Comments
No Patient representative on MSR from PAC LTC
I appreciate the inclusion of patients from the Clinician and Hospital Advisory Groups though there are no PAC LTC patients represented in this draft roster. ( seems this might be important to add bringing the Pt perspective from the PAC LTC) 2 Pts from Clinician PRMR and 1 from Hospital PRMR Thank you for noting
Representation from developers of important therapies
Johnson & Johnson notes that there is no industry representation on any of the committees for PRMR or MSR. The biopharmaceutical stakeholder group is a key component of the quality and value discussion, one that up to now it has been considered inappropriate to omit. Biopharmaceutical companies were included when the prerulemaking function was established and it throughout the decade of its existence, and it is concerning to see them removed now. While disappointed that J&J was not selected to participate, it is disconcerting that there is no representation of qualified individuals from our industry to speak of at all across the committees. J&J asks for clarification on why this critical part of our healthcare ecosystem has been excluded from the process and encourages Battelle and CMS not to depart from including a critical stakeholder group from being able to contribute to this important conversation.
Representative of Patient Advocates or Advisors on MSR Committee
The representation on the MSR committee for patient advocates or advisors are less than on the other rosters and the other rosters aren’t represented equally. There are two from the clinicians roster, one from the hospital roster, and zero from the PAC-LTC roster. If the patient’s voice is critical to the whole process, than this committee should probably have two patients from each group. If you need another person from the hospital roster to be on the MSRcommittee, I am offering to do that in order to create equity. I have spoken to one person on the PAC-LTC roster, who also thinks this committee should be more balanced when it comes to the patient’s voice from the other rosters. Thank you for taking my comment into consideration.
Surgeon Representation on Sr Committees
The list of the nominees is distinguished for this MSR committee, but the list does not seem detailed enough to demonstrate whether there are significant surgeon representation. There are many ongoing efforts to document surgical quality (Metabolic & Bariatric Surgery Accreditation & Quality Improvement Program (MBSAQIP), National Surgical Quality Improvement Program (NSQIP), Emergency General Surgery (EGS) verification program, Geriatric Surgery Verification (GSV) Program, multiple state quality collaboratives). But none of these programs appear to have significant representation with quality measures at a national level that encourage hospital leadership to support vigorously these quality efforts.
Nephrology & non-surgeon physicians are represented at the national level on this committee.
But the US generates for the elective inpatient & outpatient surgical procedures approximately $195 bil - $212 bil in hospital reimbursement & approximately $48 - $64.8 bil in hospital net income per year. CMS MIPS/ MVP only account for a fraction of these surgical procedures. Shouldn’t PQM’s MSR have at least one surgeon representation to help improve the quality for this significant revenue so that the focus can be moved toward quality instead of by volume?
We are delighted to have at least one surgeon representative nominated to the Management of Acute Events, Chronic Disease, Surgery, Behavioral Health Committee, especially representation from an expert who know what measures work (tracking controllable events that affect Surgical Site Infections (SSIs), e.g. timing of preop antibiotics, euglycemia, normothermia…) vs those measures that do not work (e.g. tracking all SSIs without risk adjustment).” But will there be any loss in translation or advocacy routing in between committees as proposed or modified measures pass through?”