PC Currently Accepting Comments

Public Comment Page: Currently Accepting Comments 

This page serves as the designated site for CMS to solicit public comments on proposed quality measures.

Instructions for Providing Comments:

  • If you are providing comments on behalf of an organization, include the organization’s name and your contact information
  • If you are commenting as an individual, submit identifying or contact information
  • Please indicate which measure(s) you are commenting on
  • You may submit general comments on the entire set of measures or you may provide comments specific to individual measures
  • Do not include personal health information in your comments. Your comments may be shared publicly.

List of Currently Accepting Comments: 

 

Project Title: Development, Reevaluation, and Implementation of Outpatient Outcome/Efficiency Measures - Lumbar Spine Imaging for Low Back Pain

Dates:

The Call for Public Comment period opens on Monday, August 24, 2020 and closes on Thursday, September 24, 2020.

Project Overview:

The Centers for Medicare & Medicaid Services (CMS) has contracted with Yale New Haven Health Services Corporation Center for Outcomes Research and Evaluation (CORE) and its partner, the Lewin Group (Lewin), to respecify the MRI Lumbar Spine for Low Back Pain (OP-8) measure. The contract name is Development, Reevaluation, and Implementation of Outpatient Outcome/Efficiency Measures. The contract number is HHSM-75FCMC18D0042 and the task order number is HHSM-75FCMC19F0002. As part of its measure development process, Yale/CORE and Lewin request interested parties to submit comments on the candidate or concept measures that may be suitable for this project.

Project Objectives:

In fall 2018, CMS approved the respecification of OP-8 for several reasons: documentation of imaging overuse persists; clinical concept is a primary target of several Choosing Wisely® recommendations; and the existing measure demonstrates substantial performance variation across participating facilities. Respecification of the measure presents an opportunity to align the updated measure with current clinical guidelines and practice, as well as incorporate improvements directly in response to stakeholder feedback.

The project’s primary objectives, as they relate to this public comment, include:

•    Respecification of OP-8 to further align the measure with current clinical guidelines and practice, incorporating improvements previously suggested by stakeholders, including:

    o    Providing feedback on the respecified measure specifications;
    o    Making assessments on the measure’s importance, face validity, feasibility, and usability; and,
    o    Recommending improvements as needed.

Documents and Measures for Comment:

These documents are provided for your review and comment. The files are found in the Download section.

•    Lumbar Spine Imaging for Low Back Pain (respecified version of OP-8) measure specifications
•    Lumbar Spine Imaging for Low Back Pain framing document

Project Specific Instructions:

Yale/CORE and Lewin are seeking feedback on the respecification of OP-8 in advance of its finalization. All comments are welcome, but we are particularly interested in feedback in the following areas:

For Lumbar Spine Imaging for Low Back Pain measure, beneficiaries who have a clinical diagnosis of one or more conditions for which imaging is considered appropriate are excluded (removed from the denominator, and, thus, also removed from the numerator) from the measure. The initial patient population for the measure includes those beneficiaries aged 18 years and older, with claims for evaluation and management (E&M) visits that contain a diagnosis of uncomplicated low back pain and occur during the measurement period.

    a.    We seek feedback on whether elderly patients with no previously diagnosed underlying etiology, should be excluded from the measure based on their age, alone.

    b.    We seek comments on the indications and preferred modalities for imaging elderly patients without a previously diagnosed underlying etiology and the age at which this type of imaging is appropriate.

    c.    We seek comments on the appropriate age threshold for excluding an elderly individual from the measure, if any.

In addition to the questions above, we welcome your feedback on the following topics:

•    Whether, in addition to CT, CMS should consider adding any other imaging modalities, such as CT myelography, to the measure specifications;
•    Whether CMS should consider expanding the current list of excluded conditions and if the current list of exclusions is clinically appropriate;
•    The usefulness of the Lumbar Spine Imaging for Low Back Pain measure to assess and improve the quality of care for Medicare beneficiaries;
•    The ability of the measure to assess facility performance; and,
•    The potential of unintended consequences following implementation of the respecified measure.

Your answers to these questions will help inform measure respecification and strengthen the usefulness of the final measure to the field.

Send your comments to Imaging.Measures@Lewin.com.

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Project Title: Development of the Skilled Nursing Facility (SNF) Healthcare-Associated Infections (HAIs) Requiring Hospitalizations Measure for the Skilled Nursing Facility Quality Reporting Program (SNF QRP).

Dates:

The Call for Public Comment period opens on September 14, 2020 and closes on October 14, 2020.

Project Overview:

The Centers for Medicare & Medicaid Services (CMS) has contracted with Acumen to develop a claims-based quality measure of healthcare-associated infections (HAIs) for the SNF QRP. The contract name is Quality Reporting Program Support for the Long-Term Care Hospital, Inpatient Rehabilitation Facility, Skilled Nursing Facility/Nursing Facility QRPs and Nursing Home Compare (PAC QRP) Support. The contract number is 75FCMC18D0015. As part of its measure development process, Acumen requests interested parties to submit comments on the candidate or concept measures that may be suitable for this project.

Project Objectives:

  • Develop a healthcare-associated infections quality measure for the SNF QRP under the meaningful measure domain: Making Care Safer by Reducing Harm Caused in the Delivery of Care.
  • Specify the target population, including the exclusion criteria.
  • Identify risk adjustment variables and the approach for risk adjustment.
  • Gather feedback on the importance, feasibility, usability, and potential impact of calculating an HAI measure.
  • Identify additional guidance required for implementation in the SNF QRP.

Documents and Measures for Comment:

This document is provided for your review and comment. This file is found in the Download section.

  • Measure specifications for the Skilled Nursing Facility (SNF) Healthcare Associated Infections (HAIs) Requiring Hospitalization.

Project Specific Instructions:

Please review the Skilled Nursing Facility (SNF) Healthcare-Associated Infections (HAIs) Requiring Hospitalizations measure specification document and deliver your feedback via the email box. Send your comments to QM-Public-Comment@acumenllc.com.

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Page Last Modified:
09/21/2020 07:33 AM