2024 Draft PRMR Committee Rosters

The American College of Physicians (ACP) appreciates the opportunity to comment on the proposed Pre-Rulemaking Measure Review (PRMR) Clinician Roster for the 2024-2025 term year. 

The College is the largest medical specialty organization and the second-largest physician group in the United States. ACP members include 161,000 internal medicine physicians, related subspecialists, and medical students. The College is dedicated to improving the quality of patient care and has been actively engaged in the performance measurement arena, including participation in several consensus-based endorsement committees over the past two decades.

Although the College submitted an organizational nominee, we were disappointed to see that our organization was not included on the PRMR Clinician Roster for the 2024-2025 term year. ACP was pleased to see that representatives from our subspecialties have been included on the roster. However, in reviewing the proposed roster, only three out of fifty-nine members are organizational representatives of Internal Medicine subspecialties, specifically hospital medicine, geriatric medicine, and cardiology. Moreover, the College is concerned that the Clinician Roster does not include a representative from the specialty at large. 

The PRMR Clinician Committee plays a vital role in reviewing and recommending measures used to evaluate clinician performance for use in federal programs. As a result, we believe it is extremely important to have those who will be measured as part of these critical discussions. The College worries that not having enough clinician voices, particularly organizations such as ours that represent a large number of physicians, will hinder progress to engage all relevant stakeholders in the decision-making process. 

ACP strongly urges the Partnership for Quality Measurement to reconsider ACP’s organizational membership on the PRMR Clinician Committee.

The National Association of State Mental Health Program Director’s Research Institute (NRI) was actively involved in the development of the first Hospital Based Inpatient Psychiatric Services (HBIPS) core measure test set. NRI’s-Performance Quality Improvement (PQI) Division, led by Dr. Glorimar Ortiz, PhD, MS, has expanded the Behavioral Healthcare Performance Measurement System (BHPMS) from helping state and private free-standing psychiatric facilities meet their data reporting requirements to offering support and resources that allow facilities to understand the intent of  quality measures and how to use their data to guide policy and clinical practices, enhancing the quality of the care provided and directing their continuous improvement efforts.  A part of this initiative includes the NRI Technical Workgroup (TWG) which provides members the opportunity to represent state and facility experiences in matters related to performance measures. 

The TWG appreciates the opportunity to provide comment related to the PRMR Committee roster. TWG members review changes in external data reporting requirements and consider the impact those changes have on facilities.  The TWG provides input that influences the work of NRI-PQI and the resources that are offered to the nearly 200 facilities that participate in the BHPMS. The appointment of Dr. Ortiz, a biostatistician with extensive knowledge from inpatient psychiatric facilities about the implementation of performance measures, the collection of quality data, and data reporting will impact both providers and future health outcomes,  is enthusiastically supported by the members of the NRI-PQI TWG as this will allow an often-underserved population to have input into the measure development process.