ePC-07 Severe Obstetric Complications (3687e)

Remove the COVID exclusion: there is nothing scientific to support excluding only COVID among all the possible conditions, infections, and diagnoses.  

Please see the attached comments and feedback from the American College of Obstetricians and Gynecologists.

Bayer US (“Bayer”) appreciates the opportunity to submit comments pertaining to the proposed endorsement of this measure. 

Bayer is a global enterprise with core competencies in the Life Science fields of health care and agriculture with nearly 25,000 employees in 300 sites across the United States. Our products and services are designed to benefit people and improve their quality of life. At the same time, we aim to create value through innovation and are committed to the principles of sustainable development and to our social and ethical responsibilities as a corporate citizen.

Bayer is committed to improving patient outcomes and advancing health by closing gaps in care. We recognize the importance of value-based care and quality measurement and are pleased to submit feedback in response to Battelle’s open comment period on the Spring 2023 measure endorsement cycle.

Bayer supports the endorsement of the Severe Obstetric Complications measure to increase quality of care for maternal health and women’s health in general. In 2021, 1,205 women in the US died of maternal causes, a rate of 32.9 deaths per 100,000 live births. ¹ This rate has been increasing and highlights a need to focus on improving obstetric care. 

The maternal mortality rate for Black women in the US is 2.6 times the rate for non-Hispanic White women. ¹ We recommend that the risk adjustment used in this measure helps to advance health equity and does not contribute to disparities in care (e.g., inappropriately adjusting on race/ethnicity). Additionally, we would recommend the stratification of this measure by race and ethnicity as a first step to reducing disparities in maternal health care and outcomes.

¹ CDC. Maternal Mortality Rates in the United States, 2021. https://www.cdc.gov/nchs/data/hestat/maternal-mortality/2021/maternal-mortality-rates-2021.htm. Accessed June 1, 2023.