NQF

Version Number: 13.4
Meeting Date: January 15, 2020

Measure Applications Partnership
Coordinating Committee Discussion Guide

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Agenda

Agenda Synopsis

Time Session
January 15, 2020  
8:30 AM   Breakfast
9:00 AM   Welcome and Review of Meeting Objectives
9:15 AM   CMS Opening Remarks and Meaningful Measures Update
10:15 AM   Overview of Pre-Rulemaking Approach
10:25 AM   Break
10:35 AM   Opportunity for Public Comment on Hospital Programs
10:45 AM   Pre-Rulemaking Recommendations for Hospital Programs
12:30 PM   Lunch
1:00 PM   Opportunity for Public Comment on Clinician Programs
1:10 PM   Pre-Rulemaking Recommendations for Clinician Programs
3:00 PM   Break
3:25 PM   Pre-Rulemaking Recommendations for PAC/LTC Programs
4:10 PM   Future Direction of the Pre-Rulemaking Process
4:35 PM   Opportunity for Public Comment
4:45 PM   Closing Remarks and Next Steps
5:00 PM   Adjourn for the Day


Full Agenda

January 15, 2020  
8:30 AM   Breakfast
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9:00 AM   Welcome and Review of Meeting Objectives
Bruce Hall, MAP Coordinating Committee Co-Chair
Chip Kahn, MAP Coordinating Committee Co-Chair
Sam Stolpe, Senior Director, NQF
Elisa Munthali, Senior Vice President, Quality Measurement, NQF

9:15 AM   CMS Opening Remarks and Meaningful Measures Update
Michelle Schreiber, QMVIG Group Director, CMS


10:15 AM   Overview of Pre-Rulemaking Approach
Kate Buchanan, Senior Project Manager, NQF
Chip Kahn

10:25 AM   Break
10:35 AM   Opportunity for Public Comment on Hospital Programs
10:45 AM   Pre-Rulemaking Recommendations for Hospital Programs
Sean Morrison, Hospital Workgroup Co-Chair
Sam Stolpe
Chip Kahn
Measures under consideration:
  1. Standardized Transfusion Ratio for Dialysis Facilities (MUC ID: MUC2019-64)
    • Description: The risk adjusted facility level transfusion ratio (STR) is specified for all adult dialysis patients. It is a ratio of the number of eligible red blood cell transfusion events observed in patients dialyzing at a facility, to the number of eligible transfusion events that would be expected under a national norm, after accounting for the patient characteristics within each facility. Eligible transfusions are those that do not have any claims pertaining to the comorbidities identified for exclusion, in the one year look back period prior to each observation window.This measure is calculated as a ratio, but can also be expressed as a rate. (Measure Specifications; Summary of NQF Endorsement Review)
    • Public comments received: 1
    • Workgroup Rationale: MAP offered conditional support for rulemaking of MUC2019-64, pending NQF endorsement of the revised measure. The measure is based on an endorsed measure (NQF 2979) that was implemented in ESRD QIP. There are two significant differences between the current NQF-endorsed STrR used on Dialysis Facility Compare and in QIP PY2021 and the proposed revision submitted. First, for hospital inpatients, the current NQF endorsed STrR relies on a restricted transfusion identification algorithm. The measure utilizes only those reported transfusion events that include ICD procedure codes, ICD procedure codes with revenue center codes, or value codes. For the proposed revision to STrR, inpatient transfusion events are identified using on a broader definition that includes revenue center codes only, ICD10 procedure codes (alone or with revenue codes), or value codes alone or in combination. The measure developer pointed out that the proposed revision results in identification of a greater number of inpatient transfusion events compared to the currently implemented STrR. Second, the current NQF-endorsed STrR includes all Medicare patients, including those with Medicare Advantage coverage, that meet inclusion criteria based on the presence of Medicare claims activity reflected in $900 or greater in dialysis paid claims in a month or recent inpatient hospitalization. The proposed STrR revision uses similar criteria but excludes all Medicare Advantage patients’ time at risk from both the measure numerator and denominator. This proposed change aims to mitigate potential bias associated with inclusion of Medicare Advantage patients. The bias derives from the absence of complete outpatient claims data for Medicare Advantage patients, severely limiting the identification of outpatient transfusion events for these individuals. MAP considered the updates to the measure to be both appropriate and necessary. MAP noted that this measure is for reporting purposes only and is not used for payment. The developer explained that this is because the measure is now using both value codes and ICD-10 codes as indicators that blood transfusions have occurred.
    • Workgroup Recommendation: Conditional Support for Rulemaking


  2. Maternal Morbidity (MUC ID: MUC2019-114)
    • Description: Structural Measure to address severe maternal morbidity in the inpatient hospital setting. (Measure Specifications)
    • Public comments received: 9
    • Workgroup Rationale: MAP did not support MUC2019-114 Maternal Morbidity for rulemaking, with potential for mitigation. The potential mitigating factors identified by MAP would be to adjust the language of the question to clarify that the hospital is expected both to attest to participation in a quality improvement initiative as well as to implement patient safety practices or bundles to address complications and that the Maternal Morbidity measure go through the NQF endorsement process. MAP observed that severe maternal morbidity is increasing at an alarming rate in the U.S., nearly doubling in the last decade. There are currently no quality measures that address maternal morbidity, and MAP is encouraged by CMS’s attempts to address this healthcare crisis. However, MAP expressed concern related to using attestation to participation in a quality improvement initiative rather than finding clear process and outcomes measures that address the quality issue directly, such as asking if specific bundles of care are incorporated into the services provided during maternal care. MAP members identified the language “and has implemented patient safety practices or bundles” to replace “which includes implementation of patient safety practices or bundles” as one way to add clarity that the intent of the measure is both to participate in a QI program and implement specific bundles known to improve outcomes. Finally, the Rural Health Workgroup noted a concern that not all rural critical access hospitals would be able to participate in a state QI collaborative. MAP noted that this is balanced by the universal availability of national-level QI programs.
    • Workgroup Recommendation: Do Not Support for Rulemaking with Potential for Mitigation


  3. Follow-Up After Psychiatric Hospitalization (MUC ID: MUC2019-22)
    • Description: The Follow-Up After Psychiatric Hospitalization measure assesses the percentage of inpatient discharges with principal diagnoses of select mental illness or substance use disorders (SUD) for which the patient received a follow-up visit for treatment of mental illness or SUD. Two rates are reported:1. Percentage of discharges for which the patient received follow-up within 7 days of discharge2. Percentage of discharges for which the patient received follow-up within 30 days of dischargeThe performance period used to identify denominator cases is 12 months. Data from the performance period and 30 days after are used to identify follow-up visits in the numerator. (Measure Specifications)
    • Public comments received: 4
    • Workgroup Rationale: MAP did not support MUC2019-22 for rulemaking. MAP noted that this measure is an expansion of the existing NQF 0576 Inpatient Psychiatric Facility Quality Reporting Program Follow-Up After Hospitalization for Mental Illness measure, broadening the measure population to include patients hospitalized for drug and alcohol disorders as those patients also require follow-up care post-discharge. MAP noted the importance of robust care transitions for this expanded population but also identified several critical concerns with the proposed measure. MAP expressed concern that the numerator requires patient choice in pursuing follow-up care and may not reflect whether follow-up care has been arranged by the hospital being measured. MAP also noted that the Stark Law may limit the ability for hospitals and care managers to ensure necessary SUD treatment follow-up after hospitalization. MAP members were also concerned that patients may not have access to appropriate SUD outpatient follow-up care. MAP members also noted the importance of telehealth follow-up as a critical tool and the importance of including these visit types in the measure. CMS noted that telehealth is currently billable in a limited fashion, only if it is submitted with a GT modifier. MAP was generally not satisfied in the current specifications and expressed concern that the measure could lead to unintended negative consequences for patients. Finally, several members noted that the evidence base for this measure needs to be specific to the conditions of interest. The MAP Rural Health Workgroup viewed this measure as appropriate, as SUD and mental health issues impact many rural residents, but the Workgroup expressed concern about to access to care, recommending telehealth follow-up as a potential solution, which would harmonize with the NCQA HEDIS measure.
    • Workgroup Recommendation: Do Not Support for Rulemaking


  4. National Healthcare Safety Network (NHSN) Catheter-Associated Urinary Tract Infection Outcome Measure (MUC ID: MUC2019-18)
    • Description: Standardized Infection Ratio (SIR) of healthcare-associated, catheter-associated urinary tract infections (UTI) will be calculated among patients in bedded inpatient care locations, except level II or level III neonatal intensive care units (NICU). This includes acute care general hospitals, long-term acute care hospitals, rehabilitation hospitals, oncology hospitals, and behavior health hospitals. (Measure Specifications; Summary of NQF Endorsement Review)
    • Public comments received: 2
    • Workgroup Rationale: MAP supported MUC2019-18 for rulemaking. A prior version of this measure is currently included in PCHQR and addresses the Meaningful Measure Area of healthcare-associated infections. The risk-adjustment model for this measure was updated, and the measure was submitted and re-endorsed by the NQF Patient Safety Standing Committee in the spring 2019 CDP cycle. The measure is otherwise identical to the existing measure in PCHQR. MAP members noted the need to monitor the use of the measure in spinal cord injuries. MAP also noted the importance of comparing cancer hospitals to like hospitals given the differences in the patient populations. The Rural Health Workgroup noted that the 11 PPS-exempt cancer hospitals in the program are in urban centers, but rural patients often use them, and expressed support of MUC2019-18. MAP supported the continued use of this measure in PCHQR with the updated specifications.
    • Workgroup Recommendation: Support for Rulemaking


  5. Hospital Harm - Severe Hyperglycemia (MUC ID: MUC2019-26)
    • Description: This measure assesses the proportion of hospital days with a severe hyperglycemic event for hospitalized patients 18 or older who have a diagnosis of diabetes mellitus, have received at least one administration of insulin or an anti-diabetic medication during the hospital admission, or have had an elevated blood glucose level (>200 mg/dL) during their hospital admission. (Measure Specifications)
    • Public comments received: 13
    • Workgroup Rationale: MAP offered conditional support for MUC2019-26 Hospital Harm – Severe Hyperglycemia, pending NQF endorsement of the measure. IQR currently does not include a measure that assesses severe hyperglycemia events that are largely avoidable through proper glycemic monitoring and intervention. MAP expressed concern and encouraged CMS to consider the unintended consequence that this measure may lead to increases in hypoglycemia, which was regarded as a more serious issue. The Rural Health Workgroup noted that diabetes rates are high in rural settings, and the measure addresses a preventable patient safety issue that is relevant for rural populations. The Rural Health Workgroup expressed concern that if glucose levels are derived from laboratory data (rather than at point of care), they may be more difficult to obtain and/or incorporate into EHR systems in rural hospitals. They also were concerned that EHR systems in rural hospitals may not be as robust or current, making it more difficult to compute the measure (e.g., using RxNORM). Finally, MAP generally agreed that the measure did not carry any significant implementation burden.
    • Workgroup Recommendation: Conditional Support for Rulemaking


  6. National Healthcare Safety Network (NHSN) Central Line Associated Bloodstream Infection Outcome Measure (MUC ID: MUC2019-19)
    • Description: Standardized Infection Ratio (SIR) and Adjusted Ranking Metric (ARM) of healthcare-associated, central line-associated bloodstream infections (CLABSI) will be calculated among patients in bedded inpatient care locations. (Measure Specifications; Summary of NQF Endorsement Review)
    • Public comments received: 2
    • Workgroup Rationale: MAP supported MUC2019-19 for rulemaking. MAP noted that MUC2019-19 is an updated version of the existing measure in PCHQR (NQF 0139). The risk-adjustment model for this measure was updated, and the measure was submitted and re-endorsed by the NQF Patient Safety Standing Committee in the spring 2019 CDP review cycle. MAP noted that this measure is also otherwise identical to the existing measure in PCHQR. MAP noted that CLABSIs are associated with significant morbidity, mortality, and costs. Patients in ICUs are at an increased risk for CLABSI because 48 percent of ICU patients have indwelling central venous catheters, accounting for 15 million central line days per year in U.S. MAP encouraged CMS and CDC to review if there are patient-specific traits that lead to higher rates of CLABSI within cancer hospitals. The Rural Health Workgroup also noted that the 11 cancer hospitals in the program are in urban centers, but rural patients often use them, and the Workgroup expressed support of MUC2019-19.
    • Workgroup Recommendation: Support for Rulemaking


12:30 PM   Lunch
1:00 PM   Opportunity for Public Comment on Clinician Programs
1:10 PM   Pre-Rulemaking Recommendations for Clinician Programs
Rob Fields, Clinician Workgroup Co-Chair
Sam Stolpe
Bruce Hall
Measures under consideration:
  1. Hospital-Wide, 30-Day, All-Cause Unplanned Readmission (HWR) Rate for the Merit-Based Incentive Payment Program (MIPS) Eligible Clinician Groups (MUC ID: MUC2019-27)
    • Description: This measure is a re-specified version of the measure, Risk-adjusted readmission rate (RARR) of unplanned readmission within 30 days of hospital discharge for any condition†(NQF 1789), which was developed for patients 65 years and older using Medicare claims. This re-specified measure attributes outcomes to MIPS participating clinician groups and assesses each group's readmission rate. The measure comprises a single summary score, derived from the results of five models, one for each of the following specialty cohorts (groups of discharge condition categories or procedure categories): medicine, surgery/gynecology, cardio-respiratory, cardiovascular, and neurology. (Measure Specifications; Summary of NQF Endorsement Review)
    • Public comments received: 17
    • Workgroup Rationale: MAP conditionally supported MUC2019-27 for rulemaking. Support for this measure is pending removal and replacement of NQF 1789 in the MIPS program measure set with this measure, and NQF CDP Standing Committee review of reliability performance at the physician group level in spring 2020. MAP noted that this measure is a respecified version of the measure Risk-adjusted readmission rate (RARR) of unplanned readmission within 30 days of hospital discharge for any conditions (NQF 1789), which was developed for patients 65 years of age and older using Medicare claims. MAP emphasized the importance of addressing unplanned readmissions and noted that physician groups can influence this outcome by supporting appropriate medication reconciliation at discharge, reducing infection risk, and ensuring proper outpatient follow-up. MAP suggested that this measure promotes a systems level approach by clinicians and suggested a future focus on especially high-risk conditions such as COPD and heart failure. MAP noted that the NQF All-Cause Admissions and Readmissions Standing Committee had requested additional information from the developer on reliability performance of this measure at various case sizes for the physician group level of analysis in the course of the consensus development process (CDP).
    • Workgroup Recommendation: Conditional Support for Rulemaking


  2. Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions; in the Medicare Shared Savings Program, the score would be at the ACO level. (MUC ID: MUC2019-37)
    • Description: Annual risk-standardized rate of acute, unplanned hospital admissions among Medicare Fee-for-Service (FFS) patients aged 65 years and older with multiple chronic conditions (MCCs). (Measure Specifications)
    • Public comments received: 16
    • Workgroup Rationale: MAP does not support MUC2019-37 for rulemaking in MIPS with potential for mitigation. The measure is a modified version of an existing NQF-endorsed measure (NQF 2888), last reviewed for endorsement in 2016. MAP noted that the newly developed measure differs from its predecessor in a few ways.•Cohort: CMS added diabetes as a cohort-qualifying condition.•Outcome: CMS narrowed the outcome to focus on admissions where risk can be reduced by providing high-quality ambulatory care, so that the measure can be used to assess ambulatory (rather than ACO-wide) care quality.•Risk-adjustment: CMS added social risk factors to the risk-adjustment model.MAP noted several potential areas of mitigation for the measure: 1. The measure should apply to clinician groups, not to individual clinicians; 2. The measure should use a higher reliability threshold, e.g., 0.7; 3. The measure developer should consider the NQF guidance on attribution and consider patient preference and selection as a method of attribution as that date becomes available; 4. The measure should undergo the NQF endorsement process. MAP suggested that rather than moving directly to this outcome measure, process measures that would get to the desired outcome might be an appropriate stepwise approach to increasing accountability. The MAP Rural Health Workgroup noted that chronic conditions included in this measure are prevalent in rural residents. However, the Rural Health Workgroup does not believe this measure should be linked to payment for rural clinicians or clinician groups.
    • Workgroup Recommendation: Do Not Support for Rulemaking with Potential for Mitigation


  3. Follow-up after Emergency Department (ED) Visit for People with Multiple High-Risk Chronic Conditions (MUC ID: MUC2019-14)
    • Description: The percent of emergency department visits for Medicare beneficiaries ages 18 and older with multiple high-risk chronic conditions (MCC) who had a follow-up service within 7 days of the ED visit. Multiple high-risk chronic conditions include 2 or more of the following: Alzheimer's disease, atrial fibrillation, chronic kidney disease, COPD, depression, heart failure, cardiovascular disease evidenced by acute myocardial infarction, and stroke or transient ischemic attack. Appropriate follow-up services include but not limited to: an outpatient visit; telephone visit; transitional or complex care management services, outpatient or telehealth behavioral health visit, or observation visit. (Measure Specifications)
    • Public comments received: 8
    • Workgroup Rationale: MAP conditionally supported MUC2019-14 for rulemaking, pending NQF endorsement. MAP noted the importance of the care coordination domain as a CMS priority. MAP observed that care coordination is the deliberate organization of patient care activities between two or more participants involved in a patient’s care to facilitate the appropriate delivery of healthcare services. This measure is an additional process measure to the Medicare Part C and D Star Ratings that lends itself to better care efficiencies and coordination for health plans and their beneficiaries. MAP also discussed the increase of utilization and costs associated with use of emergency departments for Medicare beneficiaries, particularly those with dual-eligible status and with a behavioral health diagnosis, both of which are much higher cost demographics. Coordinating the care of beneficiaries who use emergency services is an important component to ensuring that they also are receiving outpatient care and preventive services with the potential to mitigate disease progression that results in further unnecessary use of emergency facilities. The Rural Health Workgroup noted that the chronic conditions included in this measure are prevalent in rural residents, and that lack of access to care in rural areas may make performance on this measure more difficult for plans that cover rural residents. MAP was encouraged that telephone follow-up was included in this measure but encouraged CMS to ensure that the telephone follow-ups are meaningful to patients.
    • Workgroup Recommendation: Conditional Support for Rulemaking


  4. Risk-standardized complication rate (RSCR) following elective primary total hip arthroplasty (THA) and/or total knee arthroplasty (TKA) for Merit-based Incentive Payment System (MIPS) Eligible Clinicians and Eligible Clinician Groups (MUC ID: MUC2019-28)
    • Description: This measure is a re-specified version of the measure, Hospital-level Risk-standardized Complication rate (RSCR) following Elective Primary Total Hip Arthroplasty (THA) and/or Total Knee Arthroplasty (TKA) (National Quality Forum 1550), which was developed for patients 65 years and older using Medicare claims. This re-specified measure attributes outcomes to Merit-based Incentive Payment System participating clinicians and/or clinician groups (provider) and assesses each provider's complication rate, defined as any one of the specified complications occurring from the date of index admission to up to 90 days post date of the index procedure. (Measure Specifications; Summary of NQF Endorsement Review)
    • Public comments received: 8
    • Workgroup Rationale: MAP supported MUC2019-28 for rulemaking. MAP noted that this measure can improve the quality of surgical care delivery and follow-up care for a common and costly surgical procedure performed for Medicare beneficiaries. MAP agreed that patient-reported outcomes performance measures related to TKA and THA would also be desirable but would be complementary to this measure. MUC2019-18 is endorsed as NQF 3493 and is a respecified version of Hospital-level Risk-standardized Complication rate (RSCR) following Elective Primary Total Hip Arthroplasty (THA) and/or Total Knee Arthroplasty (TKA) (NQF 1550), which was developed for patients 65 years and older using Medicare claims. MAP noted that NQF 1550 is currently being used in the CMS Hospital Inpatient Quality Reporting Program, though it underwent substantial respecification to allow for clinician and clinician group attribution. In adapting the hospital-level measure for MIPS-eligible clinicians, the same cohort of patients will be measured, but the outcomes will be attributed to a larger number of healthcare entities with a shared responsibility for delivery of high quality postsurgical care. The MAP Rural Health Workgroup noted that this measure will be limited to clinicians/clinician groups with at least 25 patients, and as such, the low case-volume issue will not come into play for rural providers. However, access to supportive services prior to surgery will be even more critical when these procedures are done in the outpatient setting, and access to such services may be more limited in rural areas.
    • Workgroup Recommendation: Support for Rulemaking


  5. Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions; in the Medicare Shared Savings Program, the score would be at the ACO level. (MUC ID: MUC2019-37)
    • Description: Annual risk-standardized rate of acute, unplanned hospital admissions among Medicare Fee-for-Service (FFS) patients aged 65 years and older with multiple chronic conditions (MCCs). (Measure Specifications)
    • Public comments received: 9
    • Workgroup Rationale: MAP conditionally supported MUC2019-37 MIPS Clinician and Clinician Group Risk-standardized Hospital Admission Rates for Patients with Multiple Chronic Conditions pending NQF endorsement. MAP noted that with over 80 percent of adults over the age of 65 having MCCs, this measure has the potential to significantly improve the quality of care for the Medicare beneficiary population. MAP also noted that this measure carries a higher reliability score than the measure considered for MIPS, and MAP considered it still appropriate for the SSP program. MAP noted that ACOs in SSP focus on processes and interventions that reduce disease progression and undesirable sequalae that lead to hospital admission for Medicare patients with MCCs. Moreover, the accountability structure of an ACO allows for stronger oversight and care coordination to influence measure performance within the ACO system.MAP identified several measure gaps within SSP: diagnostic efficiency, measures of cultural change, and additional measures of care coordination and hand-offs using eCQMs.
    • Workgroup Recommendation: Conditional Support for Rulemaking


  6. Transitions of Care between the Inpatient and Outpatient Settings including Notifications of Admissions and Discharges, Patient Engagement and Medication Reconciliation Post-Discharge (MUC ID: MUC2019-21)
    • Description: The intent of the measure is to improve the coordination of care for Medicare Advantage members as they transition between inpatient and outpatient settings. The measure assesses the percentage of discharges for members 18 years of age and older who had each of the following four indicators: notification of inpatient admission; receipt of discharge information; patient engagement after inpatient discharge; and medication reconciliation post-discharge. Plans report separate rates for individuals 18-64 years of age and those 65 years and older, as well as a total rate for each indicator in the measure. (Measure Specifications)
    • Public comments received: 5
    • Workgroup Rationale: MAP conditionally supported MUC2019-21 for rulemaking, pending NQF endorsement. MAP noted that this measure was also designated as a first-year measure for HEDIS 2018. MAP observed that Medicare beneficiaries are at particular risk during transitions of care because of higher comorbidities, declining cognitive function, and increased medication use. There is observed variance in performance among health plans on all four components of the measure. Further, evidence indicates that good care transitions and care coordination reduce healthcare costs and improve outcomes. MAP also noted that the medication reconciliation postdischarge component of this measure is already included in the Star Ratings as an independent measure and has been since 2017. The measure developer (NCQA) indicated its intention to work with CMS to develop a plan to avoid the need for health plans to report on both measures. MAP expressed concern that this measure is not entirely electronic, but it was noted that alternative data sources are not available. The Rural Health Workgroup noted the importance of measures to assess transitions of care for rural residents but that the measure requires chart abstraction, which can be particularly burdensome for small rural providers. They also noted that a yes/no checkbox measure of medication reconciliation may not drive improvements in care quality. There was some concern with the medication reconciliation component, particularly given the lack of pharmacists in rural areas.
    • Workgroup Recommendation: Conditional Support for Rulemaking


  7. Hemodialysis Vascular Access: Practitioner Level Long-term Catheter Rate (MUC ID: MUC2019-66)
    • Description: Percentage of adult hemodialysis patient-months using a catheter continuously for three months or longer for vascular access attributable to an individual practitioner or group practice. (Measure Specifications)
    • Public comments received: 7
    • Workgroup Rationale: MAP conditionally supported MUC2019-66 for rulemaking. As the measure has not been reviewed by an NQF CDP Standing Committee to determine the strength of the measure’s reliability and validity, MAP’s support is conditional upon NQF endorsement. MAP noted that the use of a long-term catheter has a higher observed mortality rate than the use of arteriovenous fistula, thus this measure has the potential to provide greater quality of care for patients by reducing the associated mortality and morbidity from long-term catheter use. MAP noted that a modified version of this measure is currently being used in a CMS quality program—the End-Stage Renal Disease Quality Improvement Program (ESRD QIP). The measure is undergoing changes to allow specification for individual clinicians and clinician groups. While MAP questioned the ability of providers to move patients from catheters to fistulas, the measure developer noted that clinicians can influence this as evidenced by rate improvements after implementation of this measure in ESRD QIP. MAP expressed concern on the reliability of the measure and encouraged CMS to rigorously test the measure. The Rural Health Workgroup noted that kidney diseases are prevalent conditions in rural populations. They emphasized that rural patients on dialysis are older and have more comorbidities, and voiced concern that these patients might be pressed to use a fistula, even when there is little benefit.
    • Workgroup Recommendation: Conditional Support for Rulemaking


  8. Use of Opioids at High Dosage in Persons without Cancer (OHD) (MUC ID: MUC2019-57)
    • Description: Percent of beneficiaries receiving opioid prescriptions with an average daily morphine milligram equivalent (MME) greater than or equal to 90 mg over a period of 90 days or longer. (Measure Specifications; Summary of NQF Endorsement Review)
    • Public comments received: 10
    • Workgroup Rationale: MAP conditionally supported for rulemaking MUC2019-57 Use of Opioids at High Dosage in Persons without Cancer (OHD). The condition of support was that other opioid measures considered would not move into the Star Ratings; this measure was otherwise considered fit for implementation without conditions. The measure has been endorsed by NQF at the health plan level as NQF 2940. MAP noted that this measure leads to health plans carefully considering the needs of patients at high doses, encouraging appropriate nonopioid pain management, providing appropriate personalized pain care plans, directly addressing OUD, and potentially tapering patients off of high dose opioid regimens. MAP noted that concerns have been raised that pressure from health plans to diminish prescribing could be associated with the unintended consequence of patients seeking illicitly obtained opioids or heroin. This may lead to changes in prescribing practices for clinicians to adhere to CDC prescribing guidelines that were intended to serve as guidance and not as a strict mandate. The MAP Rural Health Workgroup agreed that opioid use is a relevant issue for rural residents, but expressed concern that without a balancing measure, there is a potential for patient harm due to forced tapering and the potential for seeking illicit drugs to treat pain. Rural residents have relatively less access to alternative pain treatment and other resources.
    • Workgroup Recommendation: Conditional Support for Rulemaking


  9. Use of Opioids from Multiple Providers in Persons without Cancer (OMP) (MUC ID: MUC2019-60)
    • Description: Percent of beneficiaries receiving opioid prescriptions from 4 or more prescribers and 4 or more pharmacies within 180 days or less. (Measure Specifications; Summary of NQF Endorsement Review)
    • Public comments received: 9
    • Workgroup Rationale: During this cycle, MAP supported one measure for rulemaking in the Part C and D Star Ratings, MUC2019-60 Use of Opioids from Multiple Providers in Persons without Cancer (OMP). This measure appropriately identifies either mismanaged pain or potential opioid seeking behavior. MAP observed that the measure will encourage health plans to address pain management and OUD within their beneficiary population while avoiding unintended consequences associated with rapid decline of opioid dosages. MAP noted that this measure is endorsed at the health plan level as NQF 2950. MAP noted that all three opioid measures are currently in use in the SSP Opioid Utilization Reports as well as in the Part D Overutilization Monitoring System. The MAP Rural Health Workgroup suggested that although this measure could promote use of drug monitoring programs in rural areas, on the whole, it may not be particularly applicable due to the relatively few pharmacies in rural areas.
    • Workgroup Recommendation: Support for Rulemaking


  10. Use of Opioids from Multiple Providers and at a High Dosage in Persons without Cancer (OHDMP) (MUC ID: MUC2019-61)
    • Description: Percent of beneficiaries receiving opioid prescriptions with an average daily morphine milligram equivalent (MME) greater than or equal to 90 mg over a period of 90 days or longer, and opioid prescriptions from 4 or more prescribers and 4 or more pharmacies within 180 days or less. (Measure Specifications; Summary of NQF Endorsement Review)
    • Public comments received: 8
    • Workgroup Rationale: MAP did not support for rulemaking MUC2019-61 Use of Opioids from Multiple Providers and at a High Dosage in Persons without Cancer (OHDMP). MAP observed that this measure was endorsed in 2017 as NQF 2951. This measure was also seen as duplicative of the other two measures, with little added benefit to the program from the combined measure. MAP emphasized the need for parsimony in the measure set. Of the three proposed opioid measures, the MAP Rural Health Workgroup agreed this one was the least useful.
    • Workgroup Recommendation: Do Not Support for Rulemaking


3:00 PM   Break
3:25 PM   Pre-Rulemaking Recommendations for PAC/LTC Programs
Gerri Lamb, PAC/LTC Workgroup Co-Chair
Kurt Merkelz, PAC/LTC Workgroup Co-Chair
Amy Moyer, Director, NQF
Chip Kahn
Measures under consideration:
  1. Home Health Within-Stay Potentially Preventable Hospitalization Measure (MUC ID: MUC2019-34)
    • Description: This measure reports a home health agency (HHA)-level rate of risk-adjusted potentially preventable hospitalizations or observation stays that occur within a home health (HH) stay for all eligible stays at each agency. A HH stay is a sequence of HH payment episodes separated from other HH payment episodes by at least two days. (Measure Specifications)
    • Public comments received: 2
    • Workgroup Rationale: MAP conditionally supported MUC2019-34 Home Health Within-Stay Potentially Preventable Hospitalization, pending NQF review and endorsement. CMS clarified that it intends to eventually replace related measures, NQF 0171 Acute Care Hospitalization During the First 60 Days of Home Health and NQF 0173 Emergency Department Use without Hospitalization During the First 60 Days of Home Health with the measure under consideration. MAP agreed that the measure adds value to the program measure set by adding measurement of potentially preventable hospitalizations and observation stays that may occur at any point in the home health stay. No measure in the program currently provides this information. The measure supports alignment for the measure focus area of admissions and readmissions across care settings and providers. There is variation in performance on this measure, and home health agencies have the ability to implement processes and interventions that can positively influence the measure results. The MAP Rural Health Workgroup noted that older, poorer, and sicker patients reflected in rural populations often have issues with access to care. No public comments were received on this measure or on the HH QRP. MAP encouraged consideration of including Medicare Advantage patients in future iterations of the measure.
    • Workgroup Recommendation: Conditional Support for Rulemaking


  2. Hospice Visits in the Last Days of Life (MUC ID: MUC2019-33)
    • Description: The proportion of hospice patients who have received visits from a Registered Nurse or Medical Social Worker (non-telephonically) on at least two out of the final three days of the patient's life. (Measure Specifications)
    • Public comments received: 3
    • Workgroup Rationale: MAP recommended conditional support for rulemaking pending NQF review and endorsement and further recommended that the existing hospice visit measures be removed from the program. Collecting information about hospice staff visits for measuring quality of care will encourage hospices to visit patients and caregivers and provide services that will address their care needs and improve quality of life during the patient’s last days of life. MAP observed that currently, Hospice Visits When Death is Imminent, Measure 1 and Measure 2, address this quality objective in the Hospice QRP, but this measure performed better in validity and reliability testing and has lower provider burden because it is reported using claims data. MAP agreed that the goal of hospice is comfort. MAP encouraged that future iterations of this measure consider the quality of provider visits in addition to the quantity of visits. MAP members reviewed analysis from CMS demonstrating that not all types of provider visits correlate positively with Hospice CAHPS results. MAP examined the possible variations on the measure concept and generally agreed that the analysis supported the current proposed measure. The MAP Rural Health Workgroup noted concerns related to access to care in rural areas. Public comments expressed concern about overlap with the existing hospice visits measures. Commenters also had concerns with a hospice program’s ability to accurately identify imminent death, and with only including some members of the interdisciplinary team in the visits captured in the measure. The commenters suggested examining other options for this measure concept such as different numbers of visits.
    • Workgroup Recommendation: Conditional Support for Rulemaking


4:10 PM   Future Direction of the Pre-Rulemaking Process
Bruce Hall
Sam Stolpe

4:35 PM   Opportunity for Public Comment
4:45 PM   Closing Remarks and Next Steps
Bruce Hall
Chip Kahn
Kate Buchanan

5:00 PM   Adjourn for the Day

Appendix A: Measure Information

Measure Index

End-Stage Renal Disease Quality Incentive Program

Home Health Quality Reporting Program

Hospital Inpatient Quality Reporting (IQR) Program and Medicare and Medicaid Promoting Interoperability Program for Eligible Hospitals and Critical Access Hospitals (CAHs)

Hospice Quality Reporting Program

Inpatient Psychiatric Facility Quality Reporting Program

Merit-Based Incentive Payment System

Medicare Shared Savings Program

Prospective Payment System-Exempt Cancer Hospital Quality Reporting Program

Part C and D Star Ratings


Full Measure Information

Standardized Transfusion Ratio for Dialysis Facilities (Program: End-Stage Renal Disease Quality Incentive Program; MUC ID: MUC2019-64)

Measure Specifications

Summary of Workgroup Deliberations

Rationale for measure provided by HHS
The Medicare ESRD Program requires Medicare certified dialysis facilities to manage the anemia of CKD as one of their responsibilities under the Conditions for Coverage (1). In addition, the Medicare ESRD Program has included payment for ESAs in dialysis facility reimbursement since 1989. It is notable that inclusion of ESAs in dialysis program payment was associated with a dramatic reduction in the use of blood transfusions in the US chronic dialysis population (2-3). Recently, reliance on achieved hemoglobin concentration as an indicator of successful anemia management in this population has been de-emphasized and use of other clinically meaningful outcomes, such as transfusion avoidance, have been recommended as alternate measures of anemia management (4-7).
Best dialysis provider practice should include effective anemia management algorithms that focus on 1) prevention and treatment of iron deficiency, inflammation and other causes of ESA resistance, 2) use of the lowest dose of ESAs that achieves an appropriate target hemoglobin that is consistent with FDA guidelines and current best practices, and 3) education of patients, their families and medical providers to avoid unnecessary blood transfusion so that risk of allosensitization is minimized, eliminating or reducing one preventable barrier to successful kidney transplantation.
The decision to transfuse blood is intended to improve or correct the pathophysiologic consequences of severe anemia, defined by achieved hemoglobin or hematocrit%, in a specific clinical context for each patient situation (8). Consensus guidelines in the U.S. and other consensus guidelines defining appropriate use of blood transfusions are based, in large part, on the severity of anemia (9-11). Given the role of hemoglobin as a clinical outcome that defines anemia as well as forms a basis for consensus recommendations regarding use of blood transfusion, it is not surprising that the presence of decreased hemoglobin concentration is a strong predictor of subsequent risk for blood transfusion in multiple settings, including chronic dialysis (12-21). For example, Gilbertson, et al found a nearly four-fold higher risk-adjusted transfusion rate in dialysis patients with achieved hemoglobin <10 gm/dl compared to those with >10 gm/dl hemoglobin. (19) In addition to achieved hemoglobin, other factors related to dialysis facility practices, including the facility’s response to their patients achieved hemoglobin, may influence blood transfusion risk in the chronic dialysis population (22, 25). In an observational study recently published by Molony, et al (2016) comparing different facility level titration practices, among patients with hemoglobin <10 and those with hemoglobin>11, they found increased transfusion risk in patients with larger ESA dose reductions and smaller dose escalations, and reduced transfusion risk in patients with larger ESA dose increases and smaller dose reductions (25). The authors reported no clinically meaningful differences in all-cause or cause-specific hospitalization events across groups.
The Food and Drug Administration position defining the primary indication of ESA use in the CKD population is for transfusion avoidance, reflecting the assessment of the relative risks and benefits of ESA use versus blood transfusion. Several historical studies, and one recent research study reviewed by Obrador and Macdougall, document the specific risks of allosensitization after blood transfusion and the potential for transfusion-associated allosensitization to interfere with timely kidney transplantation. (23) A recent analysis demonstrated increased odds ratios for allosensitization associated with transfusion, particularly for men and parous women. That study also demonstrated a 28% reduction in likelihood of transplantation in transfused individuals, based on a multivariate risk-adjusted statistical model. (24) REFERENCES1. ESRD Facility Conditions for Coverage. https://www.cms.gov/Center/Special-Topic/End-Stage-Renal-Disease-ESRD-Center.html. 2. Eschbach et al. Recombinant Human Erythropoietin in Anemic Patients with End-Stage Renal Disease. Results of a Phase III Multicenter Clinical Trial. Annals of Internal Medicine. 1989;111:992-1000.3. Powe et al. Early dosing practices and effectiveness of recombinant human erythropoietin. Kidney International, Vol. 43 (1993), pp. 1125—1133. 4. FDA Drug Safety Communication: Modified dosing recommendations to improve the safe use of Erythropoiesis-Stimulating Agents (ESAs) in chronic kidney disease. http://www.fda.gov/Drugs/DrugSafety/ucm259639.htm. 5. Kidney Disease: Improving Global Outcomes (KDIGO) Anemia Work Group. KDIGO Clinical Practice Guideline for Anemia in Chronic Kidney Disease. Kidney inter., Suppl. 2012; 2: 279–335. http://www.kdigo.org/clinical_practice_guidelines/pdf/KDIGO-Anemia%20GL.pdf.6. Kliger et al. KDOQI US Commentary on the 2012 KDIGO Clinical Practice Guideline for Anemia in CKD. Am J Kidney Dis. 62(5):849-859. 7. Berns, Jeffrey S., Moving Away From Hemoglobin-Based Anemia Performance Measures in Dialysis Patients. Am J Kidney Dis. 2014;64(4):486-488. 8. Whitman, Shreay, Gitlin, van Oijen, & Spiegel. Clinical Factors and the Decision to Transfuse Chronic Dialysis Patients. Clin J Am Soc Nephrol 8: ccc–ccc, 2013. doi: 10.2215/CJN.00160113. 9. Carson et al. Red Blood Cell Transfusion: A Clinical Practice Guideline From the AABB. Ann Intern Med. 2012;157:49-58. 10. American Society of Anesthesiologists Task Force on Perioperative Blood Transfusion and Adjuvant Therapies. Practice guidelines for perioperative blood transfusion and adjuvant therapies: an updated report by the American Society of Anesthesiologists Task Force on Perioperative Blood Transfusion and Adjuvant Therapies. Anesthesiology. 2006;105:198–208. 11. Munoz et al. “Fit to flyâ€; overcoming barriers to preoperative haemoglobin optimization in surgical patients. Br J Anaesth. 2015 Jul;115(1):15-24. 12. Dunne, Malone, Tracy, Gannon, and Napolitano. Perioperative Anemia: An Independent Risk Factor for Infection, Mortality, and Resource Utilization in Surgery. Journal of Surgical Research 102, 237-244 (2002). 13. Covin R, O'Brien M, Grunwald G, Brimhall B, Sethi G, Walczak S, Reiquam W, Rajagopalan C, Shroyer AL Factors affecting transfusion of fresh frozen plasma, platelets, and red blood cells during elective coronary artery bypass graft surgery. Arch Pathol Lab Med. 2003 Apr;127(4):415-23. 14. Jans et al. Role of preoperative anemia for risk of transfusion and postoperative morbidity in fast-track hip and knee arthroplasty. Transfusion. 2014 Mar;54(3):717-26.15. Saleh et al. Allogenic Blood Transfusion Following Total Hip Arthroplasty: Results from the Nationwide Inpatient Sample, 2000 to 2009. J Bone Joint Surg Am. 2014;96:e155(1-10).16. Ejaz, Spolverato, Kim, Frank, and Pawlik. Variations in triggers and use of perioperative blood transfusions in major gastrointestinal surgery. Br. J. Surg. 2014 Oct;101(11):1424-33.17. Foley, Curtis, & Parfrey. Hemoglobin Targets and Blood Transfusions in Hemodialysis Patients without Symptomatic Cardiac Disease Receiving Erythropoietin Therapy. Clin J Am Soc Nephrol 3: 1669–1675, 2008. doi: 10.2215/CJN.02100508. 18. Hirth, Turenne, Wilk et al. Blood transfusion practices in dialysis patients in a dynamic regulatory environment. Am J Kidney Dis. 2014 Oct;64(4):616-21. doi: 10.1053/j.ajkd.2014.01.011. Epub 2014 Feb. 19. Gilbertson, Monda, Bradbury & Collins. RBC Transfusions Among Hemodialysis Patients (1999-2010): Influence of Hemoglobin Concentrations Below 10 g/dL. Am J Kidney Dis. 2013; Volume 62 , Issue 5 , 919 – 928.20. Collins et al. Effect of Facility-Level Hemoglobin Concentration on Dialysis Patient Risk of Transfusion. Am J Kidney Dis. 2014; 63(6):997-1006. 21. Cappell et al. Red blood cell (RBC) transfusion rates among US chronic dialysis patients during changes to Medicare end-stage renal disease (ESRD) reimbursement systems and erythropoiesis stimulating agent (ESA) labels. BMC Nephrology 2014, 15:116. 22. House AA, Pham B, Pagé DE. Transfusion and recombinant human erythropoietin requirements differ between dialysis modalities. Nephrol Dial Transplant. 1998 Jul;13(7):1763-9. 23. Obrador and Macdougall. Effect of Red Cell Transfusions on Future Kidney Transplantation. Clin J Am Soc Nephrol 8: 852–860, 2013.24. Ibrahim, et al. Blood transfusions in kidney transplant candidates are common and associated with adverse outcomes. Clin Transplant 2011: 25: 653–659. 25. Molony, et al. Effects of epoetin alfa titration practices, implemented after changes to product labeling, on hemoglobin levels, transfusion use, and hospitalization rates. Am J Kidney Dis 2016: epub before print (published online March 12, 2016).

Summary of NQF Endorsement Review




Home Health Within-Stay Potentially Preventable Hospitalization Measure (Program: Home Health Quality Reporting Program; MUC ID: MUC2019-34)

Measure Specifications