The process of rulemaking and how the Centers for Medicare & Medicaid Services (CMS) comes to the decisions they do is complex. We wanted to take an opportunity to share with our readers some of the behind-the-scenes of the regulatory process. 

When CMS creates new policies, they take into consideration the opinions of stakeholders -- physicians, organizations and patients. For quality measures, CMS publishes a Measures under Consideration (MUC) list each year (usually in the late fall or the early winter months). From there, the National Quality Forum (NQF) conducts meetings, called Measure Applications Partnership (MAP) meetings, to evaluate whether or not the measures on the MUC list should be endorsed.

MarsdenAdvisors recently submitted comments to NQF to save crucial quality measures under MIPS and to drop a burdensome ASC measure.

In this blog, we'll review what NQF is and does, as well as how MarsdenAdvisors is supporting our clients in this important advocacy process. 

What is the National Quality Forum?

The National Quality Forum (NQF) is a not-for-profit, non-partisan, member-based organization that works to "catalyze improvements in healthcare". When it comes to quality measure development and evaluation, the NQF has two working groups:

• Consensus Standards Approval Committee (CSAC), which reviews whether or not any measure recommended by their subcommittees should receive endorsement. 
• Measure Applications Partnership (MAP), which the Department of Health and Human Services depends on to "foster the use of a more uniform set of measures across federal programs that provide health coverage for about 120 million Americans."

Today, Friday August 5, 2022, the commenting period for the Measure Set Review (MSR) closes. This process works to identify measures that the NQF can recommended for removal from federal quality programs (like MIPS or the ASCQR). While the NQF's guidance is not binding, it is very important to how CMS considers evaluating quality in future years.

2022 Measure Set Review (MSR) Recommendations

This commenting period is about whether or not measures should be recommended for removal by the MAP standing committee.

Relevant MIPS Measures Under Consideration by the MAP for Recommended Removal 

• Measure 19: Diabetic Retinopathy: Communication with the Physician Managing Ongoing Diabetes Care, Both the MIPS CQM and eCQM Versions
• Measure 374: Closing the Referral Loop: Receipt of Specialist Report, eCQM
• Measure 385: Adult Primary Rhegmatogenous Retinal Detachment Surgery: Visual Acuity Improvement Within 90 Days of Surgery, MIPS CQM

Relevant ASCQR Measures Under Consideration by the MAP for Recommended Removal 

• ACS-11: Cataracts: Improvement in Patient's Visual Function within 90 Days Following Cataract Surgery

MarsdenAdvisors Comments on the MAP MSR Measure Removal Comment Solicitation

At MarsdenAdvisors, we take our client's needs on as our own and make sure every physician we support is represented in the decision-making process for federal programs that impact them. 

Our main concern with the measures mentioned above being considered for removal is that it makes it increasingly hard for ophthalmologists to find and use appropriate quality measures. Specifically, sub-specialists like retina specialists, are finding it increasingly difficult to identify and report on germane and appropriate quality measures. The removal of these three additional MIPS measures  would create a significant obstacle. Additionally, two of the considered measures involve care coordination, which we believe is important to incentivize as it makes meaningful impacts on quality care holistically and are generally applicable to most physicians.

ACS-11 is an ASCQR measure that has been plagued with criticism since its inception. After several delays for implementation, general consensus amongst cataract surgeons and those who support them is to strongly oppose this measure. While CMS continues to delay its plans to require reporting on this measure, we will continue to advocate for its removal.

Next Steps

• Share this information with your colleagues.
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If you want hands-on, personalized assistance on MIPS or the ASCQR, contact us and we will have your back.