MedPAC comments on proposed CMS quality measures

The Centers for Medicare & Medicaid Services (CMS) should focus on broad, population-level outcome measures—such as potentially avoidable hospital admissions, emergency department visits and readmissions—instead of clinical process measures “that are, at best, weakly correlated with health outcomes” when looking for ways to measure quality and efficiency, the Medicare Payment Advisory Commission (MedPAC) suggested in a recent letter [PDF]  to CMS Administrator Marilyn Tavenner.

The commission’s January comments come in response to a list of measures under consideration for 21 programs that CMS published Dec. 1 as statutorily required. The programs include Long-Term Care Hospital Reporting, Home Health Care Quality Reporting, Skilled Nursing Facility Value-Based Purchasing Program, Hospice Quality Reporting and others.

“Depending on a large number of process measures reinforces undesirable payment incentives in [fee-for-service] Medicare to increase the volume of services and is overly burdensome on providers to report, while yielding limited information to support clinical improvement or beneficiary choice," MedPAC Chairman Glenn M. Hackbarth wrote.

Population-based outcome measures would not be fit for adjusting fee-for-service Medicare payments within a local area, since providers reimbursed under the fee-for-service model have not explicitly agreed to be responsible for a population of beneficiaries, Hackbarth noted. The fee-for-service Medicare program, therefore, would need to continue to rely on some provider-based quality measures to make payment adjustments—at least for now, he added.

“However, the sheer size of the December 2014 list of measures under consideration reinforces our concerns that Medicare’s provider-level measurement activities are accelerating without regard to the costs or benefits of an ever-increasing number of measures,” Hackbarth wrote. “We urge CMS to keep this broader perspective in mind as it moves into the proposed rule process for each Medicare program, and carefully consider whether each additional measure would simply reinforce or exacerbate the current system’s problems.”