2. Public Comment Results
The 51 recommended measures (Appendix 5) were posted for public comment from December
30, 2010, to March 1, 2011.4
The public submitted a total of 100 comments. About a third of the comments specifically noted that the core set was too large or raised burden of reporting as a concern. Comments suggested reducing the initial set (e.g., to one to two measures per category), or considering a phase-in approach. Numerous comments suggested avoiding measures that require medical record review. Many comments suggested aligning measures with existing reporting programs, such as Medicaid
Electronic Health Record Incentive Program (i.e., Meaningful Use5) and the Inpatient Hospital Quality Reporting program,6 as a way to decrease burden on State reporting. Comments also suggested using only measures that are endorsed by the National Quality Forum or the National Committee for Quality Assurance HEDIS® measures. Many emphasized the importance of ensuring the core set measures have met thresholds for evidence, validity, reliability, and feasibility.
In addition to general comments, the public submitted specific comments on several of the recommended measures.
- Most often, comments on a specific measure suggested excluding it from the core set due to reasons that included the following:
- Concern that measures which require medical record review are burdensome.
- Concern that measures not widely used in existing programs will complicate existing reporting efforts.
- Concern that measures that apply to highly specific populations will have small denominators and will not be feasible to report.
- Three measures received more suggestions to include them rather than exclude them:
- Breast Cancer Screening.
- Cervical Cancer Screening.
- Medical Assistance With Smoking and Tobacco Use Cessation.
In addition to comments on the recommended measures, an additional 43 measures were suggested in public comment. Each was suggested by at most two organizations (Appendix 6). Forty two of the 43 had already been considered by the Subcommittee in the preliminary stage and not selected for inclusion as a core set measure. The one measure that had not been considered was a newly developed measure that had not appeared in the original inventory of candidate measures (Healthy Term Newborn).
Based on public comment results, the overall directive to the Subcommittee was to evaluate each measure's importance to the Medicaid adult population and adherence to attributes representative of sound measurement. In addition, the Subcommittee was encouraged to recommend fewer number of measures for the core set in order to be responsive to the concerns around burden of reporting.
4 Federal Register Notice December 2010.
5 Meaningful Use is a Medicare and Medicaid EHR Incentive Program and provides a financial incentive for health care providers to adopt and "meaningfully use" certified electronic health record (EHR) technology to achieve health and efficacy goals. The three main components of the Meaningful Use program, as specified by the American Recovery and Reinvestment Act of 2009, are the use of a certified EHR in a meaningful way, such as e-prescribing; for electronic exchange of health information to improve quality of health care; and to submit clinical quality and other measures (1).
6 The Hospital Inpatient Quality Reporting program, mandated by Section 501(b) of the Medicare Prescription Drug, Improvement, and Modernization Act (MMA) of 2003, authorizes CMS to reward hospitals that successfully report designated quality measures by paying a higher annual update to their payment rates. In return, the hospital reporting program provides CMS with data that will help consumers make more informed decisions about their health care (2).
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