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Pre-Rulemaking Measure Review (PRMR)

The PRMR process supports consensus recommendations regarding the inclusion of measures under consideration (MUCs) in Centers for Medicare & Medicaid Services (CMS) quality reporting and value-based programs. 

There are three PRMR committees grouped by care setting: Hospital, Clinician, and Post-Acute Care/Long-Term Care (PAC/LTC). These committees consist of a diverse membership representing all facets of the health care system. PQM emphasizes the inclusion of patients/recipients of care, caregivers, patient advocates, and traditionally underrepresented groups in this process. 

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Measure Developers and Stewards

The Pre-Rulemaking Measure Review (PRMR) process is an annual initiative aimed at providing informed recommendations to the Department of Health and Human Services (HHS) Centers for Medicare & Medicaid Services (CMS) on the selection of quality and efficiency measures for select Medicare programs. As a measure developer or steward, your expertise is crucial to advancing health care quality. Here’s how you can engage in this process:

Select a step in the process timeline below to learn more.

Submit A MeasureRespond to QuestionsMeasure AssessmentEducation MeetingRespond to Public CommentsListening SessionRecommendation Group Meeting
  1. Submit Your Measures:
     
    • Initiate Submission: Begin by submitting your measures to the Measures Under Consideration (MUC) List via the MUC List Entry/Review Information Tool (MERIT) system by the posted deadline. This is your opportunity to demonstrate the suitability of your measures for CMS programs. For more information about submitting a measure for inclusion on the MUC List via MERIT, visit the MMS Hub Pre-Rulemaking webpage.
       
    • Provide Comprehensive Evidence: Add all necessary documentation and evidence in MERIT to demonstrate the effectiveness and relevance of your measures to the selected CMS program and target populations.
       
  2. Respond to Follow-Up Questions (August - October):
     
    • Prepare for Evaluation: From August to October, be ready to respond to detailed questions via email from Battelle staff regarding your submitted materials. This is your chance to clarify methodologies and data sources.
       
  3. Collaborate with Battelle on Measure Assessment (October - November):
     
    • Review Your Draft Preliminary Assessment (PA): To help PRMR committee members with their measure review, Battelle will develop a PA. Review the draft PA for your measure starting in late October, ensuring accuracy and relevance. Refine the assessment to highlight the value of your measures according to the PRMR criteria of meaningfulness, appropriateness of scale, and time-to-value realization. Final PAs will be shared publicly on the PQM website and used by the PRMR committee members to submit written feedback on your measure via Pre-meeting Initial Evaluation (PIE) Forms. More information is available in the Guidebook of Policies and Procedures for Pre-Rulemaking Measure Review (PRMR) and Measure Set Review (MSR).
       
  4. Attend the PRMR Measure Developer/Steward Education Meeting (December):
     
    • Learn About Our Process: Battelle will present an overview of measure review timelines, required tasks, and evaluation criteria. You'll also meet staff members who play pivotal roles in the process, offering direct access to expertise and support. This meeting is invaluable for deepening your understanding of the PRMR process and addressing any clarifying questions.
       
  5. Respond to Written Public Comments (Optional; December):
     
    • Use the PQM website to respond directly to public comments about your measure. While this is not mandatory, it is an opportunity to clarify or respond to questions or concerns about your measure.
       
  6. Attend Virtual Listening Sessions (December):
     
    • Attend a Listening Session: Join the meeting to hear live public comments about your measures. Measures are assigned to sessions based on the proposed CMS program, and you will receive details via email about which session to attend.
       
    • Answer Questions as Needed: While Listening Sessions are intended to collect spoken feedback from members of the public, you may receive a few direct questions about your measure. Be prepared to answer questions about your measure’s evidence base, development process, testing results, and suitability for the specific CMS program population of interest.
       
  7. Virtually Attend Recommendation Group Meetings (January):
     
    • Prepare for Questions: Prepare to address questions about your measure during recommendation group meetings in January. Review both spoken and written public comments and initial evaluations by committee members (i.e., PIE Forms), provided in advance by Battelle staff.
       
    • Respond to Inquiries: Give clear and concise answers to Recommendation Group Member questions. Be prepared to address any updates to your measure since initial MUC List submission and plans for measure implementation support if accepted into a CMS program. 


By participating in these activities, you contribute to the development of quality measures that are meaningful, impactful, and aligned with CMS program goals. Your involvement ensures PRMR committee members have a clear understanding of your measure prior to voting on recommendations for CMS program inclusion. 

Please review the Guidebook of Policies and Procedures for Pre-Rulemaking Measure (PRMR) and Measure Set Review (MSR) for even more details about the PRMR process and reach us at PQMSupport@battelle.org with any questions.