PRMR Clinician Draft Committee Roster 2023

As an association that represents more than 100,000 member physical therapists, physical therapist assistants, and students of physical therapy, American Physical Therapy Association appreciates the transparent process the Battelle Partnership for Quality Measurement is utilizing in developing the Pre-Rulemaking Measure Review committees, and the opportunity to provide comments for feedback on the process and selection of committee members.

We are concerned about the lack of representation from rehabilitation professionals on the PRMR Clinician Committee. The majority of individuals, including Medicare beneficiaries receiving physical therapist services, do so in a non-hospital based out-patient setting. Physical therapists play a significant role in meeting the health care needs of individuals in the community, addressing common musculoskeletal, neuromuscular, cardiovascular, pulmonary, and integumentary conditions, assisting patients with chronic conditions maintain their functional performance, and addressing risk factors for preventable adverse events like falls and progression of functional decline. Battelle has stated that in their goal to ensure measures on the MUC List are reasonable and necessary, they are seeking diverse representation of key participants, and that committees are made up of a combination of those who are the most impacted by adoption and implementation of the measures and those who bring broader and system perspectives to the PRMR and MSR processes.

Physical therapists have a unique lens among clinicians within health care that should be considered when ensuring development of these measures. Battelle even included “physical therapists” in the title of the Clinician Committee description, posted at various points within the document: “Clinicians, including physicians, nurses, pharmacists, physical therapists, etc.” Why then, would no physical therapists be included within the work group when three pharmacists, three nurses, and twenty-four physicians were?

Additionally, one of the primary challenges of the MSSP, MIPS, and MVP is the physician focused nature of these programs and the lack of meaningful measures for qualified healthcare professionals who do not report E/M codes. For these programs to truly measure the quality and effectiveness of healthcare delivery those providers who address function and its significant impact on healthcare quality, cost, and performance must play a role in this process.

APTA urges Battelle to consider appointing a physical therapist to the PRMR Clinician Committee if they truly seek diverse representation in their recommendations to the Centers for Medicare and Medicaid Services. 

As the world’s largest organization of board-certified pathologists and leading provider of laboratory accreditation and proficiency testing programs, the College of American Pathologists (CAP) is pleased to offer support for the appointment of Dr Sarah Eakin, MD, FCAP, to the PRMR Clinician Committee. The CAP appreciates the time and effort that Battelle has put into transparency of the PRMR process, including maintaining public comment on draft rosters. We are committed to serving patients, pathologists and the public by fostering and advocating excellence in the practice of pathology and laboratory medicine and believe that representation of diagnostic medicine on the PRMR Clinician Committee will be essential to promoting a robust measure recommendation process. 

Dr Eakin currently sits on the CAP’s Quality and Clinical Data Registry Affairs Committee, where she has had extensive experience with development of quality measures for pathology. She previously was a member of the CAP’s Economic Affairs Committee and their Measures and Performance Assessment Subcommittee.  She has also been nominated and accepted to participate in multiple waves of cost measure development with Acumen LLC. Dr Eakin therefore brings a diversity of expertise in measure development as well as her expertise in pathology. She has been a practicing pathologist for over 12 years and has deep knowledge of anatomic and clinical pathology.

We encourage Battelle to ensure diverse representation of clinicians going forward, including non-patient-facing clinicians and clinicians practicing in a variety of settings. As the MIPS program continues to evolve, it will be even more important to ensure that all aspects of the healthcare system are represented in the measure recommendation process. We strongly support Dr Eakin’s appointment and look forward to strong participation of all stakeholders in the process. 

Attached please find the National Association of ACOs (NAACOS) public comments on the PRMR committee rosters.

See Comment Attached - Thank you

 The list of the nominees is distinguished for these committees, including significant numbers of patient advocates, but the list does not seem detailed enough to demonstrate whether there are significant surgeon representation. There are many ongoing efforts to document surgical quality (Metabolic & Bariatric Surgery Accreditation & Quality Improvement Program (MBSAQIP), National Surgical Quality Improvement Program (NSQIP), Emergency General Surgery (EGS) verification program, Geriatric Surgery Verification (GSV) Program, multiple state quality collaboratives). But none of these programs appear to have significant representation with quality measures at a national level that encourage hospital leadership to support vigorously these quality efforts.

  Cardiology, radiology, psychiatrists, & other non-surgeon physicians are represented at the national level.

  But the US generates for the elective inpatient & outpatient surgical procedures approximately $195 bil - $212 bil in hospital reimbursement & approximately $48 - $64.8 bil in hospital net income per year. CMS MIPS/ MVP only account for a fraction of these surgical procedures. Shouldn’t PQM’s MSR & PRMR have at least one surgeon representation to help improve the quality for this significant revenue?

  We are delighted to have at least one surgeon representative nominated to the Management of Acute Events, Chronic Disease, Surgery, Behavioral Health Committee, especially representation from an expert who know what measures work (tracking controllable events that affect Surgical Site Infections (SSIs), e.g. timing of preop antibiotics, euglycemia, normothermia…) & do not work (tracking all SSIs without risk adjustment).” But will there be any loss in translation or advocacy routing in between committees as proposed or modified measures pass through?