatient Prospective Payment System (IPPS) and other proposed rules are typically posted. While the public has a second opportunity to comment, that period is scheduled for July and August – the same time as when the Physician Fee Schedule and other proposed rules are made available. The timelines released for the Fall and Spring cycles for the revised endorsement process also overlap with these months, leading to a significant burden for external stakeholders. We are extremely concerned that these overlapping comment periods will lead to reduced public input on one or more of these activities and urge the PQM to change the timing of the MSR and endorsement comment periods to avoid the months when proposed rules are also released.  
Lastly, while it is our hope that this revised process is successful, as with any redesigned process there will be the need to evaluate and refine the structure, criteria, and/or steps over time. We request that the PQM commit to an initial evaluation after the first or second year of implementation and ongoing re-evaluations of the process. These evaluations should be comprehensive including whether the Novel Hybrid Delphi and Nominal Group (NHDNG) technique and structure of the Advisory Group and/or Recommendation Group successfully achieve the desired goal of consensus-driven recommendations. Examples of what could be examined are whether the composition of the Recommendation Group for PRMR and MSR are representative of the key stakeholders to which the measures are most relevant and did the final recommendations reflect the collective input from public comments in addition to the committees. Some of these questions may be more relevant to track over time since membership of the Recommendation Group will change every year and consistency in the recommendations will be critical to ensure buy-in in the process. In addition, these evaluations should include opportunities for the public to provide reactions and recommendations on changes.
Thank you for the opportunity to comment.