Please complete this short form to comment on the recommendations for continued or discontinued use of the 35 Cost Effectiveness and Efficiency in Health Care Utilization measures in nine Centers for Medicare & Medicaid (CMS) programs.
These recommendations are based on written public comments and the robust discussions from the virtual 2024 MSR Recommendation Group meeting held on September 30 and October 1, 2024.
How to Submit a Written Public Comment
- Select the measure (ID and title) from the drop-down menu.
- Attach additional documents to provide context to your comments, as needed.
- To comment on additional measures, please complete a new form for each.
Please Note
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- There may be a brief delay between the submission of your comment and its appearance online, as all comments undergo a review process to ensure compliance with our community guidelines.
We appreciate your patience and understanding as we strive to maintain a respectful and engaging environment for everyone.
For additional information about the 2024 MSR Recommendation Group meeting, please also view the:
- MSR Recommendation Report
- MSR Recommendation Spreadsheet
- MSR Recommendation Group Meeting Summary
- Recordings from the two-day meeting (Day 1; Day 2).
To learn more about the MSR process, please see the Guidebook of Policies and Procedures for Pre-Rulemaking Measure Review and Measure Set Review.
Comments
Type of care given upon discharge to community to combat frailty
Upon discharge post acute care by the home health services or LTC facility should use evidence base therapies to combat progression of frailty, social isolation and loneliness also, show measures such as "what matters most" and "comfortability of program" input along with, evidence base therapies performance over a six-to-twelve-week period.
Support for continued use of Adult Sinusitis measure in MIPS
EDPMA appreciates and supports the committee's recommendation for the continued use of the Adult Sinusitis: Antibiotic Prescribed for Acute Viral Sinusitis measure in MIPS.
As we noted in earlier comments, this measure currently has a benchmark, which demonstrates that it is commonly reported by MIPS participants. Unlike many other measures in the MIPS inventory, #331 also does not have topped out performance according to the 2024 MIPS historic benchmarks, which suggests that gaps in performance still exist in terms of antibiotic prescribing for acute viral sinusitis. Additionally, CMS recently included this measure in the Adopting Best Practices and Promoting Patient Safety within Emergency Medicine MIPS Value Pathways (MVP). CMS has clearly stated its intent to eventually move all MIPS participants into MVPs and to retire traditional MIPS. With MVPs being CMS’ preferred future participation pathway, it is important that CMS preserve this measure as an option for MVP reporting. Overall, this measure targets the important goal of ensuring appropriate use of antibiotics and based on existing benchmarks, it is clear there is still room for performance improvement. Thank you for considering our comments.
Support for ED Use of CT for Minor Blunt Head Trauma measure
The EDPMA appreciates and supports the committee's recommendation to maintain both the ED Use of CT for Minor Blunt Head Trauma for Patients Aged 18 Years and Older measure and the ED Use of CT for Minor Blunt Head Trauma for Patients Aged 2 Through 17 Years measure in MIPS. As we noted earlier, these measures have historic performance benchmarks in 2024, indicating wide use among MIPS participants. Both measures are also included in the Emergency Medicine MVP, demonstrating that CMS continues to find value in these measures and envisions them playing an important role in the future of the program.
Emergency medicine practices face unique challenges when it comes to MIPS compliance. They manage a wide range of often unpredictable clinical scenarios and disparate patient populations. They also struggle with data capture due to a lack of control over the facility’s EHR system, which limits their reporting options and poses challenges in regard to QCDR participation. Overall, if CMS wants to incentivize movement towards MVPs, then it must ensure that a diverse set of quality measures are available so that practices of all sizes and levels of resource can take advantage of this new, more streamlined reporting pathway. Thank you for your consideration of our comments.
MRI Lumbar Spine for Low Back Pain
To the Partnership for Quality Measurement Measure Set Review Committee:
On behalf of over 39,000 orthopaedic surgeons and residents represented by the American Association of Orthopaedic Surgeons (AAOS), we appreciate that the Center for Medicare & Medicaid Services (CMS) and the Partnership for Quality Measurement’s Measure Set Review Committee (MSR Committee) have aligned in their decision to remove 00453-01-C-HOQR “MRI Lumbar Spine for Low Back Pain” from the Hospital Outpatient Quality Reporting (HOQR) Program. Please see the attached letter for our complete comments.