PRMR MUC List

MUC2024-052 - Social Need Screening and Intervention

Please see the attached comment letter.

On behalf of its member organizations, the Alliance for Person-Centered Care (the Alliance) appreciates the opportunity to comment on several of the measures on the Centers for Medicare & Medicaid Services’ (CMS) 2024 Measures Under Consideration (MUC) list. The Alliance and its member organizations are specifically commenting on the several patient-reported outcome performance measures (PRO-PMs) that are under consideration for CMS quality reporting programs. 

Please see the attached letter for our comments on these measures.

Reinvestment Partners strongly supports MUC2024-052, the Social Need Screening and Intervention
Measure. The systematic health-related social needs screening required by this measure is essential to
ensure that health plans are accountable for both identifying members with the greatest social risk and
ensuring those members secure an appropriate intervention, including relevant SDOH supplemental
benefits, connections to community resources, and/or enrollment in SNAP, WIC, LIHEAP, and other
programs.

We further support the future inclusion of utilities insecurity and include interpersonal/violence safety
screening and intervention rate to the SNS-E measure, given evidence found of the association between
utility insecurity and health outcomes and interpersonal safety’s direct association with injury,
psychological distress, and death in all age groups.
Thank you for your consideration of this comment.

Please see attached

PFPS US strongly supports the CMS strategy of using structural measures to advance patient safety and health equity.  They complement outcomes and process measures by actively and substantively engaging leadership and governance boards of health care organizations (HCOs) in addressing the stubborn challenges front line providers face in ensuring safe, equitable care for all.  Patients have the right to expect that safe care and reduction in outcomes disparities are leadership priorities. We also believe that frontline providers, who increasingly report experiencing burnout, deserve to practice in settings where patient safety and health equity improvement work is adequately resourced. The attestations of organizational leaders called for in the Patient Safety Structural Measure (PSSM), as well as other structural measures introduced by CMS in recent years, reinforces the importance of organizational support for the frontline.  Public reporting of structural measure scores have the potential to simultaneously inform HCO leaders about opportunities for improvement and  better inform patient decision-making about the priorities of HCOs we use or consider using to meet our healthcare needs.

PFPS US supports the proposed additional attestations to PSSM Domain 2. 

PFPS US supports the proposed plans to modify the existing version of this measures in CMS quality reporting programs to include reporting of MA data to help ensure that quality measurement is tracked across all Medicare beneficiaries and not just the fee-for-service population. The additional data reported on MA patients has great potential to help policy makers, providers, patients and family caregivers assess differences in benefits, risks and outcomes experienced by beneficiaries covered by these different payment models, and therefore, fuel learning and continuous improvement.  

PFPS US supports the proposed plans to modify the existing version of this measure in CMS quality reporting programs to include reporting of MA data to help ensure that quality measurement is tracked across all Medicare beneficiaries and not just the fee-for-service population. The additional data reported on MA patients has great potential to help policy makers, providers, patients and family caregivers assess differences in benefits, risks and outcomes experienced by beneficiaries covered by these different payment models, and therefore, fuel learning and continuous improvement.  

Please see my attached comments. I recommend withdrawing this measure at this time until the identified issues can be remedied.  

PFPS US supports the proposed plans to modify the existing version of this measure in CMS quality reporting programs to include reporting of MA data to help ensure that quality measurement is tracked across all Medicare beneficiaries and not just the fee-for-service population. The additional data reported on MA patients has great potential to help policy makers, providers, patients and family caregivers assess differences in benefits, risks and outcomes experienced by beneficiaries covered by these different payment models, and therefore, fuel learning and continuous improvement.  

PFPS US supports the proposed plans to modify the existing version of this measuresin CMS quality reporting programs to include reporting of MA data to help ensure that quality measurement is tracked across all Medicare beneficiaries and not just the fee-for-service population. The additional data reported on MA patients has great potential to help policy makers, providers, patients and family caregivers assess differences in benefits, risks and outcomes experienced by beneficiaries covered by these different payment models, and therefore, fuel learning and continuous improvement.  

The American Geriatrics Society (AGS) does not support the Cancer Health Equity Screening and Counseling Patient-Reported Outcome-Based Measure (PRO-PM) as currently structured for inclusion in the Merit-based Incentive Payment System (MIPS) due to the following concerns: 

1. The target population of patients aged 21 to 84 is inappropriate as this range does not match the recommended screening age for each of the types of cancers (e.g., recommendation for breast cancer to age 75, cervical cancer to age 65). 
2. It is unclear how specific screenings will be managed for those who do not meet the criteria. 
3. The survey asks whether the clinician explained why it is important to get cancer screening which assumes that getting screened is always appropriate though that is not universally true in older adults and guidelines recommend individualized decision-making. 

AGS believes it would be helpful to include more neutral language around the benefits and downsides of screening as well as the reasons for consideration for cancer screening as well as not getting screened.  

PFPS US supports the proposed plans to modify the existing version of this measuresin CMS quality reporting programs to include reporting of MA data to help ensure that quality measurement is tracked across all Medicare beneficiaries and not just the fee-for-service population. The additional data reported on MA patients has great potential to help policy makers, providers, patients and family caregivers assess differences in benefits, risks and outcomes experienced by beneficiaries covered by these different payment models, and therefore, fuel learning and continuous improvement.  

The American Geriatrics Society (AGS) is supportive of the Breast Cancer Screening measure. We believe this measure strives to incentivize more cost-effective imaging modalities and discourages excessive and frequent follow-up that may not be needed.

PFPS US supports the proposed plans to modify the existing version of this measuresin CMS quality reporting programs to include reporting of MA data to help ensure that quality measurement is tracked across all Medicare beneficiaries and not just the fee-for-service population. The additional data reported on MA patients has great potential to help policy makers, providers, patients and family caregivers assess differences in benefits, risks and outcomes experienced by beneficiaries covered by these different payment models, and therefore, fuel learning and continuous improvement.  

PFPS US supports the proposed plans to modify the existing version of this measuresin CMS quality reporting programs to include reporting of MA data to help ensure that quality measurement is tracked across all Medicare beneficiaries and not just the fee-for-service population. The additional data reported on MA patients has great potential to help policy makers, providers, patients and family caregivers assess differences in benefits, risks and outcomes experienced by beneficiaries covered by these different payment models, and therefore, fuel learning and continuous improvement.  

The American Geriatrics Society (AGS) is generally supportive of a quality measure that focuses on the importance of implementing a care plan for falls. We are concerned that while a fall may oftentimes be documented, there is no action taken (e.g., referral to physical therapy (PT) / occupational therapy (OT)). We recommend considering the following for the Patient Reported Falls and Plan of Care measure before implementation:

1. The older adult patient population is likely to have “recurrent fallers” and eventually there is likely to be diminishing or no return on PT/OT or gait and balance training, particularly as patients become frail. How will this measure handle patients with recurrent/frequent falls? 
2. Patients with more advanced dementia or severe frailty may be unable to participate meaningfully in therapy or exercise, and referrals in those patients would be inappropriate. 
3. Home safety evaluation should be considered an adjunct to PT/OT referral and gait and balance training. A care plan for falls that includes only a home safety evaluation without therapy or gait and balance training may be incomplete.

PFPS US supports the proposed plans to modify the existing version of this measuresin CMS quality reporting programs to include reporting of MA data to help ensure that quality measurement is tracked across all Medicare beneficiaries and not just the fee-for-service population. The additional data reported on MA patients has great potential to help policy makers, providers, patients and family caregivers assess differences in benefits, risks and outcomes experienced by beneficiaries covered by these different payment models, and therefore, fuel learning and continuous improvement.  

PFPS US supports the proposed plans to modify the existing version of this measure in CMS quality reporting programs to include reporting of MA data to help ensure that quality measurement is tracked across all Medicare beneficiaries and not just the fee-for-service population. The additional data reported on MA patients has great potential to help policy makers, providers, patients and family caregivers assess differences in benefits, risks and outcomes experienced by beneficiaries covered by these different payment models, and therefore, fuel learning and continuous improvement. 

The American Geriatrics Society (AGS) supports measuring and tracking quality of life. However, we have concerns about holding providers on maintaining or improving quality of life particularly as a focus on improving quality of life may not entirely be aligned with patient-specific goals of care. As an example, patients may opt for disease-modifying treatments or therapies that, in some ways, negatively impact their quality of life, which may be the case with some cancer treatments/therapies.

The American Geriatrics Society (AGS) agrees with the goal of timely diagnosis of venous thromboembolism. However, we believe that the measure as currently constructed would encourage a significant number of additional workups (i.e., D-dimer test, lower extremity ultrasonography for low-risk patients). If this measure is implemented, AGS recommends a balancing measure that examines the rates of positivity of common venous thromboembolism tests, such as the D-dimer test and lower extremity ultrasonography, in order to incentivize clinicians to have a high-index of suspicion for venous thromboembolism without indiscriminately ordering very low yield tests.

PFPS US supports expansion of this measure, already used in other CMS quality reporting programs, for implementation in the Rural Emergency Hospital Quality Reporting Program.  We believe it has the potential to reduce the spread of flu and reduce morbidity and mortality related to flu infection among patients who use Rural Emergency Hospitals.

PFPS US strongly supports CMS efforts to continuously improve the meaningfulness and useability  of Consumer Assessment of Providers and Systems (CAHPS) surveys.  We believe they can provide valuable feedback to fuel improvement that is not available from incident reporting systems.  It is important in our view that the questions included in the surveys address issues that matter to patients.  PFPS US is active in this space, now currently developing Project PIVOT (Patients Involved in deVeloping Outcomes Together), which is engaging diverse patients  and patient organizations in an iterative effort of prioritizing what they would most like to report to providers about patient safety, diagnostic excellence, bias or discrimination they experience as users of healthcare, and transparency of information shared with us.

Accordingly, we appreciate the process that CMS followed in engaging patients in the proposed revision of the existing In-Center Hemodialysis CAHPS Survey that reduces the number of questions asked based on what patients have prioritized.  By reducing the number of questions, the time burden in completing the survey is reduced. PFPS US further appreciates that the revised ICH CAHPS Survey will be offered in five languages, English, Spanish, Chinese (simplified and traditional), and Samoanm and that it will be implemented in multiple modes, i.e. Mail-Only, Telephone-Only, or Mixed Mode (mail plus telephone). These are all good steps in the right direction toward achieving CMS National Quality Strategy of fostering patient engagement to improve quality and health equity.

We urge CMS to continue to monitor and adjust CAHPS surveys across all healthcare settings to enable patients to report what matters most to them.

While the American Geriatrics Society (AGS) supports the Parkinson’s Syndromes, Multiple Sclerosis (MS), and Amyotrophic Lateral Sclerosis (ALS) measure if the expected costs can be calculated fairly, we are concerned that clinics who care for patients with more severe Parkinson’s/MS/ALS will be penalized due to the likelihood of higher costs in the severe cases. 

The American Geriatrics Society (AGS) appreciates that the Person-Centered Outcome Measures: Goal-Identification, Follow-Up, and Goal Achievement marks a shift from traditional Patient-Reported Outcome Measures (PROMs) applied to specific diagnosis-related groups toward a broader, patient-centered approach for individuals with complex conditions. While it represents a critical step in advancing goal-concurrent care, there are important considerations that need to be addressed in ensuring healthcare aligns with what matters most to patients so that the measure is successful and applied in a meaningful way.  

One challenge is the limited customization of PROMs. While well-defined, these measures often do not reflect patient-specific priorities or are rooted in one specific diagnosis such as the Geriatric Anxiety Scale (anxiety) or Patient Health Questionnaire (depression). Standardized tools may miss nuances, such as an individual’s desire to enjoy family meals on Sundays for one hour, which could be a central factor in their quality of life. Although the evidence base supports the inclusion of PROMs to measure patient-centered outcomes, enhancements are needed to make them more adaptable at the individual level and reflective of personal and cultural values. 

Goal Attainment Scaling introduces additional complexities as its success relies heavily on appropriate training and the development of measurable, and time-bound person-centered goals. Goals must be specific, actionable, and closely tied to the patient’s values. They must also be realistic in the context of the health conditions of the individual, tradeoffs, and the patient's (or caregiver’s) preferences in care. For example, the aspiration to “live longer” does not provide the specificity required for meaningful care planning, whereas “reduce my pain so I can enjoy Sunday meals with my family” offers a targeted and measurable outcome. Without criteria to assess the quality of these goals, the measure risks being unreliable. It is essential to establish standards that ensure goals align with patient priorities and provide valid data for evaluation. Additionally, meeting clinical benchmarks (e.g., goal to survive six months) may not appropriately reflect quality of care if it fails to align with the patient’s broader priorities or values.

To further complicate Goal Attainment Scaling, goals must remain flexible to account for life changes or acute medical events which can be common in this population. For instance, a patient who previously enjoyed nature walks might adapt their goal to enjoying nature in the courtyard with their home health aide after a stroke. Accommodating such transitions is essential to maintaining the integrity and relevance of goal-concurrent care and noting success rates appropriately.

Another consideration is the complexity of patient goals, particularly for those with chronic or progressive conditions. For some, the primary objective may not be improvement but maintaining their current state or delaying decline. As an example, a patient with Parkinson’s disease may prioritize “not worsening quickly and maintaining as much function as possible; being able to cook for themselves daily; and walking in their community at least three times a week for 20 minutes,” which reflects their personal trade-offs and life circumstances over time. 

AGS believes that conducting internal audits during initial implementation would ensure the measure’s meaningful application. Reviewing a percentage of charts to assess whether goals meet quality standards and reflect patient priorities, including values and preferences in care, would enable identification of strengths and gaps, ensuring that the measure genuinely aligns care with what matters most to patients. Transparent reporting of these findings would also help validate the measure’s effectiveness and build trust in its outcomes.

It is important to have clear frameworks for assessing goal quality and the impact of care for the measure to be a transformative tool. Its success requires both the healthcare system’s ability to align care with patient priorities while reliably measuring the effect of that alignment. By addressing these challenges, the measure can provide an excellent foundation for aligning care with what truly matters to patients.

PFPS US strongly supports CMS efforts to expand the use of patient-reported outcomes measures in CMS quality reporting programs in all settings, especially  Ambulatory Surgical Centers (ASCs) where few measures apply.  Accordingly, we support implementation of this measure, currently implemented in the Hospital Outpatient Quality Reporting Program, which collects information from patients via a web-based survey on the clarity of their  discharge instructions after a procedure in an ASC.  As more and more patients undergo surgery in ambulatory settings, so does the need for appropriate safety and quality measurement increase.

PFPS US fully supports extrapolating this measure, from the Prospective Payment System- (PPS-) Exempt Cancer Hospital (PCH) Reporting Program where they are currently used, to also apply to the treatment of cancer patients in general hospitals, inpatient and outpatient.  The same measures should apply in all facilities where cancer patients are treated, not just those dedicated specifically to the treatment of cancer.

PFPS US fully supports extrapolating this measure, from the Prospective Payment System- (PPS-) Exempt Cancer Hospital (PCH) Reporting Program where they are currently used, to also apply to the treatment of cancer patients in general hospitals, inpatient and outpatient.  The same measures should apply in all facilities where cancer patients are treated, not just those dedicated specifically to the treatment of cancer.

PFPS US fully supports extrapolating this measure, from the Prospective Payment System- (PPS-) Exempt Cancer Hospital (PCH) Reporting Program where they are currently used, to also apply to the treatment of cancer patients in general hospitals, inpatient and outpatient.  The same measures should apply in all facilities where cancer patients are treated, not just those dedicated specifically to the treatment of cancer.

PFPS US supports this proposed measure, which addresses unmet social needs related to food, housing, transportation, and utilities and tracks  whether the patient received a follow-up intervention during the visit, such as assistance, evaluation of eligibility for assistance, education, counseling, referral or coordination of care, among others. We are pleased to see this measure proposed as an eCQM, consistent with the CMS commitment to reduce reporting burden by advancing electronic measurement.

PFPS US encourages CMS to continue to expand its efforts on health equity to include other Health Related Social Needs, including disability, behavioral health status and gaps in employment or available support from family caregivers.

PFPS US supports this measure, which addresses the timing of administrating pain medication for patients with Sickle Cell Disease presenting in the ED. Implementation of this measure has the potential to reduce acute patient suffering and reduce hospital admission rates for SCD patients, a subpopulation challenged by racial and socioeconomic inequities.  Although there are established guidelines for the management of pain for patients in the ED, the data suggests that the average time for administering medication to patients with SCD experiencing pain is significantly longer than recommended in the guidelines, and delays in treatment contributes to poor outcomes. This suggests a potential for improvement not only in the timeliness of care but in the disparity of outcomes.

 PFPS US supports this EcQM, an outcome measure that tracks bleeding events in hospital inpatient settings following anticoagulant medication during the same patient encounter.  These are serious Adverse Drug Events (ADEs) that can lead to poor outcomes, including death.  Research shows that bleeding events associated with anticoagulants and thrombolytics are preventable through monitoring and careful dosing of these medications.

PFPS US supports this measure as an important step forward toward the goal of zero preventable harm set forth in the CMS National Quality Strategy.  We commend the measure developers for including multiple patient representatives on the Technical Expert Panel they convened, who confirmed that this measure is meaningful and important to patients and their families.

PFPS US strongly supports this measure, which addresses the crisis in patient safety, quality of care and timeliness of care in the EDs of general hospitals.. Long ED wait times and ED boarding and crowding are associated with increases in mortality, delays in care, preventable errors, poor patient experience, and staff burnout. There are also disparities in ED boarding, with people of color and behavioral health patients experiencing longer boarding times than other patient populations.  Yet there are no national metrics to assess the proportion of patients impacted by delays in timely ED care.

If implemented, it will capture the proportion of ED visits where patients experience any of these gaps in access to care: 1) Waits longer than 1 hour to be placed in a treatment room or dedicated treatment area that allows for history-taking and physical examination, or 2 ) Being left in the ED without being evaluated by a doctor or qualified nurse, or 3) ED boarding times that exceed 4 hours, or 4) ED lengths of stay longer than 8 hours. PFPS US supports these measures because of their reasonableness, meaningfulness, and practicality.

PFPS US strongly supports the intent of this measure, which addresses the crisis in patient safety, quality of care and timeliness of care in the EDs of Rural Emergency Hospitals. Long ED wait times and ED boarding and crowding are associated with increases in mortality, delays in care, preventable errors, poor patient experience, and staff burnout. There are also disparities in ED boarding, with people of color and behavioral health patients experiencing longer boarding times than other patient populations.  Yet there are no national metrics to assess the proportion of patients impacted by delays in timely ED care.

If implemented, it will capture the proportion of ED visits where patients experience any of these gaps in access to care: 1) Waits longer than 1 hour to be placed in a treatment room or dedicated treatment area that allows for history-taking and physical examination, or 2 ) Being left in the ED without being evaluated by a doctor or qualified nurse, or 3) ED boarding times that exceed 4 hours, or 4) ED lengths of stay longer than 8 hours. PFPS US supports these measures because of their reasonableness, meaningfulness, and practicality.

However, we question whether the time thresholds in numbers 3) & 4) are unrealistic for Rural Emergency Hospitals to meet, when many rural communities  have little or no mental health resources, can swell from very few patients to a surge quickly, and don't have or can afford to have "extra" resource staff.   

PFPS US support this measure because of its intent to obtain baseline data, but urges the CMS  not to penalize rural  hospitals or publicly report the data until more is known or more is done to close the gaps in resources available to Rural Emergency Hospitals.

In earlier years, PFPS US has publicly commented on the importance to achieving health equity goals of collecting and analyzing information on social determinants of health (SDOH).  We support using the evidence-based Accountable Health Communities (AHC) Health-Related Social Needs (HRSN) Screening Tool as a guide, both the Core and Supplemental items.  We are therefore pleased to see and very supportive of CMS efforts to include these new HRSN items in the Long-Term Care Hospital Quality Reporting program(LTCH QRP):

1) Within the past 12 months, you worried that your food would run out before you got money to buy more;

2) Within the past 12 months, the food you bought just didn’t last and you didn’t have money to get more; and

3) In the past 12 months, has the electric, gas, oil, or water company threatened to shut off services in your home?

We also support modifying  the current transportation item in the LTCH QRP so that it aligns better with other CMS quality reporting programs, the revised question reading as follows: In the past 12 months, has lack of reliable transportation kept you from medical appointments, meetings, work or from getting things needed for daily living?

Going forward:

• We urge CMS to expand implementation of Patient Safety Structural Measure to the LTCQR program as soon as feasible, starting with the 2024 Measures Under Consideration list.
• We encourage CMS to consider additional AHC-HRSN items in the LTCH QRP, especially those addressing disability and financial strain, both of which can affect patient safety outcomes or be social needs that contribute to bias..
• We favor the idea of further probes to identify immunization status, depression or pain measures in the LTCH QRP.
• We encourage public display of LTCH QRP data as soon as feasible to do so.

PFPS US also encourages development of a star rating system for Long-Term Care Hospitals. It will be most useful to consumers if it includes measures on patient and diagnostic safety outcomes; structural measures that motivate LTCH leaders to prioritize patient and diagnostic safety, health equity; and patient-reported outcomes and experiences of patient and diagnostic safety events, bias or discrimination, and missed or delayed diagnoses.

In sum, PFPS US strongly supports the consideration of multifactorial ways to advance safety, improvement processes and patient engagement in order to produce consistently better obstetric outcomes in all places where acute obstetric care is provided. In our view, a CoP for obstetric care is long overdue.

In earlier years, PFPS US has publicly commented on the importance to achieving health equity goals of collecting and analyzing information on social determinants of health (SDOH).  We support using the evidence-based Accountable Health Communities (AHC) Health-Related Social Needs (HRSN) Screening Tool as a guide, both the Core and Supplemental items.  We are therefore pleased to see and very supportive of CMS efforts to include these new HRSN items in the Long-Term Care Hospital Quality Reporting program(LTCH QRP):

1) Within the past 12 months, you worried that your food would run out before you got money to buy more;

2) Within the past 12 months, the food you bought just didn’t last and you didn’t have money to get more; and

3) In the past 12 months, has the electric, gas, oil, or water company threatened to shut off services in your home?

We also support modifying  the current transportation item in the LTCH QRP  so that it aligns better with other CMS quality reporting programs, the revised question reading as follows: In the past 12 months, has lack of reliable transportation kept you from medical appointments, meetings, work or from getting things needed for daily living?

Going forward:

• We urge CMS to expand implementation of Patient Safety Structural Measure to the LTCQR program as soon as feasible, starting with the 2024 Measures Under Consideration list.
• We encourage CMS to consider additional AHC-HRSN items in the LTCH QRP, especially those addressing disability and financial strain, both of which can affect patient safety outcomes or be social needs that contribute to bias..
• We favor the idea of further probes to identify immunization status, depression or pain measures in the LTCH QRP.
• We encourage public display of LTCH QRP data as soon as feasible to do so.

PFPS US also encourages development of a star rating system for Long-Term Care Hospitals.  It will be most useful to consumers if it includes measures on patient and diagnostic safety outcomes; structural measures that motivate LTCH leaders to prioritize patient and diagnostic safety, health equity; and patient-reported outcomes and experiences of patient and diagnostic safety events, bias or discrimination, and missed or delayed diagnoses.

In sum, PFPS US strongly supports the consideration of multifactorial ways to advance safety, improvement processes and patient engagement in order to produce consistently better obstetric outcomes in all places where acute obstetric care is provided. In our view, a CoP for obstetric care is long overdue.

In earlier years, PFPS US has publicly commented on the importance to achieving health equity goals of collecting and analyzing information on social determinants of health (SDOH).  We support using the evidence-based Accountable Health Communities (AHC) Health-Related Social Needs (HRSN) Screening Tool as a guide, both the Core and Supplemental items.  We are therefore pleased to see and very supportive of CMS efforts to include these new HRSN items in the Long-Term Care Hospital Quality Reporting program(LTCH QRP):

1) Within the past 12 months, you worried that your food would run out before you got money to buy more;

2) Within the past 12 months, the food you bought just didn’t last and you didn’t have money to get more; and

3) In the past 12 months, has the electric, gas, oil, or water company threatened to shut off services in your home?

We also support modifying  the current transportation item in the LTCH QRP  so that it aligns better with other CMS quality reporting programs, the revised question reading as follows: In the past 12 months, has lack of reliable transportation kept you from medical appointments, meetings, work or from getting things needed for daily living?

Going forward:

• We urge CMS to expand implementation of Patient Safety Structural Measure to the LTCQR program as soon as feasible, starting with the 2024 Measures Under Consideration list.
• We encourage CMS to consider additional AHC-HRSN items in the LTCH QRP, especially those addressing disability and financial strain, both of which can affect patient safety outcomes or be social needs that contribute to bias..
• We favor the idea of further probes to identify immunization status, depression or pain measures in the LTCH QRP.
• We encourage public display of LTCH QRP data as soon as feasible to do so.

PFPS US also encourages development of a star rating system for Long-Term Care Hospitals.  It will be most useful to consumers if it includes measures on patient and diagnostic safety outcomes; structural measures that motivate LTCH leaders to prioritize patient and diagnostic safety, health equity; and patient-reported outcomes and experiences of patient and diagnostic safety events, bias or discrimination, and missed or delayed diagnoses.

In sum, PFPS US strongly supports the consideration of multifactorial ways to advance safety, improvement processes and patient engagement in order to produce consistently better obstetric outcomes in all places where acute obstetric care is provided. In our view, a CoP for obstetric care is long overdue.

In earlier years, PFPS US has publicly commented on the importance to achieving health equity goals of collecting and analyzing information on social determinants of health (SDOH).  We support using the evidence-based Accountable Health Communities (AHC) Health-Related Social Needs (HRSN) Screening Tool as a guide, both the Core and Supplemental items.  We are therefore pleased to see and very supportive of CMS efforts to include these new HRSN items in the Long-Term Care Hospital Quality Reporting program(LTCH QRP):

1) Within the past 12 months, you worried that your food would run out before you got money to buy more;

2) Within the past 12 months, the food you bought just didn’t last and you didn’t have money to get more; and

3) In the past 12 months, has the electric, gas, oil, or water company threatened to shut off services in your home?

We also support modifying  the current transportation item in the LTCH QRP  so that it aligns better with other CMS quality reporting programs, the revised question reading as follows: In the past 12 months, has lack of reliable transportation kept you from medical appointments, meetings, work or from getting things needed for daily living?

Going forward:

• We urge CMS to expand implementation of Patient Safety Structural Measure to the LTCQR program as soon as feasible, starting with the 2024 Measures Under Consideration list.
• We encourage CMS to consider additional AHC-HRSN items in the LTCH QRP, especially those addressing disability and financial strain, both of which can affect patient safety outcomes or be social needs that contribute to bias..
• We favor the idea of further probes to identify immunization status, depression or pain measures in the LTCH QRP.
• We encourage public display of LTCH QRP data as soon as feasible to do so.

PFPS US also encourages development of a star rating system for Long-Term Care Hospitals.  It will be most useful to consumers if it includes measures on patient and diagnostic safety outcomes; structural measures that motivate LTCH leaders to prioritize patient and diagnostic safety, health equity; and patient-reported outcomes and experiences of patient and diagnostic safety events, bias or discrimination, and missed or delayed diagnoses.

In sum, PFPS US strongly supports the consideration of multifactorial ways to advance safety, improvement processes and patient engagement in order to produce consistently better obstetric outcomes in all places where acute obstetric care is provided. In our view, a CoP for obstetric care is long overdue.

In earlier years, PFPS US has publicly commented on the importance to achieving health equity goals of collecting and analyzing information on social determinants of health (SDOH).  We support using the evidence-based Accountable Health Communities (AHC) Health-Related Social Needs (HRSN) Screening Tool as a guide, both the Core and Supplemental items.  We are therefore pleased to see and very supportive of CMS efforts to include these new HRSN items in the Long-Term Care Hospital Quality Reporting program(LTCH QRP):

1) Within the past 12 months, you worried that your food would run out before you got money to buy more;

2) Within the past 12 months, the food you bought just didn’t last and you didn’t have money to get more; and

3) In the past 12 months, has the electric, gas, oil, or water company threatened to shut off services in your home?

We also support modifying  the current transportation item in the LTCH QRP  so that it aligns better with other CMS quality reporting programs, the revised question reading as follows: In the past 12 months, has lack of reliable transportation kept you from medical appointments, meetings, work or from getting things needed for daily living?

Going forward:

• We urge CMS to expand implementation of Patient Safety Structural Measure to the LTCQR program as soon as feasible, starting with the 2024 Measures Under Consideration list.
• We encourage CMS to consider additional AHC-HRSN items in the LTCH QRP, especially those addressing disability and financial strain, both of which can affect patient safety outcomes or be social needs that contribute to bias..
• We favor the idea of further probes to identify immunization status, depression or pain measures in the LTCH QRP.
• We encourage public display of LTCH QRP data as soon as feasible to do so.

PFPS US also encourages development of a star rating system for Long-Term Care Hospitals.  It will be most useful to consumers if it includes measures on patient and diagnostic safety outcomes; structural measures that motivate LTCH leaders to prioritize patient and diagnostic safety, health equity; and patient-reported outcomes and experiences of patient and diagnostic safety events, bias or discrimination, and missed or delayed diagnoses.

In sum, PFPS US strongly supports the consideration of multifactorial ways to advance safety, improvement processes and patient engagement in order to produce consistently better obstetric outcomes in all places where acute obstetric care is provided. In our view, a CoP for obstetric care is long overdue.

PFPS US strongly supports this new EcQM measure, which addresses missed or delayed diagnoses of VTE in primary care clinical settings, which can result in preventable mortality and morbidity.  We concur with findings set forth in the Preliminary Assessment that measuring and reporting delayed VTE diagnosis rates will inform health care providers and facilities about opportunities to improve care, strengthen incentives for quality improvement, and ultimately improve the quality of care received by patients. This measure also has the potential to lower health care costs associated with VTE by providing ongoing intermediate patient outcome data that can be used to improve VTE diagnostic performance and to reduce complications associated with delayed diagnosis and treatment.

PFPS US strongly supports this measure, and concurs with the Preliminary Assessment that that it will promote goal-based care for adult patients with complex care needs, which has been shown to reduce patient-reported treatment burden and the receipt of unwanted care.  It also correlates with greater physical and social well-being and care satisfaction.

We also note that the measure’s requirements (completion of setting individualized goal, development of an action plan, and timely follow-up to assess the goal) align with established evidence and guidelines. It also aligns with CMS health equity goals, in that it is particularly relevant to the care geriatric patients, a vulnerable population at greater risk of experiencing disparate outcomes of care.

PFPS US supports this proposed measure, which addresses unmet social needs related to food, housing, transportation, and utilities and tracks  whether the patient received a follow-up intervention during the visit, such as assistance, evaluation of eligibility for assistance, education, counseling, referral or coordination of care, among others. We are pleased to see it proposed across the board in the MIPS program as well as several hospital quality reporting programs, e.g. the Hospital IQR Program, the Medicare Promoting Interoperability Program and the Prospective Payment System-Exempt Cancer Hospital Quality Reporting Program.

PFPS US encourages CMS to continue to expand its efforts on health equity to include other Health Related Social Needs, including disability, behavioral health status and gaps in employment or available support from family caregivers.Given the known association of social needs with chronic health conditions, assessing and addressing social needs provides an opportunity to improve population health and advance health equity. The measure is aligned with CMS National Quality Strategy goal to address the disparities that underlie our health system, both within and across settings, to ensure equitable access and care for all.

PFPS US supports this proposed measure, which addresses unmet social needs related to food, housing, transportation, and utilities and tracks  whether the patient received a follow-up intervention during the visit, such as assistance, evaluation of eligibility for assistance, education, counseling, referral or coordination of care, among others. We are pleased to see it proposed across the board in the MIPS program as well as several hospital quality reporting programs, e.g. the Hospital IQR Program, the Medicare Promoting Interoperability Program and the Prospective Payment System-Exempt Cancer Hospital Quality Reporting Program.

PFPS US encourages CMS to continue to expand its efforts on health equity to include other Health Related Social Needs, including disability, behavioral health status and gaps in employment or available support from family caregivers.Given the known association of social needs with chronic health conditions, assessing and addressing social needs provides an opportunity to improve population health and advance health equity. The measure is aligned with CMS National Quality Strategy goal to address the disparities that underlie our health system, both within and across settings, to ensure equitable access and care for all.