Rate of annual Kidney Health Evaluation among adults with diabetes and/or hypertension

Dear Members of the Endorsement and Maintenance (E&M) Committee:

Boehringer Ingelheim Pharmaceuticals, Inc. writes in support of endorsement of CBE #5611e, the Rate of Annual Kidney Health Evaluation among adults with diabetes and/or hypertension. We commend the National Kidney Foundation for advancing a measure that moves kidney care upstream—toward earlier identification of risk—and we support both the measure and its expansion to include adults with hypertension.

Boehringer Ingelheim is a biopharmaceutical company active in both human and animal health. As one of the industry’s top investors in research and development, the company focuses on developing innovative therapies that can improve and extend lives in areas of high unmet medical need. Independent since its foundation in 1885, Boehringer takes a long-term perspective, embedding sustainability along the entire value chain.

The expansion to hypertension closes a measurement gap that current measures leave open

Chronic kidney disease is common, costly, and largely silent: an estimated 90% of adults with CKD are unaware of their condition,¹ and the only way to detect it before irreversible loss of function is laboratory testing. A complete kidney health evaluation requires two tests together—a blood test to estimate glomerular filtration rate (eGFR) and a urine test for the albumin-to-creatinine ratio (uACR)—and rates of completing both remain low. Diabetes and hypertension are the two leading contributors to CKD,³ yet the existing endorsed measures—MIPS Quality ID #488 and the NCQA Kidney Health Evaluation for Patients with Diabetes (KED)—capture only the diabetes population.² Testing tends to be more complete among patients with diabetes, who benefit from these established measures and greater clinical awareness, while adults with hypertension—who are at comparably elevated risk³—remain outside existing accountability framework and are tested less often.

This gap is not theoretical. National data show that complete guideline-recommended kidney health testing (eGFR and uACR) is lowest precisely where this measure would extend—Medicare fee-for-service members with hypertension are tested least often (8.0%), compared with 59.6% for Medicare Advantage members with diabetes.^4,5 The 2025 multi-society AHA/ACC hypertension guideline now explicitly recommends uACR testing at the time of a hypertension diagnosis (COR 1),⁶ and the 2026 AHA/ACC/ADA/ASN cardiovascular-kidney-metabolic (CKM) syndrome guideline reaffirms annual eGFR and uACR assessment for adults in CKM stage 2 or higher (Class 1 recommendation),³ giving the expanded population a firm, current, and guideline-concordant basis. Importantly, when the National Kidney Foundation tested the measure, the share of patients who received both tests (the measure’s performance score) was similar for the hypertension and diabetes populations (23.6% vs. 24.7%),² indicating that adding hypertension extends accountability to an equally undertested, equally high-risk group without distorting how the measure scores performance.

Endorsement would align measurement across programs and make prevention a shared priority

The value of this measure grows through its synergistic alignment across programs and accountable entities. A common kidney-health evaluation specification—reported at the clinician level (MIPS and MIPS Value Pathways) and the health-plan level (HEDIS and Medicare Advantage Star Ratings),² and adopted as a quality-improvement target by CMS QIN-QIOs—lets providers, plans, and quality-improvement partners work toward the same evidence-based goal. That alignment reduces reporting burden and, more importantly, reinforces early detection as a core, system-wide priority of care. We encourage the E&M Committee to view endorsement as a step toward this national alignment in kidney health.

The measure performs well against the PQM evaluation rubric

Reviewed against the five PQM measure evaluation rubric domains, the submission is strong, and the areas that may invite discussion are readily addressable rather than reasons to withhold endorsement.

• Importance. The logic model and a current, multi-society guideline base—including KDIGO 2024,⁷ ADA 2026,⁸ the 2025 AHA/ACC hypertension guideline,⁶ and the 2026 AHA/ACC/ADA/ASN CKM syndrome guideline³—support a clear net benefit, paired with a demonstrated performance gap (mean clinician performance of roughly 25%, with group scores ranging from 14% to 35%).²
• Feasibility. As an electronic clinical quality measure (eCQM) built on the same data elements as the in-use #488 measure, feasibility is well established—23 of 30 data elements are captured in discrete, standardized fields—and implementation leverages existing workflows.² Testing was conducted within one health system on one EHR platform. This meets the Appendix H eCQM expectation for initial endorsement (feasibility and data-element testing within at least one vendor); the broader multi-site, multi-vendor expectation applies at maintenance.⁹ Endorsement now, with continued testing across additional vendors and settings through the maintenance cycle, is fully consistent with the guidance.
• Scientific Acceptability. Data-element validity is good to excellent across all critical elements (agreement 88–100%; kappa 0.73–1.00), and group-level reliability is high (mean 0.97).² Mean clinician-level reliability is 0.69, with 63% of entities at or above 0.6.² Appendix H4 of the E&M Guidebook is clear that this need not preclude endorsement: every entity exceeds 0.4; the National Kidney Foundation provided the recommended low- versus high-reliability diagnostic analysis; group-level reliability is 0.97; and, for a low-burden, low-harm process measure with no existing alternative for the hypertension population, the guidance recognizes that a usable measure is preferable to none.⁹ Reliability also improves directly with sample size and performance period, both of which are expected to strengthen as the measure is adopted at scale.
• Use, Usability, and Closing Care Gaps. The measure yields actionable information and is positioned for multiple accountability applications; the National Kidney Foundation’s subgroup analyses (by sex, race, payer, and clinic) exceed what the optional Closing Care Gaps domain requires for this initial endorsement.²

A call to align with national kidney health efforts

Endorsement of CBE #5611e would align the measurement enterprise with the direction of national clinical guidelines and public-health priorities, and would extend accountability to a high-risk population that current measures leave unmeasured. We respectfully encourage the E&M Committee to endorse the measure and, in doing so, to advance a consistent national standard for early kidney health evaluation.

Thank you for the opportunity to comment and for the E&M Committee’s continued work advancing high-quality, evidence-based, patient-centered care.

References

1. Centers for Disease Control and Prevention. Chronic Kidney Disease in the United States, 2023. Atlanta, GA: US Department of Health and Human Services, CDC; 2023.
2. National Kidney Foundation. Rate of Annual Kidney Health Evaluation Among Adults with Diabetes and/or Hypertension (CBE ID #5611e): Measure Submission Form. Partnership for Quality Measurement; Spring 2026.
3. 2026 AHA/ACC/ADA/ASN Guideline for the Prevention, Detection, Evaluation, and Management of Cardiovascular-Kidney-Metabolic Syndrome: A Report of the American College of Cardiology/American Heart Association Joint Committee on Clinical Practice Guidelines. J Am Coll Cardiol. 2026. doi:10.1016/j.jacc.2026.03.056.
4. United States Renal Data System. 2024 USRDS Annual Data Report: Epidemiology of Kidney Disease in the United States. Bethesda, MD: National Institutes of Health, NIDDK; 2024.
5. Stempniewicz N, Vassalotti JA, Cuddeback JK, et al. Chronic Kidney Disease Testing Among Primary Care Patients With Type 2 Diabetes Across 24 U.S. Health Care Organizations. Diabetes Care. 2021;44(9):2000-2009.
6. Jones DW, Ferdinand KC, et al. 2025 AHA/ACC/AANP/AAPA/ABC/ACCP/ACPM/AGS/AMA/ASPC/NMA/PCNA/SGIM Guideline for the Prevention, Detection, Evaluation and Management of High Blood Pressure in Adults. Circulation. 2025;152(11):e114-e218.
7. Stevens PE, Ahmed SB, Carrero JJ, et al. KDIGO 2024 Clinical Practice Guideline for the Evaluation and Management of Chronic Kidney Disease. Kidney Int. 2024;105(4S):S117-S314.
8. American Diabetes Association Professional Practice Committee. 11. Chronic Kidney Disease and Risk Management: Standards of Care in Diabetes—2026. Diabetes Care. 2025;49(Suppl 1):S246-S260.
9. Partnership for Quality Measurement. Endorsement and Maintenance Guidebook, Version 3.3. Columbus, OH: Battelle; March 2026. Appendices D and H.

The Renal Physicians Association (RPA) is the professional organization of nephrologists whose goals are to ensure optimal care under the highest standards of medical practice for patients with kidney disease and related disorders. RPA acts as the national representative for physicians engaged in the study and management of patients with kidney disease. RPA appreciates the opportunity to submit comments on the kidney related quality measures currently under review by the Partnership for Quality Measures.

RPA supports endorsement of the Rate of Annual Kidney Health Evaluation Among Adults with Diabetes and/or Hypertension measure (CBEID 5611e). This measure addresses a well-documented gap in the use of an annual kidney health evaluation for adults at high risk for chronic kidney disease due to its two leading causes, diabetes and hypertension.
 

CKD is a an underrecognized public health crisis affecting approximately 37 million adults in the United States. Because kidney disease often progresses silently and presents with few signs or symptoms until advanced stages, many individuals remain undiagnosed until irreversible damage has occurred. Adults with diabetes and hypertension are at particularly high risk for CKD and represent populations for whom timely screening and early intervention are critically important, as earlier identification of CKD creates an opportunity for earlier and more effective interventions, including lifestyle modification, risk factor management, and emerging therapies.

The American Medical Association (AMA) believes that a case minimum greater than 20 should be required when applying this measure at the individual clinician level as a part of endorsement. This minimum would ensure that the measure’s minimum reliability is close to 0.7, which is what we believe should be the standard for endorsed measures. 

Please find attached the American Kidney Fund’s formal letter supporting the endorsement of CBEID 5611e.
 

The Academy of Nutrition and Dietetics is writing to express our strong support for endorsement of the measure, Rate of Annual Kidney Health Evaluation Among Adults with Diabetes and/or Hypertension (CBEID 5611e). This measure addresses a well-documented gap in the use of an annual kidney health evaluation for adults at high risk for chronic kidney disease due to its two leading causes, diabetes and hypertension. Please see the attached letter for an ex[lanation of our position.

Please see attached comments

ASN expresses strong support for the endorsement of CBE 5611e: Rate of Annual Kidney Health Evaluation Among Adults with Diabetes and/or Hypertension This measure addresses a well-documented gap in the use of an annual kidney health evaluation for adults at high risk for chronic kidney disease (CKD) due to its two leading causes, diabetes and hypertension. 

CKD is an underrecognized public health crisis affecting approximately 37 million adults in the United States. Because kidney disease often progresses silently and presents with few signs or symptoms until advanced stages, many individuals remain undiagnosed until irreversible damage has occurred. Adults with diabetes and hypertension are at particularly high risk for CKD and represent populations for whom timely screening and early intervention are critically important, particularly with the emergence of multiple therapeutic agents, such as ACE inhibitors, angiotensin receptor blockers, and sodium glucose cotransporter 2 inhibitors (SGLT2is), that can slow CKD progression. 

Measure performance is based on the percentage of patients aged 18–85 years with a diagnosis of diabetes and/or hypertension who received both an eGFR and uACR during the measurement period. The measure reflects current clinical guideline recommendations by Kidney Disease Improving Global Outcomes (KDIGO), the American Heart Association (AHA) and American College of Cardiology (ACC), the National Kidney Foundation (NKF), and the American Diabetes Association (ADA). Assessment of eGFR and uACR in these populations is the foundation of earlier identification of CKD, more accurate staging and risk assessment, and timely implementation of interventions that can slow disease progression and reduce complications.

Importantly, endorsement of this measure would help drive greater accountability and consistency in kidney health screening practices across healthcare systems. Increased uptake of evidence-based kidney health evaluation will improve screening, encourage diagnosis, support gap closure in CKD detection and treatment, and lower long-term healthcare costs associated with cardiovascular complications and kidney failure. 

Please see comments from the Coalition for Kidney Health attached. 

Kind Regards, 

Miriam Godwin, on behalf of the Coalition for Kidney Health