NQF
Version Number: 5.6
Meeting
Date: December 13, 2017
Measure Applications Partnership
PAC/LTC Workgroup Discussion
Guide
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Agenda
Agenda Synopsis
Full Agenda
8:30 am |
Breakfast |
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9:00 am |
Welcome, Introductions, Disclosures of Interest, and
Review of Meeting Objectives |
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Gerri Lamb, Workgroup Co-Chair Paul Mulhausen, Workgroup Co-Chair Erin
O’Rourke, Senior Director, NQF Jean-Luc Tilly, Senior Project Manager,
NQF Miranda Kuwahara, Project Analyst, NQF Elisa Munthali, Vice President,
NQF
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9:15 am |
CMS Opening Remarks and Review of Meaningful Measures
Framework |
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Pierre Yong, CMS
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9:35 am |
MAP Rural Health Introduction and
Presentation |
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Karen Johnson, Senior Director, NQF
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10:00 am |
Update on Implementation of the IMPACT Act |
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• Measure alignment and future direction
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10:30 am |
Update on the PROMIS Tool |
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• Results of national field test
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11:15 am |
Applications of MIPS in PAC-LTC |
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11:45 am |
Overview of Pre-Rulemaking Approach |
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Jean-Luc Tilly, Senior Project Manager, NQF
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12:15 pm |
Lunch |
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12:45 pm |
Skilled Nursing Quality Reporting Program (SNF
QRP) |
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• Overview of the SNF QRP • Opportunity for Public Comment: Measures
under Consideration • Pre-Rulemaking Input: SNF QRP Measures Under
Consideration Consent Calendar - CoreQ: Short Stay Discharge Measure (MUC
ID: MUC17-258) • Feedback on Gaps in the SNF QRP |
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Programs under consideration: Skilled
Nursing Facility Quality Reporting Program
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- CoreQ: Short Stay Discharge Measure (MUC ID: MUC17-258)
- Description: The measure calculates the percentage of
individuals discharged in a six-month time period from a SNF, within
100 days of admission, who are satisfied. This patient reported
outcome measure is based on the CoreQ: Short Stay Discharge
questionnaire that utilizes four items. The following are the four
items: 1. In recommending this facility to your friends and family,
how would you rate it overall? (Poor, Average, Good, Very Good, or
Excellent) 2. Overall, how would you rate the staff? (Poor, Average,
Good, Very Good, or Excellent) 3. How would you rate the care you
receive? (Poor, Average, Good, Very Good, or Excellent) 4. How would
you rate how well your discharge needs were met? (Poor, Average, Good,
Very Good, or Excellent) (Measure
Specifications; Summary
of NQF Endorsement Review)
- Public comments received: 7
- Preliminary analysis summary (Full
Preliminary Analysis)
- Contribution to program measure set:MAP has stressed the
important of patient centered care. This measure would address a
MAP PAC/LTC Core Concept of patient experience that is not currently
addressed in the program measure set.
- Impact on quality of care for patients:Patient
satisfaction is a high-priority domain for performance improvement
across Medicare pay-for-reporting and pay-for-performance programs.
As there is a substantial performance gap across most skilled
nursing facilities tested, the positive impact on quality of care
brought about by this performance measure is likely to be
substantial.
- Preliminary analysis result:
Support
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1:30 pm |
Hospice Quality Reporting Program (HQRP) |
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• Overview of the HQRP • Feedback on Gaps in the HQRP |
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Programs under consideration: Hospice
Quality Reporting Program
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1:45 pm |
Long-Term Care Hospital Quality Reporting Program
(LTCH QRP) |
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• Overview of the LTCH QRP • Feedback on Gaps in the LTCH QRP |
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Programs under consideration: Long-Term
Care Hospital Quality Reporting Program
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2:00 pm |
Inpatient Rehabilitation Facility Quality Reporting
Program (IRF QRP) |
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• Overview of the IRF QRP • Feedback on Gaps in the IRF QRP |
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Programs under consideration: Inpatient
Rehabilitation Facility Quality Reporting Program
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2:15 pm |
Home Health Quality Reporting Program (HH
QRP) |
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• Overview of the HH QRP • Feedback on Gaps in the HH QRP |
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Programs under consideration: Home
Health Quality Reporting Program
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2:30 pm |
Opportunity for Public Comment |
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2:45 pm |
Break |
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3:00 pm |
Input on Measure Removal Criteria |
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3:30 pm |
Review of NQF’s Attribution Work and Guidance on
Attribution Challenges in PAC/LTC Settings |
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Erin O’Rourke, Senior Director, NQF Jean-Luc Tilly, Senior Project
Manager, NQF
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4:00 pm |
Update on Equity Program |
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Jean-Luc Tilly, Senior Project Manager, NQF
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4:30 pm |
Opportunity for Public Comment |
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4:45 pm |
Summary of Day |
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Gerri Lamb, Workgroup Co-Chair Paul Mulhausen, Workgroup Co-Chair
Miranda Kuwahara, Project Analyst, NQF
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5:00 pm |
Adjourn |
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Appendix A: Measure Information
Measure Index
Skilled Nursing Facility Quality Reporting Program
Full Measure Information
Measure Specifications
- NQF Number (if applicable): 2614
- Description: The measure calculates the percentage of individuals
discharged in a six-month time period from a SNF, within 100 days of
admission, who are satisfied. This patient reported outcome measure is based
on the CoreQ: Short Stay Discharge questionnaire that utilizes four items. The
following are the four items: 1. In recommending this facility to your
friends and family, how would you rate it overall? (Poor, Average, Good, Very
Good, or Excellent) 2. Overall, how would you rate the staff? (Poor, Average,
Good, Very Good, or Excellent) 3. How would you rate the care you receive?
(Poor, Average, Good, Very Good, or Excellent) 4. How would you rate how well
your discharge needs were met? (Poor, Average, Good, Very Good, or
Excellent)
- Numerator: The numerator is the sum of the individuals in the
facility that have an average satisfaction score of greater than or equal to 3
for the four questions on the CoreQ: Short Stay Discharge questionnaire that
utilizes four items. The following are the four items: 1. In recommending
this facility to your friends and family, how would you rate it overall?
(Poor, Average, Good, Very Good, or Excellent) 2. Overall, how would you rate
the staff? (Poor, Average, Good, Very Good, or Excellent) 3. How would you
rate the care you receive? (Poor, Average, Good, Very Good, or Excellent) 4.
How would you rate how well your discharge needs were met? (Poor, Average,
Good, Very Good, or Excellent)
- Denominator: The denominator includes all of the patients that are
admitted to the SNF, regardless of payor source, for post-acute care, that are
discharged within 100 days; who receive the survey (e.g. people meeting
exclusions do not receive a questionnaire) and who respond to the CoreQ: Short
Stay Discharge questionnaire within two months of receiving the questionnaire.
- Exclusions: Exclusions made at the time of sample selection and the
following: (1) Patients who died during their SNF stay; (2) Patients
discharged to a hospital, another SNF, psychiatric facility, inpatient
rehabilitation facility or long term care hospital; (3) Patients with court
appointed legal guardian for all decisions; (4) Patients discharged on
hospice; (5) Patients who left the nursing facility against medical advice
(AMA); (6) Patients who have dementia impairing their ability to answer the
questionnaire defined as having a BIMS score on the MDS 3.0 as 7 or lower.
[Note: we understand that some SNCCs may not have information on cognitive
function available to help with sample selection. In that case, we suggest
administering the survey to all residents and assume that those with cognitive
impairment will not complete the survey or have someone else complete on their
behalf which in either case will exclude them from the analysis.]
Additionally, once the survey is administered, the following exclusions are
applied: (a) Patients who responded after the two-month response period; and
(b) Patients whose responses were filled out by someone else. (Note this does
not include cases where the resident solely had help such as reading the
questions or writing down their responses.) Surveys returned as un-deliverable
are also excluded from the denominator.
- HHS NQS Priority: Patient and Family Engagement, Communication and
Care Coordination
- HHS Data Source: Administrative Clinical Data, Other
- Measure Type: Patient Reported Outcome
- Steward: Centers for Medicare & Medicaid Services
- Endorsement Status: Endorsed
- Changes to Endorsed Measure Specifications?: The MUC list
indicates the measure has been modified from its endorsed
version.
- Is the measure specified as an electronic clinical quality measure?
No
Preliminary Analysis of Measure
- Preliminary analysis result: Support
- Preliminary analysis summary
- Contribution to program measure set:MAP has stressed the
important of patient centered care. This measure would address a MAP
PAC/LTC Core Concept of patient experience that is not currently addressed
in the program measure set.
- Impact on quality of care for patients:Patient satisfaction is a
high-priority domain for performance improvement across Medicare
pay-for-reporting and pay-for-performance programs. As there is a
substantial performance gap across most skilled nursing facilities tested,
the positive impact on quality of care brought about by this performance
measure is likely to be substantial.
- Does the measure address a critical quality objective not adequately
addressed by the measures in the program set? Yes. At present, the SNF QRP
does not include any patient-reported outcome measures, nor any measures
directly addressing patient satisfaction. Moreover, one of the four questions
in the survey addresses satisfaction with discharge, a component of quality
CMS has identified as a high-priority domain.
- Is the measure evidence-based and is either strongly linked to outcomes
or an outcome measure? The measure is a patient-reported outcome measuring
satisfaction across four items: 1) recommendation to friends and family, 2)
overall rating, 3) care rating, and 4) discharge needs met rating. . The
measure is a patient-reported outcome measuring satisfaction across four
items: 1) recommendation to friends and family, 2) overall rating, 3) care
rating, and 4) discharge needs met rating. The measure result is a
non-weighted percentage score: • The numerator is the number of patients who
are discharged from a SNF, within 100 days of admission, who are satisfied. •
The denominator is all patients that are admitted to the SNF, regardless of
payor source, for post-acute care, that are discharged within 100 days; who
receive the survey (e.g. people meeting exclusions do not receive a
questionnaire) and who respond to the CoreQ: Short Stay Discharge
questionnaire within the time window. • Satisfied individuals are those that
have an average satisfaction score of =>3 for the four questions on the
CoreQ: Short Stay Discharge questionnaire
- Does the measure address a quality challenge? Yes. Testing of the
measure score indicated there is a significant performance gap. The median
score is 82.5 (out of 100), indicating substantial room for improvement.
Moreover, performance is largely clustered around the median - 75th
percentile performance is at 88.6, so even top performers have the potential
to improve patient satisfaction.
- Does the measure contribute to efficient use of resources and/or
support alignment of measurement across programs? Yes. Patient
satisfaction surveys are currently in use across several Medicare programs,
including the HCAHPS survey used in the Hospital Inpatient Quality Reporting
Program and the Hospital Value-Based Purchasing Program and the Home Health
CAHPS survey used in the Home Health Quality Reporting Program. During the NQF
endorsement review of this measure, it was noted that this measure could
potentially compete with the Nursing Home CAHPS survey. However, the measures
derived from NH CAHPS have lost NQF endorsement and AHRQ has noted a lack of
resources to maintain them. This MUC is derived from an instrument that
contains four items, making it brief compared to other patient satisfaction
surveys. The develop notes that this measure has already integrated into
existing systems as a consequence of the testing regimen. However, it may be
necessary for nursing home to work with a vendor to collect the required data.
During the endorsement review the developer noted there were no fees
associated with the use of the measure. The developer did not indicate if
there are fees associated with the use of the survey.
- Can the measure can be feasibly reported? Yes. The data sources for
the measure are the CoreQ: Short Stay Discharge questionnaire and Resident
Assessment Instrument Minimum Data Set (MDS) version 3.0. The developer notes
that satisfaction survey vendors have already incorporated the MUC’s data
elements in their software. The ACHA website lists customer satisfaction
vendors using the CoreQ.
- Is the measure reliable and valid for the level of analysis, program,
and/or setting(s) for which it is being considered? Yes. NQF #2614 is
endorsed for the facility level of analysis. NQF# 2614 was evaluated as part
of the third phase of the 2015-2017 Person and Family-Centered Care project.
The PFCC Standing Committee voted by margins of 78% and 83% to advance the
measure based on NQF’s criteria for reliability and validity, respectively.
During the review of scientific acceptability, committee members raised
concerns that patients who have dementia impairing their ability to answer the
questionnaire defined as having a BIMS score on the MDS as 7 or lower were
excluded from the measure and that these exclusions could limit the
generalizability of the survey. The developer agreed that cognitive impairment
does have an effect in this setting and that by having everyone use the BIMs
score, which is used to get a snapshot of how well someone is functioning
cognitively at a given moment, allows for a more consistent approach across
all nursing home residents. A standardized approach helps reduce the incidence
of gaming. Ultimately, the Committee was in agreement with the indirect
standardization procedure used in this measure to adjust for the impairment
type of the patient, functional status at admission, and age at admission. The
measure does not use another risk adjustment approach to address additional
clinical or social risk factors.
- Measure development status: Fully Developed
- Is the measure NQF endorsed for the program's setting and level of
analysis? Endorsed
Rationale for measure provided by HHS
Collecting satisfaction
information from skilled nursing facility (SNF) patients is more important now
than ever. We have seen a philosophical change in healthcare that now includes
the patient and their preferences as an integral part of the system of care. The
Institute of Medicine (IOM) endorses this change by putting the patient as
central to the care system (IOM, 2001). For this philosophical change to
person-centered care to succeed, we have to be able to measure patient
satisfaction for these three reasons: (1) Measuring satisfaction is necessary
to understand patient preferences. (2) Measuring and reporting satisfaction
with care helps patients and their families choose and trust a health care
facility. (3) Satisfaction information can help facilities improve the quality
of care they provide. The implementation of person-centered care in SNFs has
already begun, but there is still room for improvement. The Centers for Medicare
and Medicaid Services (CMS) demonstrated interest in consumers’ perspective on
quality of care by supporting the development of the Consumer Assessment of
Healthcare Providers and Systems (CAHPS) survey for patients in nursing
facilities (Sangl et al., 2007). Further supporting person-centered care and
resident satisfaction are ongoing organizational change initiatives. These
include: the Advancing Excellence in America’s Nursing Homes campaign (2006),
which lists person-centered care as one of its goals; Action Pact, Inc., which
provides workshops and consultations with nursing facilities on how to be more
person-centered through their physical environment and organizational structure;
and Eden Alternative, which uses education, consultation, and outreach to
further person-centered care in nursing facilities. All of these initiatives
have identified the measurement of resident satisfaction as an essential part in
making, evaluating, and sustaining effective clinical and organizational changes
that ultimately result in a person-centered philosophy of care. The importance
of measuring resident satisfaction as part of quality improvement cannot be
stressed enough. Quality improvement initiatives, such as total quality
management (TQM) and continuous quality improvement (CQI), emphasize meeting or
exceeding “customer” expectations. William Deming, one of the first proponents
of quality improvement, noted that “one of the five hallmarks of a quality
organization is knowing your customer’s needs and expectations and working to
meet or exceed them” (Deming, 1986). Measuring resident satisfaction can help
organizations identify deficiencies that other quality metrics may struggle to
identify, such as communication between a patient and the provider. As part of
the U.S. Department of Commerce renowned Baldrige Criteria for organizational
excellence, applicants are assessed on their ability to describe the links
between their mission, key customers, and strategic position. Applicants are
also required to show evidence of successful improvements resulting from their
performance improvement system. An essential component of this process is the
measurement of customer, or resident, satisfaction (Shook & Chenoweth,
2012). The CoreQ: Short Stay Discharge questionnaire can strategically help
nursing facilities achieve organizational excellence and provide high quality
care by being a tool that targets a unique and growing patient population. Over
the past several decades, care in nursing facilities has changed substantially.
Statistics show that more than half of all elders cared for in nursing homes are
now discharged home (approximately 1.6 million residents; CMS, 2009). Moreover,
when satisfaction information from current residents (i.e., long stay residents)
is compared with those of elders discharged home, substantial differences exist
(Castle, 2007). This indicates that long stay and short stay residents are
different populations with different needs in the nursing facilities. Moreover,
residents are more likely to follow medical advice when they rate their care as
satisfactory (Hall, Milburn, Roter, & Daltroy, 1998). Thus, the CoreQ: Short
Stay Discharge questionnaire measure is needed to improve the care for short
stay SNF patients. Furthermore, improving the care for short stay nursing home
patients is tenable. A review of the literature on satisfaction surveys in
nursing facilities (Castle, 2007) concluded that substantial improvements in
resident satisfaction could be made in many nursing facilities by improving care
(i.e., changing either structural or process aspects of care). This was based
on satisfaction scores ranging from 60 to 80% on average. It is worth noting,
few other generalizations could be made because existing instruments used to
collect satisfaction information are not standardized. Thus, bench-marking
scores and comparison scores (i.e., best in class) were difficult to establish.
The CoreQ: Short Stay Discharge measure has considerable relevance in
establishing benchmarking scores and comparison scores. This measure’s relevance
is furthered by recent federal legislative actions. The Affordable Care Act of
2010 requires the Secretary of Health and Human Services (HHS) to implement a
Quality Assurance & Performance Improvement Program (QAPI) within nursing
facilities. This means all nursing facilities have increased accountability for
continuous quality improvement efforts. In CMS’s “QAPI at a Glance” document
there are references to customer-satisfaction surveys and organizations
utilizing them to identify opportunities for improvement. Lastly, the new
“Medicare and Medicaid Programs; Reform of Requirements for Long-Term Care
Facilities” proposed rule includes language purporting the importance of
satisfaction and measuring satisfaction. CMS states “CMS is committed to
strengthening and modernizing the nation’s health care system to provide access
to high quality care and improved health at lower cost. This includes improving
the patient experience of care, both quality and satisfaction, improving the
health of populations, and reducing the per capita cost of health care.” There
are also other references in proposed rules speaking to improving resident
satisfaction and increasing person-centered care (Medicare and Medicaid
Programs; Reform of Requirements for Long-Term Care Facilities, 2015). The
CoreQ: Short Stay Discharge measure has considerable applicability to both of
these initiatives. References: Castle, N.G. (2007). A literature review of
satisfaction instruments used in long-term care settings. Journal of Aging and
Social Policy, 19(2), 9-42. CMS (2009). Skilled Nursing Facilities Non Swing Bed
- Medicare National Summary.
http://www.cms.hhs.gov/MedicareFeeforSvcPartsAB/Downloads/NationalSum2007.pdf
CMS, University of Minnesota, and Stratis Health. QAPI at a Glance: A step by
step guide to implementing quality assurance and performance improvement (QAPI)
in your nursing home.
https://www.cms.gov/Medicare/Provider-Enrollment-and-Certification/QAPI/Downloads/QAPIAtaGlance.pdf.
Deming, W.E. (1986). Out of the crisis. Cambridge, MA. Massachusetts
Institute of Technology, Center for Advanced Engineering Study. Hall J, Milburn
M, Roter D, Daltroy L. Why are sicker patients less satisfied with their medical
care? Tests of two explanatory models. Health Psychol. 1998;17(1):70-75.
Institute of Medicine (2001). Improving the Quality of Long Term Care, National
Academy Press, Washington, D.C., 2001. Medicare and Medicaid Programs; Reform of
Requirements for Long-Term Care Facilities; Department of Health and Human
Services. 80 Fed. Reg. 136 (July 16, 2015) (to be codified at 42 CFR Parts 405,
431, 447, et al.). MedPAC. (2015). Report to the Congress: Medicare Payment
Policy.
http://www.medpac.gov/docs/default-source/reports/mar2015_entirereport_revised.pdf.
Sangl, J., Bernard, S., Buchanan, J., Keller, S., Mitchell, N., Castle, N.G.,
Cosenza, C., Brown, J., Sekscenski, E., and Larwood, D. (2007). The development
of a CAHPS instrument for nursing home residents. Journal of Aging and Social
Policy, 19(2), 63-82. Shook, J., & Chenoweth, J. (2012, October). 100 Top
Hospitals CEO Insights: Adoption Rates of Select Baldrige Award Practices and
Processes. Truven Health Analytics.
http://www.nist.gov/baldrige/upload/100-Top-Hosp-CEO-Insights-RB-final.pdf.
Summary of NQF Endorsement Review
- Year of Most Recent Endorsement Review: 2017
- Project for Most Recent Endorsement Review: Person and Family
Centered Care Project 2016-2017
- Review for Importance: 1a. Evidence, 1b. Performance Gap)1a.
Evidence: Y-17; N-1; 1b. Performance Gap: H-7; M-10; L-1; I-0Rationale: •
Committee members noted that this is a very significant measure for those who
go into a nursing home or a SNF who will not stay indefinitely or for a long
period of time. Measuring patient satisfaction and the rate of discharges back
into the community is very important to measurement as including the patient
and their preferences is becoming an integral part of healthcare’s changing
landscape. Additionally, measuring and reporting satisfaction with carehelps
patients and their families choose and trust a healthcare facility and can
help facilities improve the quality of the care they provide. • One committee
member had a question about the scale being used for this measure and felt
that the choice of the response scale (poor, average, good, very good, and
excellent) seemed heavily weighted towards positive responses. The developer
explained that they did focus groups and cognitive testing of different
response scales from ten points down to four point Likert scales and found
that no matter how they captured responses, they had different satisfaction
scores but the relative ranking remained the same. • Overall, committee
members liked that there was a conceptual framework at the beginning of the
measure submission form that linked the measure with information on additional
improvement programs, organizational change initiatives, and policies that are
going on both atthe federal level and the facility level.
- Review for Scientific Acceptability: 2a. Reliability: H-6; M-8;
L-4; I-0 2b. Validity: H-6; M-9; L-3; I-0 Rationale: • One committee member
felt that the exclusions may limit the generalizability to a small proportion
of facility nursing home patients. • There was additional concern around the
consistency of implementation across facilities and the possibility that
scores could be compromised by the low response rate. 27 • Committee members
also questioned the test/retest reliability at the patient level and sample
size. The developer explained that the data elements were tested using a
test-retest methodology: the survey was sent out and responses received from
853 patients; 100 were resurveyed one month later. The developer responded to
these concerns by saying that while morbidity does occur, and may affect the
data, there is an emphasis on making sure that both the voice of the patient
and the voice of the family are heard. • There was also discussion around
cognitive impairment and the effect this has on the survey’s overall
responses. The developer agreed that cognitive impairment does have an effect
in this setting and that by having everyone use the BIMs score, which is used
to get a snapshot of how well someone is functioning cognitively at a given
moment, allows for a more consistent approach across all nursing home
residents. A standardized approach helps reduce the incidence of gaming. • One
committee member had a question on the methodology used to reduce the number
of items in the tool and how they got from 22 to 4 items without losing some
precision. The developer responded that the process was extremely iterative
and was done hundreds of times. The purpose of this was to try and get to the
items that were capturing the most satisfaction information that did not
overlap with other items and if two items correlated very highly, it made
sense to drop one of them. • All members agreed with the decision not to risk
adjust as it is inappropriate to control out differences based on
sociodemographic factors. • Cognitive testing was done with family members,
residents, and with short stay residents. The developers collected more than
100 responses from each population at facilities in Pittsburgh. This testing
was conducted by reading questions and having the testing groups respond back
based on what they thought was being asked and if they felt it could be asked
differently. The committee indicated providing the results of this testing,
although supplemental, would have been useful information.
- Review for Feasibility: 3. Feasibility: H-5; M-13; L-0; I-0(3a.
Clinical data generated during care delivery; 3b. Electronic sources; 3c.
Susceptibility to inaccuracies/unintended consequences identified 3d. Data
collection strategy can be implemented)Rationale:• The committee agreed that
this tool is timely as there is currently no required experience ofcare
reporting or measurement in the SNF population.• Members appreciated that this
tool is brief especially since the staffing in this area tends to bevery
sparse.
- Review for Usability: 4. Usability and Use: H-5; M-11; L-2;
I-0(Used and useful to the intended audiences for 4a. Accountability and
Transparency; 4b. Improvement;and 4c. Benefits outweigh evidence of unintended
consequences)Rationale:• The committee did not have any concerns or questions
about the use and usability.285. Related and Competing Measures• This measure
was identified as related with #2615: CoreQ: Long-Stay Resident Measure
and#2616: CoreQ: Long-Stay Family Measure, submitted by the same
developer.
- Review for Related and Competing Measures: 5. Related and Competing
Measures• No related or competing measures noted.
- Endorsement Public Comments: 6. Public and Member Comment• No
comments were received on this measure.
- Endorsement Committee Recommendation: 7. Consensus Standards
Approval Committee (CSAC) Review (October 18, 2016): Y-16; N-0Decision:
Approved for endorsement
Appendix B: Program Summaries
TrueCMS Program Specific
Measure Priorities and Needs document, which was released in April 2017.
Program Index
Full Program Summaries
TrueCMS Program
Specific Measure Priorities and Needs document, which was released in April
2017.
Program History and Structure: The Quality Reporting Program (QRP) for
Inpatient Rehabilitation Facilities (IRFs) was established in accordance with
section 1886(j) of the Social Security Act as amended by section 3004(b) of the
Affordable Care Act. The IRF QRP applies to all IRF facilities that receive the
IRF PPS (e.g., IRF hospitals, IRF units that are co-located with affiliated
acute care facilities, and IRF units affiliated with critical access hospitals
[CAHs]). Data sources for IRF QRP measures include Medicare FFS claims, the
Center for Disease Control’s National Health Safety Network (CDC NHSN) data
submissions, and Inpatient Rehabilitation Facility - Patient Assessment
instrument (IRF-PAI) records. The IRF QRP measure development and selection
activities take into account established national priorities and input from
multi-stakeholder groups. Beginning in FY 2014, IRFs that fail to submit data
will be subject to a 2.0 percentage point reduction of the applicable IRF
Prospective Payment System (PPS) payment update. Plans for future public
reporting of IRF QRP measures are under development. Further, the Improving
Medicare Post-Acute Care Transformation of 2014 (IMPACT Act) amends title XVIII
(Medicare) of the Social Security Act (the Act) to direct the Secretary of the
Department of Health and Human Services (HHS) to require Long-term Care
Hospitals (LTCHs), Inpatient Rehabilitation Facilities (IRFs), Skilled Nursing
Facilities (SNFs) and Home Health Agencies (HHAs) to report standardized patient
assessment data, data on quality measures including resource use measures. The
development of standardized data stems from specified assessment domains via the
assessment instruments that are used to submit assessment data to CMS by these
post-acute care (PAC) providers. The IMPACT Act requires CMS to develop and
implement quality measures from five measure domains: functional status,
cognitive function, and changes in function and cognitive function; skin
integrity and changes in skin integrity; medication reconciliation; incidence of
major falls; and the transfer of health information when the individual
transitions from the hospital/critical access hospital to PAC provider or home,
or from PAC provider to another settings. The IMPACT Act also delineates the
implementation of resource use and other measures in at least these following
domains: total estimated Medicare spending per beneficiary; discharge to the
community; and all condition risk adjusted potentially preventable hospital
readmission rates.
High Priority Domains for Future Measure Consideration:
CMS identified
the following four domains as high-priority for future measure consideration:
1. Making Care
Affordable: An important consideration for the IRF QRP is to better assess
medical costs based on PAC episodes of care. Therefore, CMS is considering
developing efficiencybased measures such as a Medicare Spending per Beneficiary
measure concept.
2.
Communication/Care Coordination: Assessing resident care transitions and
rehospitalizations are important. Therefore, CMS is considering developing
measures that assesses discharge to the community and potentially preventable
readmissions.
3.
Communication/Care Coordination: Infrastructure and processes for care
coordination are important for the IRF QRP. The World Health Organization
regards implementing medication reconciliation as a standard operating protocol
necessary to reduce the potential for ADEs that cause harm to
patients.
Preventing and responding to ADEs
is of critical importance as ADEs account for significant increases in health
services utilization and costs. Medication reconciliation conceptually
highlights care transitions and resident follow-up. Therefore, a medication
reconciliation quality measure for IRF patients is being considered for future
quality measure development.
4.
Communication/Care Coordination: Discharge to a community setting is an
important health care outcome for patients in post-acute settings, offering a
multi-dimensional view of preparation for community life, including the
cognitive, physical, and psychosocial elements involved in a discharge to the
community. Being discharged to the community is an important outcome for many
patients for whom the overall goals of care include optimizing functional
improvement, returning to a previous level of independence, and avoiding
institutionalization. Therefore, a discharge to community measure for IRFs is
being considered for the future use in the IRF QRP.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
TrueCMS Program Specific
Measure Priorities and Needs document, which was released in April 2017.
Program History and Structure: The Improving Medicare Post-Acute Care
Transitions Act of 2014 (The IMPACT Act) added Section 1899B to the Social
Security Act establishing the Skilled Nursing Facility Quality Reporting Program
(SNF QRP). Facilities that submit data under the SNF PPS are required to
participate in the SNF QRP, excluding units that are affiliated with critical
access hospitals (CAHs). Data sources for SNF QRP measures include Medicare FFS
claims as well as Minimum Data Set (MDS) assessment data. The SNF QRP measure
development and selection activities take into account established national
priorities and input from multi-stakeholder groups. Beginning in FY 2018,
providers that fail to submit required quality data to CMS will have their
annual updates reduced by 2.0 percentage points. Further, the Improving
Medicare Post-Acute Care Transformation of 2014 (IMPACT Act) amends title XVIII
(Medicare) of the Social Security Act (the Act) to direct the Secretary of the
Department of Health and Human Services (HHS) to require Long-term Care
Hospitals (LTCHs), Inpatient Rehabilitation Facilities (IRFs), Skilled Nursing
Facilities (SNFs), and Home Health Agencies (HHAs) to report standardized
patient assessment data, data on quality measures including resource use
measures. The development of standardized data stems from specified assessment
domains via the assessment instruments that are used to submit assessment data
to CMS by these post-acute care (PAC) providers. The IMPACT Act requires CMS
to develop and implement quality measures from five measure domains: functional
status, cognitive function, and changes in function and cognitive function; skin
integrity and changes in skin integrity; medication reconciliation; incidence of
major falls; and the transfer of health information when the individual
transitions from the hospital/critical access hospital to PAC provider or home,
or from PAC provider to another settings. The IMPACT Act also delineates the
implementation of resource use and other measures in at least these following
domains: total estimated Medicare spending per beneficiary; discharge to the
community; and all condition risk adjusted potentially preventable hospital
readmission rates.
High Priority Domains for Future Measure Consideration:
CMS identified the following domains as high-priority for future measure
consideration:
- Making Care Affordable: An important consideration for the SNF QRP is to
better assess medical costs based on PAC episodes of care. Therefore, CMS is
considering developing efficiency-based measures such as a Medicare Spending
per Beneficiary measure concept.
- Communication/Care Coordination: Assessing resident care transitions and
rehospitalizations are important. Therefore, CMS is considering developing
measures that assesses discharge to the community and potentially preventable
readmissions.
- Communication/Care Coordination: Infrastructure and processes for care
coordination are important for the SNF QRP. The World Health Organization
regards implementing medication reconciliation as a standard operating
protocol necessary to reduce the potential for ADEs that cause harm to
patients. Preventing and responding to ADEs is of critical importance as
ADEs account for significant increases in health services utilization and
costs. Therefore, a medication reconciliation quality measure for SNF
residents is being considered for future quality measure development.
- Communication/Care Coordination: Discharge to a community setting is an
important health care outcome for patients in post-acute settings, offering a
multi-dimensional view of preparation for community life, including the
cognitive, physical, and psychosocial elements involved in a discharge to the
community. Being discharged to the community is an important outcome for many
residents for whom the overall goals of care include optimizing functional
improvement, returning to a previous level of independence, and avoiding
institutionalization. Therefore, a discharge to community measure for SNFs is
being considered for the future use in the SNF QRP.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
TrueCMS Program Specific Measure
Priorities and Needs document, which was released in April 2017.
Program History and Structure: The Home Health Quality Reporting
Program (HH QRP) was established in accordance with section 1895
(b)(3)(B)(v)(II) of the Social Security Act. Home Health Agencies (HHAs) are
required by the Act to submit quality data for use in evaluating quality for
Home Health agencies. Section 1895(b) (3)(B)(v)(I) of the Act also requires that
HHAs that do not submit quality data to the Secretary be subject to a 2 percent
reduction in the annual payment update, effective in calendar year 2007 and
every subsequent year. Data sources for the HH QRP include the Outcome and
Assessment Information Set (OASIS) and Medicare FFS claims. Data is publically
reported on the Home Health Compare website. The HH QRP measure development and
selection activities take into account established national priorities and input
from multi-stakeholder groups. Further, the Improving Medicare Post-Acute Care
Transformation of 2014 (IMPACT Act) amends title XVIII (Medicare) of the Social
Security Act (the Act) to direct the Secretary of the Department of Health and
Human Services (HHS) to require Long-term Care Hospitals (LTCHs), Inpatient
Rehabilitation Facilities (IRFs), Skilled Nursing Facilities (SNFs) and Home
Health Agencies (HHAs) to report standardized patient assessment data, data on
quality measures including resource use measures. The development of
standardized data stems from specified assessment domains via the assessment
instruments that are used to submit assessment data to CMS by these post-acute
care (PAC) providers. The IMPACT Act requires CMS to develop and implement
quality measures from five measure domains: functional status, cognitive
function, and changes in function and cognitive function; skin integrity and
changes in skin integrity; medication reconciliation; incidence of major falls;
and the transfer of health information when the individual transitions from the
hospital/critical access hospital to PAC provider or home, or from PAC provider
to another settings. The IMPACT Act also delineates the implementation of
resource use and other measures in at least these following domains: total
estimated Medicare spending per beneficiary; discharge to the community; and all
condition risk adjusted potentially preventable hospital readmission rates.
High Priority Domains for Future Measure Consideration:
CMS identified the
following domains as high-priority for future measure consideration:
- Patient and Family
Engagement: Functional status and functional decline are important to assess
for residents in HH settings. Patients who receive care while in a HH may have
functional limitations and may be at risk for further decline in function due
to limited mobility and ambulation. Therefore, measures to assess functional
status are in development.
- Making Care Safer:
Safety for individuals in a home-based setting is an important priority for
the HH QRP as persons in home health settings are at risk for major injury due
to falls, new or worsened pressure ulcers, pain, and functional decline.
Therefore, these concepts will be considered for future measure development.
- Making Care
Affordable: An important consideration for the HH QRP is to better assess
medical costs based on PAC episodes of care. Therefore, CMS is considering
developing efficiencybased measures such as a Medicare Spending per
Beneficiary measure concept.
- Communication/Care
Coordination: Assessing an individual’s care transitions and
rehospitalizations is important. Discharge to a community setting is an
important health care outcome for patients in post-acute settings, offering a
multi-dimensional view of preparation for community life, including the
cognitive, physical, and psychosocial elements involved in a discharge to the
community. Being discharged to the community is an important outcome for many
individuals for whom the overall goals of care include optimizing functional
improvement, returning to a previous level of independence, and avoiding
institutionalization. Therefore, CMS is considering developing measures that
assesses discharge to the community and potentially preventable readmissions.
- Communication/Care
Coordination: Infrastructure and processes for care coordination are important
for the HH QRP. The World Health Organization regards implementing medication
reconciliation as a standard operating protocol necessary to reduce the
potential for ADEs that cause harm to patients. Preventing and
responding to ADEs is of critical importance as ADEs account for significant
increases in health services utilization and costs. Therefore, a medication
reconciliation quality measure for individuals in a home health setting is
being considered for future quality measure development. Medication
reconciliation conceptually highlights care transitions and resident
follow-up.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
TrueCMS Program Specific
Measure Priorities and Needs document, which was released in April 2017.
Program History and Structure: The Long-Term Care Hospital (LTCH)
Quality Reporting Program (QRP) was established in accordance with section
1886(m) of the Social Security Act, as amended by Section 3004(a) of the
Affordable Care Act. The LTCH QRP applies to all LTCHs facilities designated as
an LTCH under the Medicare program. Data sources for LTCH QRP measures include
Medicare FFS claims, the Center for Disease Control and Prevention’s National
Health Safety Network (CDC’s NHSN) data submissions, and the LTCH Continuity
Assessment Record and Evaluation Data Sets (LCDS). The LTCH QRP measure
development and selection activities take into account established national
priorities and input from multi-stakeholder groups. Beginning in FY 2014, LTCHs
that fail to submit data will be subject to a 2.0 percentage point reduction of
the applicable Prospective Payment System (PPS) increase factor. Further, the
Improving Medicare Post-Acute Care Transformation of 2014 (IMPACT Act) amends
title XVIII (Medicare) of the Social Security Act (the Act) to direct the
Secretary of the Department of Health and Human Services (HHS) to require
Long-term Care Hospitals (LTCHs), Inpatient Rehabilitation Facilities (IRFs),
Skilled Nursing Facilities (SNFs) and Home Health Agencies (HHAs) to report
standardized patient assessment data, data on quality measures including
resource use measures. The development of standardized data stems from specified
assessment domains via the assessment instruments that are used to submit
assessment data to CMS by these post-acute care (PAC) providers. The IMPACT Act
requires CMS to develop and implement quality measures from five measure
domains: functional status, cognitive function, and changes in function and
cognitive function; skin integrity and changes in skin integrity; medication
reconciliation; incidence of major falls; and the transfer of health information
when the individual transitions from the hospital/critical access hospital to
PAC provider or home, or from PAC provider to another settings. The IMPACT Act
also delineates the implementation of resource use and other measures in at
least these following domains: total estimated Medicare spending per
beneficiary; discharge to the community; and all condition risk adjusted
potentially preventable hospital readmission rates.
High Priority Domains for Future Measure Consideration:
CMS identified the
following domains as high-priority for LTCH QRP future measure consideration:
- Effective
Prevention and Treatment: Having measures related to ventilator use,
ventilator- associated event and ventilator weaning rate are a high priority
for CMS as prolonged mechanical ventilator use is quite common in LTCHs and
respiratory diagnosis with ventilator support for 96 or more hours is the most
frequently occurring diagnosis.
- Effective
Prevention and Treatment (Aim: Healthy People/Healthy Communities): In
discussions with LTCH providers, it was noted that mental health status is an
important measure of care for LTCH patients. CMS is considering a Depression
Assessment & Management quality measure.
- Patient and Family
Engagement: While rehabilitation and restoring functional status are not the
primary goals of patient care in the LTCH setting, functional outcomes remain
an important indicator of LTCH quality as well as key to LTCH care
trajectories. Providers must be able to provide functional support to patients
with impairments. Thus, metrics showing change in self- care and mobility
function are under development.
- atient and Family
Engagement: CMS would like to explore measures that will evaluate the
patient’s experiences of care as this is a high priority of providers.
Therefore, the HCAHPS and Care Transition quality measure (CTM)-3 is being
considered.
- Making Care
Affordable: An important consideration for the LTCH QRP is to better assess
medical costs based on PAC episodes of care. Therefore, CMS is considering
developing efficiency-based measures such as a Medicare Spending per
Beneficiary measure concept.
- Communication/Care
Coordination: Assessing patient care transitions and rehospitalizations are
important. Therefore, CMS is considering developing measures that assesses
discharge to the community and potentially preventable readmissions.
- Communication/Care
Coordination: Infrastructure and processes for care coordination are important
for the LTCH QRP. Therefore, a medication reconciliation quality measure for
LTCH patients is being considered for future quality measure development.
Medication reconciliation conceptually highlights care transitions and
resident follow-up.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
TrueCMS Program Specific Measure
Priorities and Needs document, which was released in April 2017.
Program History and Structure: The Hospice Quality Reporting Program
(HQRP) was established in accordance with section 1814(i) of the Social Security
Act, as amended by section 3004(c) of the Affordable Care Act. The HQRP applies
to all hospices, regardless of setting. Proposed data sources for future HQRP
measures include the Hospice Item Set and the Hospice Consumer Assessment of
Healthcare Providers and Systems (CAHPS) survey. HQRP measure development and
selection activities take into account established national priorities and input
from multi-stakeholder groups. Beginning in FY 2014, Hospices that fail to
submit quality data will be subject to a 2.0 percentage point reduction to their
annual payment update.
High Priority Domains for Future Measure Consideration:
CMS identified the following domains as high-priority for HQRP future
measure consideration:
- Overall goal HQRP: Symptom Management Outcome Measures. There is a lack of
tested and endorsed outcome measures for hospice across domains of hospice
care, including symptom management (e.g.; physical and other symptoms).
Developing and implementing outcome measures for hospice is important for
providers, patients and families, and other stakeholders because symptom
management is a central aspect of hospice care.
- Communication/Care Coordination and/or Patient and Family Engagement:
Patient preference for care is difficult to measure at end of life when
patients may or may not be able to state their preferences, and may have
changes in their preferences. However, a central tenet of hospice care is
responsiveness to patient and family care preferences; as much as possible,
patient preferences should be incorporated into new measure development.
- Patient and Family Engagement: Measurement of goal attainment is naturally
linked to determining patient/family preferences. Quality care in hospice
should address not only establishing what the patient/family desires but also
providing care and services in line with those preferences.
- Making Care Safer: Timeliness/responsiveness of care. While timeliness of
referral to hospice is not within a hospices’ control, hospice initiation of
treatment once a patient has elected the hospice benefit is under the control
of the hospice. Responsiveness of the hospice during timeof patient or family
need is an important indicator about hospice services for consumers in
particular.
- Communication/Care Coordination: Measurement of care coordination is
integral to the provision of quality care and should be aligned across care
settings.
Current Measures: NQF staff have compiled the program's
measures in a spreadsheet organized according to concepts.
Index of Measures (by Program)
All measures are included in the
index, even if there were not any public comments about that measure for that
program.
Skilled Nursing Facility Quality Reporting Program
Full Comments (Listed by Measure)
(Program: Skilled Nursing Facility Quality
Reporting Program; MUC ID: MUC17-258) |
- What will happen to the other SNF quality measures if the single measure
being proposed is enacted? (Submitted by: Qualis Health)
- Need to Exclude any resident/patient who during the short stay has a
Prognosis less than 6 months or elects hospice during the course of stay.
The language reads: (4) Patients discharged on hospice; My question is if
the resident is ‘discharged on hospice does that mean they are D/Ced from the
facility? There is nothing on the MDS at the time of D/C that indicates they
are going to ‘hospice’... I also question if a BIMS of 7 or less is too low.
Low risk B&B QM which is alo a 7 on the BIMs & have residents with a
higher BIMS not capable of finding the bathroom or calling the staff if they
even know they need to go. So not sure the cut off should be at 7. .
(Submitted by: Focused Post Acute Care)
- Exclusion language reads: (4) Patients discharged on hospice; What about
the resident who goes home on a palliative plan of care because they do NOT
elect the insurance benefit of ''hospice'. I believe these residents should
be excluded as well. Also if they had a Prognosis less than 6 months during
their time in the nursing home as well. (Submitted by: Melody
Malone)
- Exclusion Language reads: 6) Patients who have dementia impairing their
ability to answer the questionnaire defined as having a BIMS score on the MDS
3.0 as 7 or lower. Any BIMS question that results in less than 15 requires
cueing. I believe any resident in the denominator, defined as: who respond to
the CoreQ: Short Stay Discharge questionnaire within two months of receiving
the questionnaire, who required cueing on the BIMS will not be able to
adequately complete the survey. Therefore I recommend the BIMS score be 15.
(Submitted by: Melody Malone)
- AOTA supports the development and execution of patient experience measures
related to SNF. Patient satisfaction surveys tend to be more subjective. AOTA
supports the use of the patient satisfaction scores from CoreQ, but recommends
replacing with a patient experience measure as soon as reasonable. (Submitted
by: American Occupational Therapy Association)
- We support the use of this measure. (Submitted by:
Ascension)
- CMS is currently testing a Patient Experience of Care Survey in other
Post-Acute Care settings. Consideration of this measure for the SNF QRP would
potentially implement a patient satisfaction measure that would be
inconsistent with the work CMS is currently piloting for the IMPACT Act. While
providers would prefer the reduced burden the 4 question CoreQ may provide in
comparison to the 58 question Patient Experience of Care Survey, has the CoreQ
demonstrated meaningful differentiation of quality between providers?
Endorsement of this measure was based upon testing from a limited number of
SNF providers. Has additional testing been performed to provide evidence of
meaningful variability between providers? (Submitted by: Uniform Data System
for Medical Rehabilitiation)
Appendix D: Instructions and Help
If you have any
problems navigating the discussion guide, please contact us at: mailto:mappac-ltc@qualityforum.org.
Navigating the Discussion Guide
- How do I get back to the section I was just looking at?
The
easiest way is to use the back button on your browser. Other options are using
your backspace button (which works for many browsers on laptops), or using the
permanent links at the upper right hand corner of the discussion guide. But
the back button is the best choice in most situations.
- Can I print the discussion guide out?
You can, but we don't
recommend it. Besides using a lot of paper (probably a couple hundred pages at
least), you'll lose all the links that allow you to move around the document.
For instance, if you're scrolling through the agenda and want to see more
information about a particular measure, the electronic format will allow you
to click a link, read more, and then bo back. If you're on paper, there will
be a lot of flipping through paper.
- If I can't print this out, how can I read it on the plane?
Although the Discussion Guide opens in a web browser, an internet connection
is not required to view the file.
- How do I know that I'm looking at the most recent version?
At
the top left corner of the discussion guide is a version number. At the
beginning of the in person meetings, the NQF staff will ask everyone to load
the most recent discussion guide version and will check that everyone has the
same version loaded.
- What electronic devices can I use to view the discussion guide?
We tried to make this as universal as possible, so it should work on your
laptop (PC, Mac, Linux), your tablet (iPad, Android), or your phone (iPhone,
Android). It should also work on many types of browsers (IE, Firefox, Chrome,
Safari, Opera, Dolphin,....). Please let us know if you have any problems, and
we'll troubleshoot with you (and improve the discussion guide for the next go
around).
- Why do I see weird characters in some places?
Because we're
joining data from many different sources, we do find some technical
challenges. This generally shows up as strange characters--extra question
marks, accented characters, or otherwise unusual items. We've been able to fix
many of these problems, but not all. We ask that you bear with us as we
improve this over time!
Content
- What is included in the discussion guide?
There are four
sections within this document:
- Agenda, with summaries of each measure under consideration
- Full information about each measure, including its specifications,
preliminary analysis of how this measure can advance the program's goals,
and the rationale by HHS for being included in the list
- Summaries for each federal health program being considered
- Public comments that have been received to date (Note that the
discussion guide may be released before the public comment period is
finished, in which case there will just be a placeholder for where comments
will go)
- How are the meeting discussions organized?
The meeting sessions
are organized around consent calendars, which are groups of measures being
considered for a particular program or groups of measures for a particular
condition or topic area. For each measure being discussed, this document will
show you the description, the public comments (if any), the summary of the
preliminary analysis, and the result of the preliminary analysis
algorithm.
Appendix E: Instructions for Joining the Meeting
Remotely
Remote Participation Instructions:
Streaming Audio Online
- Direct your web browser to: http://nqf.commpartners.com/.
- Under “Enter a Meeting” type in the meeting number: 457077
- In the “Display Name” field, type in your first and last names and click
“Enter Meeting.”
Teleconference
- Dial (888) 802-7237 for workgroup members or (877) 303-9138 for public
participants to access the audio platform.